19 Sex Work and the ITPA

Severyna Magill

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Learning Aims:

By the end of this module you will have learnt about the language used within the sex industry, for example the difference between “sex work” and “prostitution;” a brief overview of the prostitution policy in India from 1860 ‘til 1978; and from 1978 to the present; the main body of legislation that governs sex work within India, and the position of sex workers under the present legislation.

Introductory Note:

Whilst we acknowledge that there are male sex workers within this Human Rights of Women course our focus will be exclusively on female sex workers, and we will be using the female pronoun even though many of the examples we give may equally affect male sex workers. Further, we recognise that male sex workers often face double discrimination on account of their profession and for being a minority gender within the profession. For more information on this area, please see: https://www.unodc.org/pdf/india/publications/htvs_miniweb/dancing_boys.pdf.

Definitions of the Sex Industry in General

The social actors who make up the sex industry are not simply those who transact in sex directly but are also the business owners, investors, independent contractors and other non-sexual employees of such establishments that facilitate the entire process. This module will focus on the position of the sex worker herself. She is any person who engages in the exchange of a sexual act/service in exchange for money or goods. The sex industry extends to the sites of activity, including but not limited to brothels, bars, restaurants, motels, hotels, flats, massage parlours, offices, cars/vans or anywhere that sex is offered commercially (including occasionally).

 

The social position of women within the sex-industry:

A significant number of women within the industry have limited other employment prospects. A recent study completed by the UNDP (United Nations Development Programme) and the UNFPA (United Nations Family Planning Association) states that from 73 female sex workers they interviewed from the Asia-Pacific region only 11 had completed secondary school. Many of the participants had been victims of gender discrimination and had been forcibly taken out of school in order to start earning money for the family (it is likely due to patriarchal cultural stereotypes male siblings would have been allowed to stay in school longer). Some participants in the study had been entered into child marriages by their parents, some had fled abusive marriages, others had been widowed early, possibly because of child marriage to a much older man, and some had “entered sex work after being thrown out of their family home or ostracized because of the stigma related to premarital sex, even when it was sexual abuse.” Some women started working in the profession either due to coercion from family members/partners or due to the coercive nature of their lived situation. 33% of the participants had “experienced sexual abuse or rape in their childhood and/or adolescence from older cousins, uncles, other relatives, teachers, sibling’s friends or fellow school mates.” In recognition of the lived reality for many women engaged in the sex-work industry, their lack of qualifications, access to family support (most women are likely to have moved to cities to seek employment, including those who have not run away from their marital/natal families due to abuse/ostracisation) and their vulnerable social position (a significant number of women have no formal fixed address as many live and work in informal/illegal brothels), some legislation deliberately does not criminalise the selling of sexual acts. This is because it did not want to place already vulnerable women at risk of further marginalisation, oppression or fear of arrest.

“Sex Work” and “Prostitution”

The language used to define sex work is critical in establishing the relationship between the sex industry and human rights. Identifying sex work as “work” or denotes both a type of labour as well as an income generating activity. Such an understanding extends recognition of the basic human rights and needs for decent working conditions to those who are part of this industry. This module will use the term “sex work” and not “prostitution” as it plays a role in enabling sex-workers to articulate their realities. This definition is useful because of the flexibility that it provides in terms of expounding on the various related activities, including escorting, street-based sex work, massage, prostitution, dance, pornography, acting/performing, professional domination and submission, fetish, and phone sex work, etc. (This is not an exhaustive list). It is also the preferred term used by the UN and World Health Organisation.

The terminology does, however, have its limitations. More often than not, many individuals do not prefer to associate themselves with the term sex worker due to the criminal element and stigma often associated with it. Some (radical) feminists have also stated that calling it work makes it appear more as a freely entered into profession and marginalises recognition of the coercive environment and vulnerable position of women within society that results in her having few other income generating options. This is an issue that needs tackling at the policy level as well as the activism level.

Evolution of the ‘Prostitution Policy’ in India

The Preamble of the 1949 Indian Constitution provides for justice, liberty, equality, and “the dignity of the individual.” These rights have further been articulated through the positive rights that are enshrined in the Fundamental Rights section of the Constitution, Articles 12 to 32. Article 15 prohibits discriminatory treatment of all individuals irrespective of race, religion, caste, sex, and/or place of birth. Article 23 prohibits human trafficking and slavery. Article 24 prohibits employment of children in hazardous employment. In addition to this set of positive rights that are legally enforceable, there is a set of directive principles laid down as desirable objectives for the state to attain. Although they are not legally enforceable, they include rights with regard to livelihood, a clean environment, protection of all citizens (including children) against abuse, just and human work environment, etc. Furthermore, the Indian judicial system with its expansive interpretation of rights has attempted to read these directive principles into the fundamental rights in cases of Public Interest Litigation.

