Unfriendly Bodies, Hostile Cities - Economic and Political Weekly

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Unfriendly Bodies, Hostile Cities
Reflections on Loitering and Gendered Public Space
Shilpa Phadke
Following sexual assaults on women in public spaces in
cities, discussions tend to frame the issue in terms of
women’s safety in the streets rather than their right to
access public space. The overarching narrative appears
to be that cities are violent spaces that women are better
off not accessing at all. This paper attempts to make a
case for women and others accessing a city which is
perceived as hostile, and to do so without being
censured. It argues that loitering offers the possibility of
rewriting the city as a more inclusive, diverse and
pleasurable one.
Versions of this paper were presented at the L B Kenny Endowment
Lecture at the Asiatic Society, Mumbai, March 2012; Subaltern
Urbanism, Columbia University, Mumbai, January 2013; “Inequality,
Mobility and Sociality in Contemporary India”, Yale University, the
US, April 2013; Wellesley College, the US, April 2013; and Brandeis
University, the US, May 2013. The author would like to thank the
participants at all of these for their engaged and thoughtful comments.
Thanks especially to Abhay Sardesai, Amit S Rai, Sameera Khan and
Shilpa Ranade who commented on this paper at various stages.
Shilpa Phadke (shilpa@tiss.edu) teaches at the School of Media and
Cultural Studies, Tata Institute of Social Sciences, Mumbai.
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On 22 August 2013 five men gang-raped a young photojournalist
in the dilapidated Shakti Mills premises in
Mumbai. It immediately set off discussions in news
features, blogs and broadcast news about how dangerous the
city had become and how women’s mobility was going to be
further restricted. The question of unfriendly space assumed
centre stage when in New Delhi five men brutally raped and
assaulted a young physiotherapy student in a bus and beat up
her male friend before throwing them off the vehicle on
16 December last year. Thousands protested against the incident
on the streets of Delhi and other cities. These protesters
demanded better infrastructure, more efficient policing, and
more stringent punishment for the rapists. It is the question of
women’s safety on the streets that frames this discussion rather
than any concern with women’s right to access public space.
The question of making streets safer for women is not an
easy one, because the discourse of safety is not an inclusive
one and tends to divide people into “us” and “them” tacitly
sanctioning violence against “them” in order to protect “us”
(Phadke et al 2009). This is endorsed by the wide reportage of
any sexual assault that involves lower class men attacking
middle class women. 1 In comparison, upper and middle class
perpetrators of sexual violence get off easily. 2 So also when
lower class, dalit or tribal women are sexually assaulted the
media barely covers these attacks and there is little or no
public outrage.
The overarching narrative appears to be that cities are
violent spaces that women are better off not accessing at all.
An examination of responses by the state and its functionaries
to the attacks on women is telling. Following the Mumbai
attack, Maharashtra’s Home Minister R R Patil offered police
protection to women journalists on assignments. In response
to the sexual assault of a young woman who worked in a Gurgaon
mall on 12 March 2012, the Gurgaon police and administration
passed an order that malls and other similar establishments
in the city should not permit women to work after 8 pm,
without permission from the labour commissioner. In response
to the Park Street rape in Kolkata on the night of 5 February
2012, West Bengal Chief Minister Mamata Banerjee suggested
that the rape victim was part of a conspiracy to defame her
government. The West Bengal government suggested that
pubs should not stay open after 11 pm. In reaction to the murder
of journalist Sowmya Vishwanathan in 2008, Delhi chief
minister, Sheila Dikshit suggested that “one should not be so
adventurous”. 3 Even after the December 2012 attack, her first
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esponse was to evade responsibility by claiming that the bus
service was a private one.
These responses suggest that large cities and particularly
public spaces are unfriendly, even hostile spaces for women.
The state and its functionaries appear to believe that given this
hostility, women might be better off avoiding these spaces
altogether. Thus, not only do the former not just abdicate their
responsibilities to facilitate access and provide justice, if not
safety, but they also assume that nobody would want to access
unfriendly spaces. 4
If the discourse on safety is inadequate to further women’s
claims to public space, how might we strategise to push for
women’s rights to public space? It is imperative to engage with
the question of women’s rights to public space as citizens, posing
a counter voice to not just the voices of moral policing but also
to challenge the centrality of the discourse of safety even among
those protesting government inaction. I have argued earlier that
what women need in order to access public space is not
conditional safety but the right to take risks (Phadke 2005).
