Empowering Sex Workers: A Gender Justice Perspective

Paper Details 

Paper Code: AIJACLAV5RP2024

Category: Research Paper

Date of Submission for First Review: May 16, 2024

Date of Publication: December 11, 2024

Citation: Debanjali Mukherjee, “Empowering Sex Workers: A Gender Justice Perspective", 4, AIJACLA, 50, 50-59 (2024), <https://www.aequivic.in/post/empowering-sex-workers-a-gender-justice-perspective>

Author Details: Debanjali Mukherjee, Student, Amity University, Kolkata

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Abstract

This paper uses a critical lens to examine the relationship between sex work empowerment and gender justice. Recognizing the variety of identities and experiences within this community, it explores the intricacies of sex work. It uses a gender justice framework to analyze systemic oppressions and structural inequalities that affect sex workers. It focuses on how gender-based discrimination increases vulnerabilities.

Utilizing a combination of multidisciplinary literature and empirical data, the study examines the significance of acknowledging sex work as lawful employment and promotes laws and initiatives that put sex workers' safety, rights, and general welfare first. The study also explores how stigma, criminalization, and social marginalization contribute to the continuation of gender-based violence and discrimination against sex workers, highlighting the necessity of intersectional methods to address these issues.

The paper finds effective strategies and paths for achieving gender justice in the discourse around sex work by analyzing current programs and advocacy efforts. In the debate around sex work, it highlights the significance of ongoing initiatives and advocacy campaigns, highlighting effective strategies and paths forward for the advancement of gender justice. The significance of giving sex workers' voices and agency a central place in community-based and policymaking processes is emphasized through confronting established conventions and removing structural obstacles. The study makes the case for a more inclusive and rights-based strategy for sex work that advances social justice and gender parity.

Keywords

Sex work, gender justice, empowerment, intersectionality, stigma discrimination, rights-based approach;

Introduction

The story of brothels has always been an intriguing matter of discussion among the people of the society. Facts which were completely unknown comes into the purview of common people through this paper. It majorly highlights the issues of an ongoing process of struggle of prostitutes till date from the date of emergence. We have been made aware of the hindrances of women to become an important part of the society. Now inspite of prostitution being made legal in India there are certain restrictions to them including child prostitution, kerb crawling, owning or managing a brothel, pimping, pandering etc.

In basic words, this profession has never been accepted or welcomed wholeheartedly by any such member of a society. Though the profession was meant to start with a noble intention which later turned out to be nasty and dreadful. Till today people hesitate to come across to such places where this profession is practiced and followed. Mothers of other children scare to allow their children to communicate with other children of the prostitutes because they think that their son’s or daughter’s childhood might become dreadful like theirs. They make sure that their wards never gets misled through any of their contact and association.

In addition to fighting for their rights and agency within the framework of sex work, a gender justice perspective on sex workers recognizes and addresses the intersecting kinds of gender-based injustice and discrimination they experience.

The term of “prostitution”1 an evil word for the society reminds of the hindrance towards a particular and neglected section of the society because of their profession.[1]

The Origin of Sex Workers: The Devdasi System

The term Dev describes God and the term Dasi describes servants which means the “the servants of god”. Now the question comes, who are these servants of god? And what does the phrase “the servants of god”2[2] mean? 

Numerous investigations have revealed a connection between our art and culture and "The Devdasi System," one of the most sinister ancient Indian systems. There are remnants of India's most well-known musical family at the Mangeshi temple in Goa. Master Dinanath, the late Lata Mangeshkar's father, fulfilled his inherited responsibility as a minister in this temple, being known as the nightingale of India. Yesubai Rane, Dinanath's mother, was a member of the temple's devdasi community. She used to perform a variety of artistic genres there. Her son Dinanath finally passed on her abilities to Lata Mangeshkar. Even though Yesubai was a devdasi, she was also Dinanath's father's mistress.