India, despite having constitutional and other legislative provisions that prohibit discrimination and being a signatory to numerous international agreements on women’s rights that actively prohibit discrimination and exploitation based on gender have not successfully managed to protect the human rights of sex workers. Elevated levels of violence, child sex workers, a lack of access to healthcare, including preventative health care such as information regarding safe sex practises and accessible health screening has resulted in high levels of HIV and other sexually transmitted infections. This can be linked to the immorality and stigma associated with sex work itself and to the lack of recognition of sex work that attracts basic human rights.

Domestic Laws in India regulating sex-work 1868 – 1978:

The prevalent laws with regards to the sex industry in India originated during colonialism. One of the first legislations to deal with the matter was the Contagious Disease Act of 1868. This Act segregated sex trade workers and isolated them to ghetto-esque areas like Sonagachi in Calcutta. Sex workers were affiliated with being vectors of disease and as a result were subject to police harassment under the regime of the criminalization of sex work that then existed in the colonial world. This Act was later repealed in 1889 through a movement led predominantly by white female missionaries, who accorded victim status to sex workers within their “rescuing” discourse.

Upon decolonization, India became part of the global trafficking abolitionist movement, and in 1950 signed the UN Declaration on the Suppression of Trafficking. In consonance to this, it further signed the All India Suppression of Immoral Traffic Act (SITA) in 1956, which was later amended in 197818 and again in 1986 when it was renamed the Immoral Traffic Prevention Act (ITPA) as it is known today. The ITPA is discussed in more detail below.

The Indian Penal Code 1860 (IPC) also has several provisions that deal with the sex industry. Offences under the IPC include kidnapping/abducting or criminally intimidating a woman against her will for the purpose of illicit sexual intercourse (section 366); “importing” a girl below the age of 21 from a foreign country (section 366 B); kidnapping/abducting any person and subjecting them to grievous hurt, slavery, or unnatural lust (section 367); trading in or detaining a person as a slave (section 370); selling or letting on hire or otherwise procuring a minor below the age of 18 with knowledge that such minor will be used for the purpose of prostitution or illicit intercourse or for any immoral or unlawful purposes (sections 372 and 373).

Domestic Laws in India regulating sex-work 1978 – present:

The ITPA (1986) is the primary legislation that regulates trafficking and sex work in India today. When it was drafted and enacted it was done so considering the vulnerability of women who enter the profession: the ITPA recognises that the majority of women within the profession enter the industry out of a necessity to financially support themselves and their dependents and may have few other professional options. Recognising the vulnerability of sex workers, the Act focuses on criminalising elements they feel may coerce women to work in the industry such as pimps, brothel owners, and those benefitting from the earnings of sex workers.

The ITPA is however problematic from a rights-based perspective: It does not make a distinction between consensual and non-sexual sex work, therefore equating all sex work to prostitution. Whilst it does not criminalize sex work, it clamps down on ancillary mechanisms such as brothel keeping (section 3), living off the earnings of prostitution (section 4), procuring (section 5), practicing of prostitution in public (section 7), and soliciting (section 8). By criminalising these provisions, it makes practicing sex work safely and legally virtually impossible. The following section will critique the Act from equality, rights-based, gender-sensitive approach.

Critique of the ITPA: 

 

Definition of a Brothel and Rights to a Workplace:

Article 3 of the ITPA provides a punishment for “keeping a brothel or allowing premises to be used as a brothel.” Part one of the provision is clearly aimed at targeting “[a]ny person who keeps or manages, or acts or assists in the keeping or management of, a brothel.” This was intended to act as a deterrent to anyone who may be exploiting women for their own financial or other benefit. Part two of the same provision, however, blurs this distinction by including: “the tenant, lessee, occupier or person in charge of any premises.” This, therefore, includes anyone using a room within a brothel and labels them as a tenant, lessee or occupier and also criminalises this. The consequence for sex workers is that if they want to work in “any house, room, conveyance or place, or any portion of any house, room, conveyance or place” they are subject to a punishment of up to two years in prison for a first conviction or rigorous imprisonment for 3-7 years and a fine of up to 2lakh rupees for a second conviction. Further, the definition of a brothel also includes any location that is used for the “mutual gain of two or more prostitutes.” These provisions are highly problematic. All people have the right to safe and secure working conditions, as provided for under Article 7 of the ICESCR, Article 3.1 of the Occupational Safety and Health Convention, 2006, and the National Policy on Safety, Health and Environment at Work Place adopted by the Government of India’s Ministry of Labour and Employment. If sex workers are prevented from even sharing a work location between two people on a consenting basis, they are forced to work in isolated and much more dangerous conditions.