While I was researching women’s access to public space in
the early 2000s, two aspects became quickly apparent. One,
that most respondents agreed that women must be safe in public
space, and two, that the women they were referring to were
inevitably middle class, usually Hindu upper caste, mostly
heterosexual and always respectable women. Written not too
subtly in the subtext was the assumption that women were
unsafe due to the presence of two categories of people: first,
that of a certain kind of man usually lower class, mostly
migrant, often unemployed and sometimes uncomfortably
Muslim; second, that of the un-respectable woman: the street
walker, the bar dancer. The first group was perceived to be a
threat to women’s physical safety, the second and by no means
less important group was perceived to produce a threat to the
reputation of even respectable women.
In this paper, I focus on the lower-class male, asking questions
around the access of different groups of people who
might not be friendly to each other. Phadke et al (2011) suggested
that the celebration of loitering was an important way
of claiming city public spaces in defiance of laws against loitering
after sunset and before sunrise. We argued that the only
way in which women might find unconditional access to public
space was if everyone, including those who were not necessarily
friendly to women also had unconditional access (Phadke
et al 2011). Subsequently in conversations with feminist activists,
particularly those who work with young women, we have
been challenged several times on the grounds that everyone
loitering includes even those “others” (often young men) who
intimidate young women and inhibit their access, thus in fact
restricting their mobility.
In this paper I attempt to think through questions of justice
in access to public space. It is unnecessary to point out that
men have more access than women, the rich have more access
than the poor or indeed that the very aspiration of becoming a
“global” city is based on the exclusion of those who do not fit
in. I will attempt both to respond to the very real questions
raised by feminist activists in relation to loitering as well as
SPECIAL ARTICLE
locate them in a context where public spaces are shrinking
for everyone.
The first section traces competing claims to public space in
cities. The second section focuses on the idea of the unfriendly
body asking why some bodies are considered more unfriendly
than others. The third section asks the question: what makes
for friendly/unfriendly cities? Using the illustrative cases of
Singapore and Mumbai it reflects on the trade-off between
safety and loitering. The fourth section engages the desire to
access the city despite its hostility.
This paper engages multiple questions: What does it mean
to stake an equal claim for all to loiter in public space? How
does one engage with the threat posed by one group of such
loiterers to another potential group of loiterers? How does one
understand claim staking in a context where city public spaces
are surveillanced and policed? What are the claims of different
kinds of bodies and how can we arrive at an idea of justice
that at least attempts to address the claims of as many different
groups as possible? In thinking through the notion of
unfriendliness of bodies, spaces and cities, I attempt to make
a case for women and others to make choices to access a city
which is perceived as hostile without being censured for it
and to continue an argument on why loitering offers the
possibility of rewriting the city as a more inclusive, diverse
and pleasurable city.
1 Competing Claims to Public Space
The post-16 December Delhi protests focused on young men
and one saw a number of posters which exhorted us to teach
men not to rape. The fact that the perpetrators of the brutal
sexual assault leading to the death of the victim were a bus
driver, two cleaners, a fruit vendor and an assistant gym
instructor drew attention to lower class men in cities marking
them for surveillance. The unemployed status of the perpetrators
of the Mumbai attack will only endorse the need for
such surveillance.
Even as the protests raged, prime minister, Manmohan
Singh urged the police to increase surveillance of “footloose”
migrants. 5 In Mumbai, migrants have long been seen as perpetrators
of violence. 6 Parochial politicians have already raised
the “outsiders” bogey in response to the 22 August attack. This
kind of prejudiced representation is not new and is not restricted
to media reports. For instance, there is a particular
way in which lower class women and men are cast in particularly
development discourse since the 1970s – the former as
potentially ideal subjects of development aid and the latter as
almost “lost causes”, men who are often violent, unemployed
and dominate women, reflective of everything that is wrong
with “developing” countries. In these narratives of development,
almost unvaryingly men are cast as the problem and
women as the victims. These are also seen in the context of
narratives around microfinance where women are seen as
good borrowers – that is a good risk as opposed to men. This is
true not only in India but across the world. 7
This vision of the lower-class man as an obstacle to
progress is one that is reflected in the media as well.