The devdasi temple system was the target of a nationwide protest because the protesters felt that it was causing prostitution to rise and negatively affecting society. Researchers claim that serving God was the original purpose of the Devdasi system. The devdasis used special methods to worship God through prayer. They used to worship god by engaging in a variety of artistic performances, such as singing and dancing. Based on the oldest records, the system dates back to the sixth century AD. It was decided by the queen of the Keshari dynasty that ladies possessing unique abilities and characteristics of classical performances could only serve God by marrying the divinity. At that time, women in the community were seen as honorable and deserving of respect if they worked in this field. In addition, they were eventually revered as nothing less than Laxmi's heavenly divinity.

It was also thought that these devdasis have unique abilities to master their five senses and innate human urges in order to surrender to god. Around the temples where they prayed was their general task. Few academics actually contend that the ancient dance style known as "Bharatnatyam" follows the devdasi method.

For financial backers, supporting these divine servers was an honor. A few years later, the devdasis were selected to participate in wedding ceremonies as well as private soirées including a variety of classical dance styles. Slowly the noble profession gave way to lust instead of honor. In this way, dancing and prostitution merged into one. The nation's temples were gradually destroyed by foreign invaders, depriving the devdasis of both their patrons and a safe place to reside.

Due to their financial stability, the devdasis, who were later referred to as prostitutes, were forced to perform in the aforementioned locations. With no one to support them after losing so much of their well-earned respect in society, the women's only choice was to become mistresses of priests, kings, and landowners.

Previously the high class women were mostly preferred for this profession who had unique traits and talents in classical background, whereas later when their journey brought them from temple to brothels, they eventually lost standards and now only women from lower castes were chosen and rather compelled to be a part of this profession.

According to another research, Goa, a Portuguese colony founded in early 16th-century Portuguese India, was home to groups of Portuguese slaves. Due to the Portuguese trade in Japanese slaves, in the late 16th and early 17th centuries, Goa was the destination of Japanese captives transported by Portuguese traders from the Portuguese Empire, as well as members of their prisoner lascar crew from South Asia.3[3]

These were mostly young Japanese women and girls who had either been abducted or sent to Japan as sexual slaves. Tawaifs were courtesans who worked for the lords of India, particularly during the Mughal era. The Urdu literary legacy, poetry, theater, music, dance (mujra), and manners were all considered strong suits for the tawaifs. Originally from North India, tawaifs have been an essential component of Mughal court culture since the 16th century. Wawifs rose to even greater prominence as Mughal control started to decline in the middle of the eighteenth century.

Up until the federal Mann Act was passed in 1910, prostitution in the US was only seldom regulated. This law forbade the interstate movement of women for "immoral purposes." Almost all states had legislation prohibiting brothels or controlling prostitution revenues by 1915. Additionally, prostitution was a significant source of income for the ancient Greek and Roman administrations.

Few types of prostitution are:-

1. Street: Clients are solicited on the street, park, or other public places.

2. Brothel: Premises explicitly dedicated to providing sex.

3. Escort: Client contacts sex worker by phone or via hotel staff.

4. Private: Client contacts sex worker by phone

As the idiom itself states that ‘All that glitters is not gold’, just like having a luxurious and honourable life, it even had limitations of not able to live a normal life like other women and get married to a normal man of their own choice. A prostitute had to go through all the struggle after living a so called luxurious life post getting married to the deity.

Few researchers asserted in the 19th century that devdasis were special and distinct from others since they belonged to a higher social and economic level than married women. Devdasis did engage in romantic relationships, but these were with men from higher castes and males they themselves selected.4[4] Oddly enough, though, this procedure was never used to disparage them; rather, it was believed to be advantageous to them because it served as a means of achieving a greater level of spirituality. This was a result of the unique women's close relationship to God. 

Current Scenario

Recent studies and examples takes us forward to varietal changes that has occurred or come into appearance of common people. It is quite evident from the study that day by day, the system of prostitution is deteriorating. Insignificance has gotten with the name of prostitution.

Times travelled from temples to brothels and from honour to dishonour & lust.