If sex workers work in a building with other sex workers, they are more likely to be able to set house rules for all clients. This could include requiring all customers to wear barrier forms of contraception like condoms which help to reduce the number of unwanted or unplanned pregnancies and reduce the transmission of sexually transmitted infections and HIV/AIDS. If a woman is working alone, she may ask a client to wear contraception. If he does not want to wear a condom, he might leave and seek satisfaction elsewhere. If she is in a financially vulnerable position (which most sex workers are), she may then agree to have intercourse without using contraception as her need for money for daily survival becomes a more immediate and visible need than the threat of pregnancy or contracting an infection. If a woman is working is the same location as another sex worker they may both require customers to wear contraception. In this case, even if the customer goes to another sex worker if she has the same rule he is more likely to comply. Women are therefore able to more successfully assert their conditions of work and have them complied with when they are working together than when they are working alone.

Further if anti-social behaviour, verbal abuse, physical violence or other forms of unwanted behaviour occurs when women are working together, they are more able to come to support and help each other to stop the violence than if they are working alone. If a woman is working alone, she is not able to call for help if she is being physically assaulted and is, therefore, more physically vulnerable. Further, if she is working alone in isolated conditions, she may also be more vulnerable to having the terms of the contract violated and suffering violence that was not agreed to if she can not call for support. She may also be more vulnerable to not being paid and not as able to assert pressure on the client than if she was working with other women where a collective voice could be raised and more pressure put on the client.

The provisions in the ITPA that define a brothel and therefore regulate the locations where sex work may take place, therefore, despite the intention of not criminalising the sex worker, reinforce the vulnerability and increase the risks and dangers to the woman. If work places were not prohibited by the law, they might also be subject to minimum standards which are currently not present.

Powers to Raid Brothels & Remove Persons Therein:

Article 15 of the ITPA grants the police the power to raid a suspected brothel without a warrant: “Notwithstanding anything contained in any other law for the time being in force, whenever the special police officer or the trafficking police officer as the case may be, has reasonable grounds for believing that an offence punishable under this Act has been or is being committed in respect of a person living in any premises, and that search of the premises with warrant cannot be made without undue delay, such officer may, after recording the grounds of his belief, enter and search such premises without a warrant.”31 The section also puts requirements on the police in an effort to ensure their powers are used responsibly. These requirements include, amongst others, to ensure: that “two or more respectable inhabitants (at least one of whom shall be a woman) . . . attend and witness the search” (this ceases to apply if a female is conducting the search) 15(2); and “(6-A) The special police officer or the trafficking police officer, as the case may be, making a search under this section shall be accompanied by at least two women police officers” article 15(6)(A).

In reality, the requirements to either have female officers present or to bring at least one female witness from the local community and rarely fulfilled. The Act further goes on to state in article 15(4) that the police officer “entering any premises under sub-section (1) shall be entitled to remove therefrom all the persons found therein.” This provision significantly affects the relationship of the sex worker with the police. The intention was that any worker found would then be placed in a “protective home” or “corrective institution” (article 19(3)(i) and (ii). Such protective rules where the police were expected to act as saviours ‘rescuing’ women from their situation and forcing them to be rehabilitated, often in underfunded, under-resourced or non-existence homes and the violation of the entry requirements above increase the fear and distrust among the sex workers and therefore increases the distance between them and the police.

As working in a brothel is illegal the police often search brothels without a warrant (legally), but often without female officers or witnesses (an abuse of the law). Women are then left in a vulnerable position where they may be subjected to harassment at the hands of male police officers, including but not limited to physical, sexual, and mental abuse. In some cases, women are threatened with arrest for working in a brothel or are made to either pay monetary bribes to or perform sexual acts on the officers to avoid arrest. The workers are unable to seek justice and protection of their rights as they are scared of the consequences of working in what may be defined as a brothel.