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SPECIAL ARTICLE
Uma Chakravarti (2000) analyses a television serial titled
“Naya Zamana” (New World):
…we have the full assemblage of stereotypes: the central character
naturally is a ‘bai’ who is upright and tries to live honestly. Her husband
is a brutal male – we have seen no poor upright men in a long time
– who whiles away his time in a drunken stupor when he is not engaged
in beating his wife, or harassing his stepdaughter. ...Such images then
feed into middle class perspectives on poverty and morality which are
distributed in inverse proportion among the different classes; if the
poor are poor it is because the lower class male is so irresponsible
(p WS15).
As I have argued elsewhere, the exclusion of women from
public space cannot be seen in isolation but is linked critically
to the exclusion of other marginal citizens. The person(s) who
are seen to pose the risk are men – of a certain class and occupation
(or lack thereof). Safety for women then has become
increasingly about emptying the streets of other marginal citizens
deemed to be a “threat” to women. At the top of this list is
the lower-class male (also often unemployed, often lower caste
or Muslim), but sex workers, bar dancers and others seen to be
in need of surveillance also qualify. In this politics, both those
seen as the threat and those perceived to be in danger are rendered
illegitimate users of public space. I have argued that
their claims to public space are not competing but rather need
to be coterminous if they are to be successful (Phadke 2007).
This is not to suggest however, that we need a collective multimovement
for access to public space but that each act of claiming
of public space must acknowledge the rights of others to
that space public space.
When we engage with violence in relation to claims on the
city, it is important to see violence against women in public as
being located alongside violence against the poor, Muslims,
dalits, hawkers, sex workers and bar dancers. Addressing the
question of women’s access to public space then means engaging
with realities of layered exclusion and multiple marginalisations:
the exclusion of the poor, dalits, Muslims, or
indeed hawkers and sex workers are not acts of benevolence
towards women but part of larger more complex processes
where one group of the marginalised is set against another
(Phadke et al 2011).
How does one understand the complex politics of gender in
these situations when it intersects with the reality that today,
the middle classes are even more privileged in access to public
space and other resources than ever before, and this includes
middle-class women, however limited their access might be.
Feminist and other gender-based responses to women’s restricted
access to public space have also often identified men as
the source of threat in the public. The presence of middle-class
women as vocal advocates of women’s right to public space,
has acquired some visibility in the last two years buttressed by
the processes of globalisation where women especially as consumers
and professionals are an extremely desirable part of
the cityscape.
In the Indian context, initiatives like the Blank Noise project,
the “Pink Chaddi” campaign, Hollaback Mumbai, Hollaback
Chennai and the Slutwalks in some cities have raised important
questions from the perspective of competing access to
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public space. The Blank Noise project initiated first as a student
project which grew into a much larger artist-activist
endeavour encouraging women to talk back by claiming “I
never ask for it”, or to participate in street performances has
been critiqued by some as being located in a gaze where
middle-class women accuse lower-class men of sexual harassment.
Similarly, the Pink Chaddi campaign and the Slutwalk
have been accused of being elitist and relevant only to a small
minority of urban women.
I would argue that feminism has space for all kinds of protests
and claim staking and the question of relevance itself is
an irrelevant one. One does not have to point out that women
across classes have very different access to space and spatial
resources. The question is, how do these initiatives resonate
with women from different classes who may have very different
senses of entitlement. Who can talk back to whom and
when? Who can take photographs of whom? What are the
politics of legitimacy and “rightful” citizenship that operate in
this claim staking?
2 Unfriendly Bodies and Hostile Cities
It is villages and the countryside which are invoked in images
of tranquillity. Cities are often seen as spaces of noise, dust,
speed and worse, as locations of vice and violence. The city
then is the space of excitement rather than calmness, of risk
rather than safety.
In recent years cities across the world have developed policies
and committees in an attempt to protect themselves from
natural disasters and acts of human violence. In acknowledgement
of an ever present terror threat, in some cities there is a
constant assessment of risk and danger levels, especially at
airports and other such sites. 8 This apparent danger, often
perceived as a danger to life, does not prevent people from
venturing out into public space in cities. In Mumbai, the relatively
high attendance at workplaces following terror attacks
or natural disasters has often been lauded and seen as a measure
of its resilience. So why is it that any perception of threat, even
unfriendliness, produces a range of effects that suggest women
should stay away from public space? 9,10
Given that public space is classed, communalised and
caste(d) along with being gendered, how can we understand
the different modes of speech and the possibility of this being
seen (whether intended or unintended) as “unfriendly
speech”? At the same time, it is also worth reflecting on young
men who are often seen in the discourse on safety as merely
undesirable bodies. What is it about “unfriendly bodies” that
makes it impossible for women to co-inhabit space with them?