The legal frameworks, social views, and geographic location all had a significant impact on the circumstances faced by prostitutes. Numerous issues experienced by sex workers included violence, discrimination, stigma, lack of access to healthcare, and legal protections. Ongoing initiatives to support the safety and rights of sex workers have been made by activists, organizations, and legislators; in certain areas, sex work has even been decriminalized or made lawful. I suggest reviewing recent papers or studies from reliable sources or groups that support the rights and advocacy of sex workers for the most accurate and current information on the current state of the sex worker situation.

Human Rights Watch estimates that over 20 million prostitutes work in India, with 35 percent beginning their professions at the age of 18. Human trafficking is partly to blame for the prostitution industry's rise. UNAIDS(Joint United Nations Programme on HIV/AIDS) reported in 2022 that there are 6.5 lakh prostitutes in India; however, the National AIDS Control Organization believes that the country is home to around 800,000 sex workers.

Prostitution and its identification

The act of participating in sexual behaviour for payment is known as prostitution. This can involve oral, manual, non-penetrative, or sexual contact. A common definition of prostitution is having comparatively indiscriminate sex with someone who isn't your spouse or friend in exchange for quick cash or other assets.5[5]

For millions of people around the world, prostitution is an unpleasant reality. Because there are limited economic alternatives for them, many women, particularly in impoverished areas, turn to prostitution. Sex labor gives an illiterate woman, who might be under pressure to support her family, an easy way to generate quick money. Prostitution soon appears like a viable alternative, possibly the only one, if she lives in a nation that permits the sex industry.

Various surveys state that devdasis used to wear a unique necklace which they were supposed to handover during their lifetime. This is the reason why devdasis searched for those families who were in need of money or so as to reduce their burden, those families would sell off their daughters to them. The necklaces played a vital role in their identification process which helped the societies to recognise them as devdasis or later termed as prostitutes. They even had a deep rooted belief that they could not attain salvation until and unless they transfers their necklace to any other devdasi.6

Individual Choices as a priority for prostitution

Prostitution can never be a personal choice for a girl to live for, its always a compulsion for them or their family to hold onto a disrespectful and dreadful profession. From time immemorial, the women of the society believed and had complete faith as well as pride in the serving of god. They were unaware that such pride could breed hatred and embarrassment to the community. Due to a particular problem that the families were going through, several families sold their girls and sent them to the temple of Yellema Mata in southern India. They fervently thought that the only way to rescue their family from the predicament was to sacrifice their ladies in the temple in order to worship and serve the god.

Regardless of whether a woman is involved in prostitution, domestic work, or both, society continues to hold us accountable for every misstep and diminish our worth if we begin to demonstrate our abilities. Our vocations are merely a conduit for how society and other men perceive us as interchangeable objects.[6]

The journey from temples to brothels contribute various factors starting from religious beliefs to economic needs. Speaking about the individual choices of prostitutes, they nearly failed to have one. For an instance, the administrative authorities and other police officer while raiding famous red-light areas that of Kamathipura and different brothels found that nowadays the prostitutes vary mostly from extreme lower section of the society.  A social activist speculated that in India, there might be an estimated 100,000 lower-caste women and girls work in prostitution.

In the state of Rajasthan, the Khakranagla village, inhabited by a number of families of the Bedia caste have been identified with prostitution. Traditionally Bedias and Nats were dancers in Rajasthan and MP. Being entertainers it was customary for women and girls to perform for feudal lords. When the zamindari system was abolished, they lost their patrons. Overtime a number of Bedia women were compelled to take up prostitution for economic reasons and the men lived off their earning. Multiple such cases are found all over the world stating inevitable factors of choosing prostitution as a profession.

In the year 2015, an NGO named Sampark Organisation7 showed data from surveys of three districts that 57% of girls were forced into devdasi system so that they can earn money for their family, 42% girls were forced because of their illness and weak immune system and rest 1% devdasis were themselves interested in practicing this system because they denied to discontinue this practice.

