For
many in India, the LGBTQ+ concept may appear as a relatively new Western
import, raising concerns that it might overshadow the country’s rich cultural
heritage. Some still perceive it as a psychological issue in need of a cure.
The battle for the LGBTQI+ community extends beyond the recognition of their
rights to fostering a society where these rights can be embraced, making them
more inclusive rather than isolating. This research article delves into India’s
historical relationship with homosexuality, with a focus on the challenges
faced during the Colonial Period and the subsequent legal battles that
transformed LGBTQ+ rights. Furthermore, it sheds light on the absence of
essential rights such as marriage, adoption, protection from sexual harassment,
domestic violence, and accommodation, emphasizing that legal recognition alone
falls short of addressing their needs. We will also explore the ongoing efforts
across countries to integrate the Queer community into the fold of societal
acceptance and legal protection.
KEYWORDS:
Homosexuality,
LGBTQ in India, Queer Community, Fundamental Rights, Recognition of Marriage, Section
377, Discrimination, Adoption Rights, Violence against LGBTQI+
INTRODUCTION:
India, with its rich cultural history, has been a battleground for various struggles, including the fight for LGBTQ+ rights aimed at securing acceptance and acknowledgment. Amid these battles, the fight for LGBTQ+ rights has often lingered in the shadows, underestimated and underappreciated. This struggle plays out on two significant fronts: the societal arena, marked by lingering prejudices and discrimination, and the legal landscape, where the LGBTQ+ community fought tirelessly from 2001 to 2018 to get rid of colonial-era legislation in the form of Section 377 of the Indian Penal Code. However, even after its repeal, this law left a long-lasting impact on society. The Navtej Singh Johar judgment [1] emerged as a milestone, not only decriminalizing heterosexual relationships but also broadening the understanding of ‘gender’. Although the legal triumph marked a substantial advancement, the journey toward complete equality for LGBTQIA+ individuals in India is far from over. Ongoing issues such as discrimination, harassment, and violence against LGBTQIA+ people remain pressing concerns. Additionally, numerous marginalized groups within the LGBTQIA+ community encounter substantial obstacles on the path to acceptance and inclusion.
HOMOSEXUALITY
IN INDIA:
In
traditional Hindu literary sources, explicit discussions of homosexuality are
lacking, but these texts do contain instances of homoerotic encounters and the
presence of third-gender characters within their narratives. This can be
observed in texts like the Vedas, Mahabharata, Ramayana, Puranas, and
Upanishads [2]. For example, in the Mahabharata, characters such as Brihannala
and Shikhandi illustrate the acceptance of diverse identities in Indian
mythology. In the past, various terms were used to describe people’s sexual
identities. These terms, including “tritiya prakriti” for dual
qualities, “napumsa” for those lacking manhood, “nastriya”
for those lacking womanhood, “kliba” for individuals unable to engage
with women, “shandha” for those with female-associated qualities,
“svairini” for same-sex relations, and “stripumsa” for
male-associated qualities, were employed in ancient India to describe diverse
gender identities and orientations [3]. Furthermore, the poetry and literature
from the Mughal period also depict diverse sexual orientations and expressions
from that era [4].
STRUGGLE DURING COLONIAL PERIOD:
Homosexuality
has a historical presence in India’s cultural heritage, but it became
stigmatized due to various historical and societal influences. During the
colonial era, Section 377 was introduced, encompassing the entire LGBTQ+
community, and additional acts targeted the transgender community. Derogatorily
referred to as ‘eunuchs,’ transgender individuals faced discrimination. In
1897, the British introduced an amendment to the Criminal Tribes Act of 1871,
making baseless presumptions about the criminal tendencies of ‘eunuchs.’ This
law-imposed registration requirements and severe restrictions, preventing them
from dressing as their identified gender or participating in public
performances. Even after the repeal of the Criminal Tribes Act in 1949, similar
discriminatory laws persisted, leading to continued oppression and control of
transgender individuals [5]. The draconian act’s repeal in 1949 did not erase
the stigma it brought, and Section 377 continued to haunt the LGBTQ+ community
in India until its repeal in 2018.
RESISTANCE
FROM SOCIETY:
Society
often shapes its opinions and perceptions based on individual social upbringing
and education. When school curricula fail to promote critical thinking, it
leaves little room for alternative ideas, relying on textbook images and the
guidance of teachers who typically adhere to conventional gender norms.