Do women then never access spaces where there are “unfriendly
bodies” present?
What does it mean to be loitering or to even desire to loiter
in hostile cities with unfriendly speech/bodies present? What
are the consequences of suggesting those unfriendly bodies
should not be there? In this section I use the prism of the notion
of “unfriendly bodies” as a way of looking at questions of
hostility in public space. How does one understand the notion
of the “unfriendly body”? What are unfriendly bodies and to
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whom are they unfriendly? What are the risks posed by a variety
of “unfriendly bodies” to each other and to the body of the
city itself? Who are the bodies who are a threat to the citybody?
And most relevantly in this case, does public space hold
the possibility for unfriendly bodies to coexist?
Multiple Bodies in Public Space
I would like to mention here the idea that part of the problem
of multiple bodies in public space is about the possibilities it
creates for the mixing of ought-to-be-unmixable bodies –
across caste, class or religion; the anxiety of bodies that ought
to be unfriendly, becoming friendly or worse, intimate. 11
If we were to locate this understanding within the context of
risk, one might say that many women are horribly unsafe at
home, a space often of unfriendly bodies and speech and yet we
do not stop women from being there. In fact we urge them to be
in that very space. What if we were to cast the presence of unfriendly
bodies in this same light? Is it possible for us to think of
unfriendly bodies as being a hazard of public space rather than
a deterrent? It is also important to notice that cities are not relentlessly
unfriendly but rather move from being friendly to unfriendly
depending on various contextual and situational
factors, including among other things, temporality, crowds,
lighting, and availability of infrastructure and amenities such
as transport and toilets. Is it possible to conceive of the city as
an intermittently unfriendly space to be negotiated? What if
antagonism in public space were naturalised? What if women
were to desire to access city public spaces, despite their hostility?
For women, particularly young women, sexual harassment
is a form of unfriendliness different from other kinds of hostility,
and has the power to generate extreme anxiety. It is important,
however, to note that there is also an acute awareness
among women that this harassment is not only about the
“moment of harassment” but about how they are perceived in
a more complex way as being “good” or “bad” girls. One discussion
we had with a group of young men and women from a
non-governmental organisation (NGO) near Dharavi suggested
that a set of arbitrary codes distinguish “good girls” from “bad
girls” which inflects who gets harassed and how much. There
were loud disagreements which suggested that there is no consensus
on this. Responding to sexual harassment verbally may
stem the harassment or escalate it. Reusing a street on which
one had been harassed might be taken to mean a tolerance of
or even desire for such verbal harassment. There was no foolproof
way for women to convey that they did not enjoy “the
attention” (Phadke 2005).
When one talks to young women about their fears of sexual
harassment in public space, they tellingly articulate less a fear
of physical harm than the anxiety that by continuing to access
these spaces where they are sexually harassed, they are in fact
courting a risk to their reputations. That their presence on
streets where sexual harassment is likely reflects a certain
kind of unbecoming “boldness” which indicates their unsuitability
for an arranged marriage. They fear partly the young
men but also the “community” who will “talk” thus cementing
their reputations, or more accurately, lack thereof.
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When we raised the question of unfriendly bodies at a workshop
in Pune in August 2011, and talked about the dilemmas
posed by pitting the rights of young men against those of
young women in public space, one group articulated the argument
that unfriendly bodies include not just the young men
who might pass comments but also neighbourhood “aunties”
who would pass other kinds of, equally discomfiting comments.
12 This immediately complicates our understanding of
who constitute unfriendly bodies in public space, as also our
perception of deterrents to loitering.
Here it is worth reflecting on the smooth elision whereby
the young men who are admittedly a source of discomfort to
the young women are sought to be taken off the streets while
the aunties and their equally threatening presence (certainly
to reputation) and therefore to women’s access to the public
only acquire more legitimacy.
This argument, while it does not offer any solutions, does
allow us to reflect on the notion that it is only some unfriendly
bodies that are rendered illegitimate and not others which
ironically acquire even greater legitimacy as the upholders of
morality or are at the very least seen as benign (if gossipy)
presences. Their very real role in actually restricting young
women’s mobility in and access to the public is rarely the subject
of debate. Here one might be tempted to argue that the
sexualised gaze may be perceived, even experienced, as more
immediately threatening than the moral-policing of the aunties
and this may well be the case. This does not, however, in
any way undermine the argument that there are different
kinds of unfriendly bodies who contribute to women’s restricted
access to public space.