Intersectionality

The notion of intersectionality posits that oppression takes place through an interconnected system of oppression rather than along a single axis. According to Crenshaw, there are three forms of intersectionality: structural, political, and representational intersectionality.[7]

1. Structural - The term "structural intersectionality" refers to the way that various systems interact to highlight the disparities in the experiences that women of color have with rape and domestic abuse. The concept of structural intersectionality describes how racism, sexism, and classism interact to oppress women of color and shape their experiences in many contexts.[8]

2. Political - Political intersectionality draws attention to two opposing political systems that divide women and women of color into two marginalized categories. Because race and gender frequently interact, the experiences of women of color are different from those of White women and men of color.

3. Representational - Supportive imagery for women of color is encouraged by representational intersectionality. The marginalization of women of color in representation is condemned by representational intersectionality as sexist and racist.

Stigma and Discrimination

Globally, sex workers and people living with HIV(Human Immunodeficiency Virus) experience severe stigma and discrimination, such as violations of their human rights, repressive laws and policies, lack of access to protection and justice,  violence, lack of access to appropriate health and social care,  social marginalisation, housing and economic discrimination, migration issues etc.

HIV-positive individuals and sex workers experience comparable forms of stigma, such as being viewed as "unclean" and a "risk to public health, unable of caring for themselves or making wise choices. The stigma associated with HIV is exacerbated for sex workers.

Living with HIV, sex workers might not feel comfortable telling friends or coworkers about their status, and they could be reluctant to use programs and community assistance out of fear of prejudice. Communities of sex workers may keep their distance from HIV-positive sex workers in order to resist the myth that those who work in the sex industry are "vectors of disease" or sexually harmful. Communities of HIV-positive individuals may choose to keep their distance from sex workers in order to combat the myth that engaging in sexual activity leads to HIV infection.

Migration may be unattainable for HIV-positive sex workers. Limitations on admission, stay, and residence exist in 79 nations regarding HIV-positive individuals. It is also common for countries to restrict or deport sex workers.

Human trafficking for sexual exploitation

The crime of forcing or coercing someone to perform commercial sex acts or to provide labor or services is known as human trafficking, sometimes known as trafficking in humans. Coercion can be psychological or physical, covert or overt. Laws to stop human trafficking and forced prostitution. Other offenses linked to human trafficking are also punished, including Section 366B's importation of a foreign girl for sex, Section 370A's exploitation of a trafficked person, and Section 366A's procurement of a juvenile girl.9[9]

Elements of human trafficking are-

1. Area Of Human Trafficking Act: Persons recruited, moved, transferred, harbored, or received.

2. Methods: Using or threatening to use force, coercion, kidnapping, fraud, deceit, abusing one's position of authority or weakness, or providing rewards or payments to someone who has force over the victim and thereon gets followed in that manner.

3. Goals: Forced labor or services, sexual exploitation, prostitution of others, and slavery.

Elements of prostitution are-

1. Act: Engaging in sexual activity or communication with another individual in exchange for money or other valuables.

2. Methods: To ask, seduce, make an offer, convince, or consent to be a prostitute

Families unintentionally or intentionally send their girls into the hands of peddlers who promise to save them by entangling them in the devdasi system, all in the name of God. Generally, a girl is forced to enter this hazardous job through kidnapping, trafficking, or false hope. These and numerous other circumstances, such as the economic downturn, religious convictions, and the desire for a better life, push these girls into prostitution.

Necessity of health and safety

Accessing services can be stigmatizing and discriminatory for sex workers and HIV-positive individuals health services. Sex workers with HIV risk having their status attributed to their work while seeking medical attention. In addition to experiencing: 10[10]

1. Denial or delay of health care, some healthcare professionals may treat sex workers living with HIV as less worthy of appropriate and respectful care.

2. Secrets being broken

3. Discreet, critical, and stigmatizing health care providers.

4. Testing and treatment that are forced or required.

5. Steroid or abortion that is forced upon oneself. Failure to stop the transmission of diseases from mother to kid

Preventive health measures which should be made available to sex workers-

1. Vaccination- Sexual workers should be up to date on their measles, mumps, rubella (MMR), meningococcal, and diphtheria-tetanus (DT) vaccinations due to close interaction with clients whose immunization status is uncertain. Hepatitis A, B, and influenza vaccinations etc.