The ITPA also enables magistrates to order the removal of any person from a site that sex work is carried out (article 16). This is a gross violation of the sex worker’s right to shelter and may lead to forced homelessness. This additionally makes it difficult for sex workers to find alternative locations that are both safe in terms of shelter and also enabling in terms of their profession, due to poverty and the prevalent social stigma. This hardship is further reinforced with the Act’s requirement that sex workers may not work in any public place, or place “within a distance of two hundred meters of any place of public religious worship, educational institution, hotel, hospital, nursing home or such other public place of any kind” article 7(b). Any violation of this requirement may result in a prison sentence of up to 3 months. Such policies risk pushing sex-workers who are procuring clients into narrow alleys and places that have less pedestrian traffic. This decreases their chances of being helped if they are in an uncomfortable situation and reinforces the lack of respect and tolerance towards their work which further diminishes their status as equals within society with their form of income generating activity labelled as devious and not acceptable to society.

Procurement of Clients:

The ITPA also regulates the procurement of sex by clients. This was drafted with the intention of targeting the purchaser, and not the sex worker as it recognises the vulnerable and socially disadvantaged position of the sex worker. The drafters of the legislation deliberately didn’t want to punish the sex worker or put them at further risk of disadvantage, and that is why the purchaser, or client, and not the seller is criminalised.

Under the Act any person who “attempts to procure a person whether with or without his/her consent, for the purpose of prostitution” Article 5(a) “shall be punishable on conviction with rigorous imprisonment for a term of not less than three years” Article 5(d). This was clearly intended to act as a deterrent towards those who were considering the purchase of sex and to try to safeguard the sex worker from harm. Despite these intentions in practice the safety of the sex worker is still very much affected. If neither the purchase nor the selling of sex is criminalised then neither party fears being arrested at any stage of the negotiation process. When one party is criminalised, say in this case the purchaser, they feel scared of being arrested when they are approaching a sex worker. The reality on the ground, therefore, means that prior to the act of purchasing is made illegal a negotiation may take several minutes before an agreed service and exchange is agreed upon.

Time to negotiate a fee for a specific service enables the sex worker to also assess the safety of the client and whether she feels comfortable engaging with them; time to negotiate and agree to what the client is requesting and any conditions associated with this such as the sexual act itself, how long it will last for, whether contraception will be worn; and time to negotiate what she agrees to as a financial (or other) reward/payment. These negotiations typically take place in doorways, on pavements by the windows of parked cars or near scenes of social interaction such as bars, hotels, and clubs. When the purchase or selling is criminalised, either party is likely to be unwilling to engage in a negotiation as any prolonged communication may raise the suspicions of the police or law enforcement officials. The result is that the worker feels pressurised to enter a purchaser’s car/other location without having had as much time to negotiate. When she is already in the car/bedroom/other her negotiating power is no longer as high; it’s harder for her to work up a rapport, to flirt, to walk away or tease the client with suggestions and smiles all of which may also help her to agree her price. She is also less able to reject any propositions she is uncomfortable with or to have the time to ensure she feels safe with the client. These negative consequences on the negotiating process are experienced on a routine basis, far more often than purchasers are actually arrested. They may, therefore, be said to disproportionately affect women. Laws intended to protect the sex worker and criminalise the purchaser do in fact then harm the sex worker.

Living Off the Earnings of a Sex Worker:

Article 4 of the ITPA criminalises anyone above the age of 18 “for living on the earnings of prostitution.” It goes on to state: “[Any person] who knowingly lives, wholly or in part, on the earnings of the prostitution of any other person shall be punishable with imprisonment for a term which may extend to two years.” This section was clearly intended to target pimps or other persons who were forcing women to work as sex workers and making a profit. Whilst this is a praiseworthy aim the provisions may be abused to the detriment of a sex worker and her family.

The strict drafting of the paragraph results in it reading:

“Where any person over the age of eighteen years is proved,— (a) to be living with, or to be habitually in the company of, a prostitute; or (b) to have exercised control, direction or influence over the movements of a prostitute in such a manner as to show that such person is aiding abetting or compelling her prostitution; or (c) to be acting as a tout or pimp on behalf of a prostitute, it shall be presumed, until the contrary is proved, that such person is knowingly living on the earnings of prostitution.”

By presuming guilt until the contrary is proved the provision was drafted to have a deterrent power to deter potential pimps from selling women. It also recognises the different power status between a sex worker and a pimp and that a paper trail of evidence may be hard to establish. Therefore the cohabiting or the ‘habitually in the company of’ provision was seen as sufficient to demonstrate that a relationship of power or control of a pimp existed; the ‘influence over the movements of a prostitute, ’ e.g. to send women to clients was seen as sufficient to prove that work was taking place as a result of this relationship. This may adversely affect a sex worker’s life choices and actively discriminate against her and her dependents on several grounds.