The social figure of the perpetrator of sexual harassment is
layered and complicated by a film produced by Askhara (a
women’s resource centre) titled Jor Se Bol, an anti-street- sexualharassment
film. 13 The documentary subverts the process of
“othering” since the filmmakers knew some of the men seen
hanging out at street corners in the documentary. This not only
immeasurably complicates our understanding of the male unfriendly
body but also places him firmly as an agential subject.
In a thoughtful blogpost on the Delhi gang rape, Kamayani
Sharma (2012) points out that as a middle-class young woman
who has migrated to one of the metropolises, she has had to
rely on strangers, men “to help me find accommodation in the
least shady neighbourhoods, move into said accommodation,
repair my lavatory, fix sockets and bring me home in their rickshaws
and taxis at odd hours”. She points out that all of these
men were “working class” and “less educated”. From the “train
driver who scared off a drunken beggar hauling himself next
to me on the last Churchgate-Virar, the rickshaw driver who
asked me if I was sure about going alone down the dark path
that led to my room or the tempowala-turned-friend who
helped me bring home my refrigerator from the station after
midnight for free”. 14 This layered narrative complicates our
understanding of the urban lower-class male.
Another figure, strangely a figure of authority, the policeman
is also seen as an unfriendly body, especially after dark.
Young women often recount that they have been instructed
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not to approach policemen on the street to ask for directions or
any other kind of help. One young woman was told by her
father as she was learning to drive to never stop even if a “cop”
flagged her down. She was instructed that they would deal
with whatever problem it was later on but as a lone woman
driver, she should simply drive on. Stories of violence committed
by the police only buttress these narratives.
There are multiple ways of complicating the discussion on
unfriendly bodies. One is to think through the range of bodies
in public space that might be constructed as unfriendly so that
the discussion is more complex and nuanced rather than identifying
the lower-class male as the single villain of the piece.
Another is to think through the possibility of populating public
space with friendly bodies whose presence might counter the
threat perceived to be emanating from unfriendly bodies. This
of course is a partly academic exercise but might also hold possibilities
for thinking about how we might envisage an “ideal
composition” of public space such that it will be inclusive in a
general sense and more particularly gender friendly and welcoming
to women across class, caste, community and ability.
It is also important to record that it is not only individuals
who render spaces unfriendly – contexts such as empty streets,
design factors such as enclosed footpaths which have no escape
route and the lack of infrastructural facilities like transport,
toilets, adequate street lighting – but also contribute to the
creation of unfriendly spaces. Cities need not, and should not,
be hostile and unfriendly spaces because of a lack of infrastructural
facilities. Good public transport, for instance, is
central to facilitating access to the city and the provision of 24-
hour public transport would go a long way in making cities
friendlier (Phadke 2012). I would argue that the sexual assault
that took place in the privately run Whiteline bus could not
have happened in a BEST bus in Mumbai because the checks
and balances that operate in a public sector company would
make it virtually impossible to take a BEST bus out for a joyride.
15 Also contrary to popular assumption, shutting bars and
restaurants early do not make cities safer. The more the number
of people out on the streets at night the safer the streets. 16
Can we begin to think about street violence in more comprehensive
and complex ways not only as something men do to
women but also as emanating from the structures of power itself
as well as operating on multiple axes – gender, class, caste and
religion, as also infrastructure (or lack thereof) and design?
3 Friendly Cities, Unfriendly Cities
In 2008, along with my colleagues Shilpa Ranade and
Sameera Khan I was invited to participate in the International
Symposium of Electronic Arts that was held in Singapore as
part of an artists-in-residence programme. 17 In this section, I
reflect on four short but intense weeks of living in and thinking
about loitering in Singapore in 2008 and juxtapose these
thoughts with our research in Mumbai.