2. Regular screening for sexually transmitted infections, cancer, and tuberculosis-Asymptomatic sexually transmitted diseases are common, and ectopic pregnancy and pelvic inflammatory illness can result from postponed therapy. Regular screening for sexual workers lowers the risk of HIV transmission and other STDs, promotes condom usage, and guards against STD complications, according to randomized controlled trials.

3. HIV post-exposure prophylaxis- For occupational HIV exposure, a Cochrane review recommends post-exposure prophylaxis, and recommendations for 28 days of two or three antiretroviral medications starting within 72 hours are out there.

4. Pregnancy prevention- Dual methods of contraception, such as long-acting injectable progesterone or oestrogen implants, oral contraceptives, intrauterine devices, or diaphragms, should be made available to sex workers.11[11]

Rape in prostitution

When someone in the prostitute industry is forced to endure sexual assault or violence against their will, it is referred to as "rape in prostitution." It's a significant problem that draws attention to the vulnerability and exploitation that those who engage in the sex trade frequently experience. The sub-topic itself being controversial derives different manings of rape in prostitution. A basic concept in rape states that whenever an opposite sex is compelling or forcing the other person to have intimate relation or intercourse with that very person, only a negative word ‘NO’ becomes a whole sentence. This particular words gets applied to any situation may it be a girl, a woman , a wife or even a sex worker.

Instead of calling rape "sex without consent," lets argue that it should be called "gender-based violence." By reclassifying rape as an injustice and removing it from the exclusive domain of interpersonal relationships, this situates it within the frameworks of criminal justice and civil rights.

As per the update of 2018,

The Bench stated that the trial court had correctly concluded that "even if the accused persons' allegations that the woman is of immoral character are taken to be true, that does not give them any right to rape her against her consent." The Supreme Court has determined that even sex workers have the right to deny their services and seek justice when they are coerced. This decision overturns a 2009 Delhi High Court ruling and reinstates the 10-year sentence that four individuals were previously given by a lower court.12

In a 1997 gang rape case in the nation's capital, the supreme court ruled on Tuesday, ordering the guilty parties to turn themselves in within four weeks in order to fulfill the balance of their sentences.[12]

Labor Rights and Legal Reforms

In 2014, 42 countries had laws which specifically criminalised HIV non-disclosure, exposure and transmission. Additional countries have prosecuted people living with HIV under other laws, such as public health laws or laws against sexual assault.

To address HIV and AIDs effectively, India had the highest number of persons living with HIV and AIDS worldwide in 2006, according to the Joint United Nations Programme on HIV/AIDS (UNAIDS), with 5.7 million people (UNAIDS 2006).

KSWU(Karnataka Sex Workers Union), 2006 campaigns to decriminalize sex work, demands labor rights, and works to have sex work recognized as respectable labor rights that any other worker is entitled to. KSWU fights against government agencies, goons, the police, and other groups that use violence, oppression, and exploitation against sex workers. KSWU is an advocate for social entitlements and fair working conditions. KSWU is an independent organization run democratically by its members, comprising sex workers.

According to the Immoral Trafficking Prevention Act of 1986, if sex work is done independently and in private, it cannot be considered an unlawful conduct in and of itself.

Only when a sex worker's client has procured her for someone else is a 370-A IPC offense made out: Orissa HC. "The offence under Section 370-A (2) of the IPC cannot be attracted against the customer in the absence of material that women are trafficked for the purpose of engaging in sexual exploitation."13[13]

Notions favouring the legalisation of prostitution in India-

1. Legalisation will secure their children

2. Spread of STDs can be controlled

3. Sexual assault  and others related activities will decline

4. Forced prostitution may end

5. Rights of sex workers will be safeguarded

Involvement of society and community empowerment

People involved in prostitution and sex work have been served by Veshya Anyay Mukti Parishad (VAMP) and Sampada Gramin Mahila Sanstha (SANGRAM), its sister organization People in prostitution and sex work (PPS) in the 19th century.