Unfortunately, higher education in India follows a similar pattern, where
gender definitions remain confined to the binary concept of male and female.
Social upbringing further reinforces these beliefs, cementing traditional
gender roles. India, dominated by a patriarchal society, struggles to adapt to
evolving perspectives on gender and sexuality, impeding progress toward
equality. The role of the state cannot be overlooked, especially when its ideology
aligns with these conventional norms, perpetuating the struggle for Queer
rights. The resistance from society is evident in the tragic suicides that have
occurred. Among 135 analyzed cases, 54.5% involved multiple stressors,
primarily stemming from social stigma [6]. In 1988, the temple wedding of two
women made headlines, leading to their arrest and job loss after a photo leak.
From 1992 to 2000, fifteen joint same-sex suicides were documented in Kerala,
often driven by impending arranged marriages [7]. Even today, cases of suicide
linked to LGBTQI+ issues continue to be reported nationwide [8] [9]. Despite
the decriminalization of queer relationships, violence and oppression persist,
highlighting the ongoing struggle for recognition.
THE
LGBTQ+ RIGHTS MOVEMENT IN INDIA [10]:
In
1991, the LGBTQI+ movement in India gained significant momentum with the
release of the groundbreaking report titled “Less Than Gay: A Citizens’
Report on the Status of Homosexuality in India” by a collective known as
Aids Bhedbhav Virodhi Andolan (ABVA) [11]. This report, which openly demanded
queer rights, broke societal taboos and shared the stories of hundreds of
LGBTQI+ individuals [12]. Around the same time, activist Giti Thadani initiated
a network called Sakhi in Delhi, providing a platform for lesbian women to
connect through letters. A pivotal moment occurred when Prince Manvendra Singh
Gohil [13] from the Gujarat royal family publicly declared his homosexuality,
inspiring others to ‘come out’ and openly discuss their sexual orientation.
Following these events, various gay pride parades were organized nationwide.
The first gay pride parade in Kolkata, which began in 1999 [14], marked the
commencement of these parades in different parts of the country. Literary and
scholarly works in the late 1980s and early 1990s, along with other writings
from this period, contributed to the growing LGBTQI+ rights and acceptance in
the country. “A Lotus of a Different Color: An Unfolding of the Asian Gay
and Lesbian Experience” (1993), edited by Rakesh Ratti, was among the
pioneering anthologies that explored the experiences of the South Asian queer
diaspora during this time. Simultaneously, mathematician Shakuntala Devi’s
work, “The World of Homosexuals” (1977), which had received limited
attention before, gained renewed interest. Moreover, R. Raj Rao’s collection of
short stories, “One Day I Looked at My Flat in Soul City” (1995),
fearlessly portrayed the pain and suffering faced by queer individuals in India.
Hoshang Merchant’s “Yaraana: Gay Writings from South Asia” (1999)
played a crucial role in compiling diverse genres of queer writings from India
[15].
LEGAL
MILESTONES IN THE JOURNEY OF LGBTQ+ RIGHTS:
In
December 2001, the Naz Foundation, an NGO advocating for gay rights, filed a
Public Interest Litigation (PIL) seeking the legalization of gay sex among
consenting adults. The Delhi High Court dismissed this PIL in 2004, stating
that there was no cause of action in favor of the Petitioners and that the
petition couldn’t be entertained to examine the academic challenge to the
constitutionality of the legislation. On appeal, the Supreme Court set aside
the High Court’s order and remitted the matter back to the court. Upon
re-examination, the Division Bench of the Delhi High Court [16] read down
Section 377 of the IPC to exclude consensual homosexual sexual activity between
adults. However, on appeal, a two-judge Bench of the Supreme Court, in Suresh
Kumar Koushal v. Naz Foundation [17], reversed the judgment of the Delhi High
Court. The review and curative petitions against this decision were also
dismissed. In 2014, the National Legal Services Authority v. Union of India
(NALSA) [18] judgment by the Supreme Court marked a turning point. It affirmed
the constitutional right of transgender persons to self-identify their gender
without medical reassignment, recognizing the rights to life, dignity,
autonomy, gender identity, and sexual orientation. This judgment galvanized the
transgender rights movement in India and led to the inclusion of a third gender
category on official documents. It also reinvigorated challenges to Section
377, the law criminalizing consensual adult same-sex relationships. The 2017
Puttuswamy v. Union of India [19] judgment established the right to privacy,
including the right to sexual orientation and gender identity. This further
fueled the legal challenges against Section 377. Finally, in September 2018,
the Supreme Court in the Navtej Singh Johar case, led by the Chief Justice,
unanimously declared Section 377 unconstitutional. This judgment acknowledged
the fundamental rights of sexual and gender minorities and emphasized the right
to life, dignity, identity, and sexual orientation. The landmark Navtej Johar
judgment transcended anti-sodomy laws worldwide by recognizing the rights of
all sexual minorities within the LGBTQ+ community.