As someone who grew up in a city that wanted to be Singapore,
the idea of the super clean city-state was part of my imagined
cityscape of the world. Arriving in Singapore, Ranade
and I were taken aback to arrive at a degree of comfort in
54
navigating and negotiating the city, its transport and its
idiosyncrasies within two days. Within another two days we
had our work in place. We were aided in the creation of part of
our installation by a group of students at the National University
of Singapore. 18
Our media installation titled “Gendered Strategies for
Loitering”, aimed to question some of the underlying assumptions
about public space and gender in both Singapore and Mumbai,
raising questions about the possibilities for loitering. Both
cities have similar colonial throwback legislation allowing the
police to arrest suspicious loiterers after sunset and before
sunrise. Through the idea of loitering, the installation attem pted
to ask questions about pleasure, risk, and citizenship. The
work included a new-media “game” inviting the audience to
“loiter” in a street in Mumbai. This was complemented by
time-lapse video footage of three locations each in Mumbai
and Singapore and an audio commentary that engaged with
the gendered inhabitation of public spaces in the two cities.
In the time-lapse videos, a camera placed on tripod shot half
a second every 30 seconds creating an audiovisual document
that attempted to map the movements of people in that space.
In Mumbai we shot at the Holi Maidan in Dharavi, Shivaji Park
in Dadar and Carter Road in Bandra. In Singapore, we shot at
the Padang, an open playing field in central Singapore sometimes
used for National Day parades, in an open square in an
Housing Development Board (HDB) complex in China town,
and in an open space, near the Jurong East Mass Rapid Transit
(MRT) railway station that many people used to walk through.
In Mumbai, the Holi Maidan was occupied mostly by young
boys playing while older men stood aroud a liquor bar at the
edge of the ground. The Shivaji Park was full of different
groups of boys playing cricket, other people including women
and college girls walking through and often heading towards a
temple at the edge of the park while varied others were seen
walking along the periphery of the park or sitting on the low
wall which marks its boundary. 19 We shot a section of Carter
Road from a high-rise building finding that often people
walked along this road but rarely paused to loiter.
In Singapore, there was a football game going on in the
Padang, and many different groups of tourists came in to photograph
themselves against the backdrop. In the HDB in Chinatown
once again people moved in and out of the square we
were shooting and only twice did anyone stop to chat. Along
the path in Jurong East, people moved with the rapidity of
commuters heading home after work. In this fairly large
maidan, nobody loitered.
While shooting in Mumbai we inevitably encountered a
crowd following us with a dozen questions. In Singapore, where
both of us were obviously foreigners, we expected more questions,
only to be completely flummoxed when none, absolutely
none, were forthcoming. It seemed to us as if their lack of
curiosity held within it a sense of lack of claim. This strange city
baffled us even as it offered us an experience of previously unmatched
efficiency and productivity. This was a city where as a
woman one felt a sense of comfort, where one did not have to
plan one’s clothing (in an effort to avoid sexual harassment)
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and one could wander around at night without needing to strategise
about how to get back home. The public toilets got us to
pull out our cameras, so beautiful and well designed were they.
Singapore baffled us, because despite its safety and comfort,
nobody loitered. The women were out there as much as the
men, in their short-shorts, head-scarves and salwar-kameezes,
often late into the night. Yet, if we looked carefully, nobody
loitered. Not the women, not the men. Nobody loitered outside
the segregated spaces for loitering – the void decks, the hawkers’
centres, and of course needless to say, the malls. Even the
loitering behaviour of the foreigners appeared segregated and
contained and most migrant workers would head for one or
another mall on their Sundays off. 20
People might walk in defiance of the demarcated pathways,
as Gunalan Nadarajan, non-resident Singaporean and curator
of the exhibition pointed out to us, 21 or use complaint and humour
as a form of articulating dissent, especially in the anonymous
space of the internet as Selvaraj Veluthan (2004) has
argued; but any subversion appeared to end there. The city
was not anonymous enough to allow for more. The glorious
lighting that made it so much safer for people to use the streets
also had the effect of rendering everyone visible.
In Mumbai, at least some men loiter. They stand at corner tea
stalls sipping “cutting-chai” (a half-glass of strong tea) and relax
indolently at paan-shops, smoking. Often many marginal men:
manual workers, taxi and rickshaw drivers and those we call
taporis in Mumbai (people who have no apparent work/
employment) and occasionally students too are part of this group.
Women, with the exception of students in the vicinity of their
college campuses, are discouraged from loitering on the streets.