With HIV prevalence among the highest in the nation, the work intends to successfully address HIV and AIDS in rural Maharashtra and northern Karnataka, especially along the Mumbai-Karnataka corridor. The philosophy of VAMP and SANGRAM is based on two key ideas. First, PPS may be agents of social change, transforming their own communities; second, in order to affect change among marginalized populations, it is necessary to foster a sense of community by developing a consciousness of common identity and, from there, building collective solidarity.

In India, there are effective strategies that support PPS's rights and empowerment, mostly in metropolitan regions. These include well-known initiatives like Kolkata's Sonagachi project and the Durbar Mahila Samanwaya Committee (DMSC). In 1992, SANGRAM started working with 16 women who were engaged in prostitution and sex work on a small budget.14[14]

There can be multiple reasons why these non- profit organizations were built up in order to provide support to the sex workers and prostitutes-

1. Creating a sense of identity and collective solidarity- Women created a shared identity by sharing their life stories, and this eventually fostered a sense of unity.PPS involved in SANGRAM and VAMP's work started to develop a feeling of identity and social solidarity when they realized how similar their experiences were as a marginalized group.

2. Recognizing sex workers as change agents for the community- The way that sex workers are viewed in the communities where VAMP works has drastically changed. “I used to conceal my face with my pallu (the end of a sari) and call the cops sahib [sir] when they called me randi. They now acknowledge me as a valued member of SANGRAM and VAMP. I'm greeted as "madam" and asked to seat down and asked if I wanted to have tea”

Earning the respect which these prostitutes had lost long ago was an absolute difficult for them. These initiatives had profitable outcomes as well which are-

1. More sustainable HIV and AIDS programme-  The organizations have a history of successfully offering advice, information, and assistance. The fundamental values upon which the partnership is based give the women of VAMP the authority to carry out outreach to the larger community, going beyond PPS with HIV and AIDS programming. Currently, each month, roughly 120 VAMP peer educators give 350,000 condoms to 5,000 women. Condoms are not sold; they are given away for free. Areas requesting 6,000 condoms now request 8,000 condoms. PPS have witnessed the advantages of using condoms, as STIs, or sexually transmitted infections, have declined.

2. Recognition of people in prostitution and sex work as persons with human rights- PPS in Sangli, as well in other places, are aware from personal experience that they are not always protected by the legal and law enforcement systems. Members of VAMP have successfully used collective action to pursue their legal rights to protection. The Delhi meeting attendees drafted and filed a policy regarding HIV and sex work from a rights-based standpoint, in accordance with Greater Involvement of People Living

   
   

   the with AIDS (GIPA) and Universal Access principles (The Global Working Group on Sex Work and HIV 2007.

Conclusion

In conclusion, understanding and resolving the overlapping forms of discrimination and inequality that sex workers experience on the basis of their gender identity, sexual orientation, race, and other intersecting characteristics requires adopting a gender justice approach. This viewpoint highlights how crucial it is to support the rights of sex workers as employees, uphold their agency and autonomy, advance their health and safety, and combat stigma and prejudice. It also entails backing legislative changes that put sex workers' rights and welfare first and address the systemic injustices and societal imbalances that make them vulnerable. In the end, achieving gender justice for sex workers necessitates a complex strategy based on respect for their human rights, empowerment, and community.

In the case of Budhadev Karmaskar v. State of West Bengal (2011),

The court recognized sex work as a profession, and directed the police not to interfere with or take criminal action against consenting sex workers. Since prostitutes are also human beings and their issues must be taken care of, the Supreme Court of India ruled in Budhadev Karmaskar v. State of West Bengal that they have a right to live in dignity under Article 21 of the Indian Constitution.15

Better surveys needs to done to stop the continuation of devdasi system which are still continuing in various places of the nation, risking and destroying the lives of young girls.15[15]

Despite all the precautions implemented, these women continue to demonstrate their unique contribution to the population management of society. Even yet, "Ganga Mati" is still taken from the brothels to create the Maa Durga statue before puja. If God can continue to exist in these brothels, then why can't society accept them fully to participate in this puja? These ladies simply want the right to exist in society without feeling guilty or ashamed, with pride.[16]

Concluding with the assertion that being a woman requires a great deal of fortitude and pride and is in no way an easy job. Regardless of their occupation, society consistently judges them and uses derogatory language and other forms of humiliation to denigrate them. Gender justice is not just a phrase; it is a force that may benefit society by educating people before they speak.