If a woman chooses to engage in sex work in order to financially support her partner, children and/or other dependents her dependents are at risk of being charged with living off the earnings of a prostitute if they are over the age 18. This is a violation of her right to privacy, and freedom from arbitrary interference by the state in to her family life and home as guaranteed in the ICCPR article 17(1) as it interferes with both how she chooses to earn money when sex work itself is not illegal, and how she chooses to manage and allocate her household budget. Further, it is a violation of the ICCPR’s non-discrimination provision in article 2(1) as it distinguishes her as a mother, wife, partner, daughter, because of her profession, from other women who may equally support their dependents but with money from other, equally legally permissible, forms of employment.

It is also a violation of freedom of association ICCPR article 22, and equal protection of the law ICCPR article 26 for her and her dependents. Imagine for example the child of a sex worker who wishes to pursue higher education beyond the age of 18 or who needs financial support from their mother/sister etc. to support them or a husband or partner who may be unemployed or for medical reasons be unable to earn either on a temporary or permanent basis. They as an individual who has a financial benefactor who is not a sex worker would be able to consensually receive money from their relative free from the burden of fear that they may then be charged with living off the earnings of a prostitute and then have the burden to prove their innocence when any other relative would not. Placing this fear and burden on the financial dependents of a sex worker is, therefore, a violation of their freedom of association.

Forced Medical Testing and Degrading Treatment:

The ITPA also provides for forcible testing of sex workers for sexually transmitted infections. Such a provision in the law is a clear breach of equality and privacy of the sex workers. Such testing, especially for women involves intimate medical examinations that physically penetrate the body. If these are performed in an insensitive way, they can be painful, humiliating and degrading. This further adds to their differential treatment and reinforces their humiliation as well as dehumanizes them on the basis of their choice of profession. Subjecting anyone to cruel or degrading treatment or punishment is a violation of article 7 ICCPR.

The ITPA fails to provide substantive support for the workers by providing them with accurate and accessible information regarding safe sex practises and how to minimise contracting sexually transmitted infections which would fulfil their rights to health as found in the ICESCR and in the Women’s Convention. The state could, for example, provide free or subsidised barrier forms of contraception that would reduce the transmission of some major sexually transmitted infections, including HIV/AIDS or chlamydia which can result in infertility. It also fails to offer appropriate constructive support that helps to recognise the powerlessness of many women to engage in the formal workforce. A better strategy would be to offer them relevant skills in a supportive environment that would allow them to keep living with and supporting their family whilst fulfilling their economic right to work and to not discriminate against them because of their choice (ICESCR art 1, CEDAW art. 1).

Overall the current legislation in force in India today is considerate to women’s interests but does not focus on the fulfilment of women’s rights. In this way, the ITPA is very much a document of its time, the 1970s, and needs to be re-imagined to the new generation’s understandings of how to best protect women’s rights in a way that is sensitive to their lived reality. Since the coming into force of the ITPA despite its provisions for corrective homes and re-training of sex workers to encourage their ‘emancipation’ from the industry sex-work continues to be a reality and a continuing profession. New efforts should be made to provide minimum health and safety standards and to continue ensuring, but to a higher and more accessible standard, that opportunities to leave the sex-industry are created and supported.

 

Conclusion:

This module has covered definitions used in the sex industry in general, the social position of most women within the sex-industry, the evolution of law regulating sex work in India from 1868 to today, and has critiqued, from a women’s rights perspective, some of the provisions of the current legislation.