QUEST
FOR OTHER RIGHTS:
The
Navtej Singh Johar Judgment was undoubtedly a groundbreaking moment in India’s
LGBTQ+ rights movement. However, achieving true equality for the LGBTQ+
community entails more than just decriminalization. To ensure their full
inclusion in various aspects of society, it is imperative to address several
other key rights and protections.
Marriage
Equality: Presently, Indian law only recognizes marriage between a
man and a woman. This exclusion deprives LGBTQ+ individuals of legal
recognition for their relationships, the benefits that come with marriage, and
the security of family rights. The Supreme Court in Supriyo v. Union of India
[20], dealing with this complex issue and giving a setback for the Queer
community, refused to recognize the Right to Marriage as a Fundamental Right
and held that there is no unqualified right to marriage except that recognized
by statute. The Supreme Court, in this judgment, also held that transgender
persons in heterosexual relationships had the right to marry under existing
laws, including personal laws that regulate their marriage.
Adoption
Rights: Likewise, Indian adoption laws predominantly favor
heterosexual couples, presenting obstacles for LGBTQ+ individuals and couples
seeking to adopt children. The Supreme Court’s decision in Supriyo v. Union of
India further exacerbated the challenges faced by queer couples, as it denied
them the right to adopt, citing the absence of a legal framework as the reason
for this denial.
Protection
from Domestic Violence: Current domestic violence laws,
initially designed for heterosexual relationships, fail to provide LGBTQ+
individuals with sufficient legal protection, leaving them exposed to abuse
without a clear legal remedy. To effectively address this issue, it is crucial
to introduce inclusive language and guidelines into these laws. Regarding
domestic violence against transgender women, the Supreme Court is currently
examining an appeal against the Bombay High Court’s decision, which recognized
their protection under the law and their entitlement to maintenance [21].
Accommodation
Discrimination: Discrimination against LGBTQ+
individuals when seeking accommodation remains a pressing issue. Landlords and
property owners sometimes discriminate based on sexual orientation or gender
identity. Although the Indian Constitution and national laws do not explicitly
mention the right to adequate housing, the Supreme Court’s legal
interpretations emphasize the constitutional protection of the right to
shelter. This interpretation extends broadly, with the Supreme Court outlining
the responsibilities of national and state authorities in proactively
addressing homelessness, especially among disadvantaged communities. While the
courts haven’t explicitly addressed housing priorities for LGBTQ individuals,
the NALSA and Navtej rulings indicate that the Supreme Court recognizes LGBTQ
persons as a vulnerable and marginalized group deserving of appropriate
prioritization and protection [22].
Protection
from Sexual Harassment: Sexual offenses in India
predominantly revolve around women as victims, lacking gender-neutral
provisions. Despite the Justice Verma Committee recognizing the necessity for
such neutrality, its recommendations remained unenacted. Crucial sections like
375 IPC (rape) and 354-A (sexual harassment) continue to be gender-specific.
This means that if a male person identifying as female faces any form of sexual
harassment, they lack legal recourse under current laws. Similarly, significant
legislation like the Sexual Harassment of Women at Workplace (Prevention,
Prohibition, and Redressal) Act primarily addresses harassment against women,
leaving transgender individuals and those of other genders without appropriate
legal protections [23].
Reservation
for Transgender Persons: The absence of a specific
reservation quota for the transgender community in India, despite their
recognition as a socially and educationally backward class, presents a
significant barrier to their growth and inclusion. While the 2014 NALSA
judgment laid the foundation for acknowledging the historical discrimination
faced by transgender individuals, the current stance [24] of allowing them to
avail existing reservation benefits without a separate quota may not fully address
their unique challenges and vulnerabilities. To ensure genuine empowerment and
inclusion, it is imperative to allocate a distinct reservation quota for
transgender persons, thereby recognizing their distinct identities and
providing them with equitable access to education and employment opportunities
that have long been denied to them. This step would represent a crucial move
towards rectifying past injustices and promoting the socio-economic advancement
of the transgender community in India.