[1]‘Prostitution’ (Wikipedia, 13 March 2024) <https://en.wikipedia.org/wiki/Prostitution> accessed 14 March 2024

[2] ‘Servant of God’ (Wikipedia, 13 February 2024) <https://en.wikipedia.org/wiki/Servant_of_God> accessed 14 March 2024

[3] ‘History of Prostitution’ (Wikipedia, 23 February 2024) <https://en.wikipedia.org/wiki/History_of_prostitution#:~:text=Sumerian%20records%20dating%20back%20to,to%20three%20classes%20of%20women.> accessed 14 March 2024

[4] ‘——’ (Encyclopædia Britannica) <https://www.britannica.com/topic/prostitution> accessed 14 March 2024

[5] ‘Sampada Grameen Mahila Sanstha’ (Sangram) <https://www.sangram.org/> accessed 14 March 2024

[6] ‘History of Prostitution’ (Wikipedia, 23 February 2024) <https://en.wikipedia.org/wiki/History_of_prostitution#:~:text=Sumerian%20records%20dating%20back%20to,to%20three%20classes%20of%20women.> accessed 14 March 2024

[7] Modinatheme, ‘The Unsolved Problem’ (Sampark Foundation) <https://www.samparkfoundation.org/> accessed 14 March 2024

[8] (Stigma and discrimination experienced by sex workers ...) <https://d8dev.nswp.org/sites/default/files/Stigma and Discrimination Experienced by Sex Workers Living with HIV Community Guide, NSWP - December 2015.pdf> accessed 14 March 2024

[9] Goff P, ‘Prostitution and Human Trafficking: Know the Difference’ (The Exodus Road, 16 November 2022) <https://theexodusroad.com/prostitution-and-human-trafficking-know-the-difference/> accessed 14 March 2024

[10] ‘Research Guides: Persistent Links for Library Resources: JSTOR’ (JSTOR - Persistent Links for Library Resources - Research Guides at University of Oregon Libraries) <https://researchguides.uoregon.edu/persistentlinks/jstor> accessed 14 March 2024

[11] (Briefly reviewed - jstorhttps://www.jstor.org/stable/10.2307/20473) <https://www.jstor.org/stable/10.2307/20473> accessed 14 March 2024

[12] ‘Even Sex-Workers Have Right to Refuse: Supreme Court’ (Hindustan Times, 2 November 2018) <https://www.hindustantimes.com/india-news/even-sex-workers-have-right-to-refuse-sc/story-6P5445E9uS5BhNXoava1WI.html> accessed 14 March 2024

[13] (Briefly reviewed - jstorhttps://www.jstor.org/stable/10.2307/20473) <https://www.jstor.org/stable/10.2307/20473> accessed 14 March 2024

[14] ‘Sampada Grameen Mahila Sanstha’ (Sangram) <https://www.sangram.org/> accessed 14 March 2024

[15] ‘Upholding Women’s Rights: When the Supreme Court Got It Right’ (Hindustan Times, 19 August 2021) <https://www.hindustantimes.com/india-news/upholding-women-s-rights-when-the-supreme-court-got-it-right-101629354643975.html> accessed 15 March 2024

[16] Garg R, ‘Sex Workers Rights in India’ (iPleaders, 6 December 2022) <https://blog.ipleaders.in/sex-workers-rights-in-india/#:~:text=It%20prohibits%20trafficking%2C%20begar%20and,(Prevention)%20Act%2C%201956.> accessed 15 March 2024