you can view video on Sex Work and the ITPA

Reference

  • The Immoral Traffic (Prevention) Act, 1956: http://wcd.nic.in/act/itpa1956.htm
  • International Covenant on Economic, Social and Cultural Rights: http://www.ohchr.org/EN/ProfessionalInterest/Pages/CESCR.aspx
  • Convention on the Elimination of All Forms of Discrimination against Women New York, 18 December 1979: http://www.ohchr.org/EN/ProfessionalInterest/Pages/CEDAW.aspx
  • East Meets Westwood: http://magazine.ucla.edu/year2004/winter04_03_06.html
  • All India Network of Sex Workers (AINSW): http://ainsw.org/about.php
  • National Network of Sex Workers India (NNSW): http://www.nswp.org/news-story/the-national-network-sex-workers-india-join-nswp-and-aswa-decrying-the-latest-attack-sex-
  • Durbar Mahila Samanwaya Committee (a collectivization of 65000 sex workers, functions as an exclusive forum of female, male and transgender sex workers in West Bengal): http://durbar.org/
  • Thanks for the mention? Sex Work and the national HIV/AIDS strategy for the United States: http://www.bestpracticespolicy.org/2015/07/31/thanks-for-the-mention-sex-work-and-the-national-hivaids-strategy-for-the-united-states/
  • Human Trafficking Cases Jump in India; Convictions Decline!, Pranav Garimella: http://www.indiaspend.com/investigations/human-trafficking-cases-jump-in-india-convictions-decline-23536
  • World Health Organisation. (2005), World Health Organisation: http://www.who.int/gender/documents/sexworkers.pdf
  • ‘The Right(s) Evidence: Sex Work, Violence and HIV in Asia; A Multi-Country Qualitative Study.’ Authors: Manjima Bhattacharjya, Emma Fulu and Laxmi Murthy with Meena Saraswathi Seshu, Julia Cabassi and Marta Vallejo-Mestres. Published by UNDP & UNFPA, 2015: http://asiapacific.unfpa.org/sites/asiapacific/files/pub-pdf/Rights-Evidence-Report-2015-final_0.pdf
  • ‘Sex Workers: Part Of The Solution An analysis of HIV prevention programming to prevent HIV transmission during commercial sex in developing countries’ Cheryl Overs for the World Health Organisation (2002) p. 2 Available here: http://www.who.int/hiv/topics/vct/sw_toolkit/115solution.pdf
  • Agustin, L. (2005) New Research Directions: The Cultural Study of Commercial Sex, 8 Sexualities 618—631, 622; see also:  ‘The Right(s) Evidence: Sex Work, Violence and HIV in Asia; A Multi-Country Qualitative Study’ Authors: Manjima Bhattacharjya, Emma Fulu and  Laxmi Murthy with Meena Saraswathi Seshu, Julia Cabassi and Marta Vallejo-Mestres. Published by UNDP & UNFPA. 2015. Available at:
  • http://asiapacific.unfpa.org/sites/asiapacific/files/pub-pdf/Rights-Evidence-Report-2015-final_0.pdf
  • ‘Sex Work and Health: A Question of Safety in the Workplace’ Priscilla Alexander, JAMWA Spring 1998 Vol.53, No.2. Available at: http://esplerp.org/wp-content/uploads/2012/08/Sex-Work-and-Health-A-Question-of-Safety-in-the-Workplace.pdf
  • ‘UNAIDS Guidance Note on HIV and Sex Work’ (2012): http://www.unaids.org/sites/default/files/sub_landing/files/JC2306_UNAIDS-guidance-note-HIV-sex-work_en.pdf
  • Sex Workers: Part Of The Solution An analysis of HIV prevention programming to prevent HIV transmission during commercial sex in developing countries’ Cheryl Overs for the World Health Organisation (2002) Available here: http://www.who.int/hiv/topics/vct/sw_toolkit/115solution.pdf
  • ‘Sex Work and the Law In Asia And The Pacific’ (2012): http://www.undp.org/content/dam/undp/library/hivaids/English/HIV-2012-SexWorkAndLaw.pdf
  • ‘Exploring the Dynamics and Vulnerabilities of HIV Transmission Amongst Sex Workers in the Palestinian Context’ A UN Women Operational Research – Occupied Palestinian territory (2011): http://www.unwomen.org/~/media/headquarters/media/publications/en/exploringthedyna micsandvulnerabilitiesofhiv.pdf
  • Van der Meulen, E. Durisin, E & Love, V. Selling Sex 2-3 (1st ed.). India Const. Preamble, Ministry of Law and Justice, Government of India: http://lawmin.nic.in/olwing/coi/coi-english/coi-indexenglish.html
  • Contagious Disease Act 1869: http://ozcase.library.qut.edu.au/qhlc/documents/qr_heal_act_1868_31_Vic_No40.pdf
  • ‘The Right(s) Evidence: Sex Work, Violence and HIV in Asia; A Multi-Country Qualitative Study.’ Authors: Manjima Bhattacharjya, Emma Fulu and Laxmi Murthy with Meena Saraswathi Seshu, Julia Cabassi and Marta Vallejo-Mestres. Published by UNDP & UNFPA, 2015: http://asiapacific.unfpa.org/sites/asiapacific/files/pub-pdf/Rights-Evidence-Report-2015-final_0.pdf