LGBTQI+
RIGHTS ACROSS THE WORLD:
Before
delving into LGBTQ+ rights across different countries, it’s essential to
underscore the significance of social acceptance alongside legal rights. Rights
only hold value when embraced and respected by society, allowing individuals to
enjoy their freedoms genuinely.
Social
Acceptance: In recent years, there has been a global shift in the way
LGBTQ+ individuals are perceived. Out of 175 nations, 56 have become more
accepting, 57 have seen acceptance decline, and 62 have stayed consistent.
Countries like Brazil, Canada, Great Britain, and the United States have
notably improved their acceptance of LGBTQ+ people. In 2020, Iceland, Norway,
the Netherlands, Sweden, and Canada stood out as the most LGBTQ+-friendly
nations. These positive changes were concentrated in regions such as Australia,
Oceania, North and South America, and Western Europe [25]. Another interesting
finding from a 2019 Pew Research Center survey [26] is that people in wealthier
and more developed economies tend to be more accepting of homosexuality than
those in less wealthy and developed ones. Additionally, younger generations
show higher acceptance of homosexuality across countries.
Marriage
Equality: Same-sex marriage has made substantial progress globally,
primarily in Europe and the Americas, since the Netherlands pioneered it in
2001. Notably, countries like Argentina, Australia, Canada, and the United
States have embraced marriage equality through referendums, court rulings, or
parliamentary decisions. Various European nations, including Belgium, Spain,
and the United Kingdom, have taken steps to legalize same-sex marriage. South
Africa is the sole African nation where it is legal, while the tide of
acceptance has touched Latin America, with Colombia and Uruguay following
Argentina. The Asia-Pacific region has seen Taiwan and New Zealand allow
same-sex marriages. Eastern Europe marked a milestone when Slovenia legalized
it. These developments reflect a global shift towards LGBTQ+ inclusivity, even
though disparities remain in legal recognition across different regions [27].
Adoption
Rights: In 2020, adoption rights for same-sex couples were legally
recognized in 28 countries and regions, with a greater prevalence in the
Americas and Europe than in Oceania, Asia, and Africa. South Africa was the
singular African nation allowing same-sex couples to adopt children, and Israel
was the exclusive Asian country permitting such adoptions [28]. Nevertheless,
Poland implemented a ban preventing LGBTQ+ individuals, including single
parents, from adopting [29]. Italy observed increased restrictions on same-sex
parenting [30], whereas Hungary passed a law in 2020 that forbade adoption by
same-sex couples [31]. Additionally, Russia way back in 2013 enforced a ban on
the adoption of children by gay couples [32].
Rights
against discrimination: Discrimination and violations are
not limited to India; they are global concerns. A significant event in this
context occurred in the United States in 2021 [33], when the bill to amend the
Civil Rights Act of 1964 was passed by the US House. This amendment included
protection for individuals based on their sexual orientation and gender
identity, akin to existing protections for race, religion, sex, and national
origin. Furthermore, President Biden’s executive order in June 2022 [34]
emphasized the commitment to upholding LGBTQI rights and ensuring equality.
According to a 2016 report from the global research group WORLD Policy Analysis
Center (WORLD) and the University of California, Los Angeles (UCLA), Britain,
Bolivia, Ecuador, Fiji, and Malta are the only countries where constitutional
rights are extended to individuals, regardless of their sexual orientation and
gender identity [35].
CONCLUSION:
The
journey of the LGBTQI+ community in India has seen progress in the face of
challenges. From battling the constraints of the Colonial Period to the momentous
decriminalization of homosexuality, significant strides have been taken. Yet,
the fight for LGBTQ+ rights encompasses more than legal acceptance; it’s about
securing fundamental rights like marriage, adoption, and protection from
discrimination. When the state’s stance clashes with constitutional morality,
it’s the judiciary’s duty to uphold the constitution’s true values and
safeguard marginalized communities. The Supreme Court of India has been pivotal
in this, decriminalizing homosexuality and expanding fundamental rights for
LGBTQI+ individuals, with the Navtej Singh Johar case setting a transformative
precedent. However, the recent Supriyo case decision has raised concerns.
Globally, countries like Canada, Sweden, the Netherlands, and Norway lead by
example, showing that embracing LGBTQI+ rights not only eliminates legal
barriers but fosters a culture of acceptance and equality. Their journeys
inspire the ongoing global effort for LGBTQI+ inclusion.
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