However, because men loiter and because the streets are
complex mazes of people and objects and often because the
energies of the city public spaces are dispersed confusingly
and unpredictably, it is actually possible for women to imagine
loitering. To imagine slipping into the interstices of public
spaces unnoticed and unremarked; left to forge one’s own connection
however tenuous with the city. To subvert the desires
of the city for regulation and order and to know that one is safe
from recognition in the amorphous, anarchic city. Though this
possibility of anonymously slipping into the city falls very short
of any kind of political claim, it nonetheless is significant in its
approximation of the pleasures of loitering in city public space.
If at all one sees women obviously hanging out in Mumbai, it
is only in the new spaces of consumption that one sees them
performing masquerades of flanerie and loitering; window
shopping and strolling along the gleaming vitrified floors
enjoying the illusion of the pleasure of the public. The malling
behaviour of middle-class women might provide a clue to understanding
why nobody loiters in Singapore. As we walked down
Orchard Road in Singapore, the undisputed queen of retail
districts, it felt like the entire city seemed to draw on the texture
of this mall-dotted road. Orchard Road symbolises the life
and pleasures of the city, and most people whom we asked
what we should do in Singapore pointed us in its direction.
It seemed to us then that in some ways the entire city had
been rendered private. One might conjecture that the safety
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we felt in Singapore could be compared to the sense of safety
the consumer citizen felt in a mall in Mumbai, for instance. 22
The lack of claim staking we sensed in people might be attributed
to this – the notion that it all belonged to the privatised
state that was responsible for its upkeep. Citizens were merely
users/consumers, not co-owners. One might argue that like in
the malls the illusion of public space is performed repetitively
so that the lines between public and private appear to blur
without affecting the reality that these are private spaces, controlled
and under surveillance. 23
In one sense Singapore is the culmination of everything
Mumbai city planners want, both rhetorically and literally: a
city of clean lines, sparkling buildings where people usually
stay in the areas they are supposed to, conforming to the
omniscient vision of the planners. In Mumbai, the thrust of all
new development is towards cleansing the city, of removing
the undesirables from the visible body of the city. Women’s
safety, or to be more specific, middle- and upper-class women’s
safety, is similarly premised on the removal of lower-class and
minority men from public spaces.
In another, more tentative vein, I would like to reflect briefly
on the responses of two expatriate women who had been living
in Singapore for some years when we met them. They separately
pointed out that while Singapore is largely free of street
sexual harassment, it was also devoid of sexual possibilities in
public. A part of the excitement of public spaces is the anticipation
of meeting someone interesting, of a flirtation or just the
thrill of that momentary frisson one feels exchanging glances
of mutual attraction without necessarily acting on it. The loss
of such sexual possibilities is difficult to quantify and only two
women expressed this sentiment without prompting, though
several others concurred when asked. While this is far from a
representative sample it is nonetheless important to ask, what
are the various possibilities that are lost when public space is
devoid of surprise, excitement, and yes, even risk. 24
When one thinks of safety in a city and the idea of a friendly
city, Singapore qualifies. However, the unanswerable question
that we are faced with is one that we have read in the subtext
of many of the conversations we have had with women in
Singapore and Mumbai – how does one speak to the choice
between personal freedom and safety?
Loitering and Safety
In public space terms, how do we weigh the uncertain pleasures
of loitering against the certainty of safety? What is the
trade-off between street pleasures and the seated comfort of a
hawkers’ centre? To what extent would we be willing to trade
the pleasure of unexpected discoveries of the new hawker
round the street, the anarchic street life, the spaces that
nobody can see, for the monitored guarantee of safety? What
are the relative values of freedom and comfort? The choice
between freedom and comfort is a complicated one, especially
when it comes to safety.
What does it mean to desire to access spaces that may be
hostile? What does this mean for risk and strategising? Of
course we cannot wait until all streets are safe – but do we
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even imagine they will ever be safe, given that not even our
homes are safe. If they are to be safe then does this mean they
will also inevitably be sanitised?
Are there other possibilities that we might consider other
than one where the city becomes an extension of the mall? A
space perhaps not as seductively friendly, but a space that
might offer both the possibility of coexistence as well the possibility
of articulating not just dissent but also staking a claim
to city public spaces?
4 Friendliness and the Street
Streets are spaces where people make claims. Streets are also
spaces where these claims are shot down. Streets are spaces of
surveillance and spaces of fear. They are also spaces of excitement
and thrills. How might one imagine a street utopia, if
indeed such a thing exists? Or in other words, how might one
mobilise the varied dynamics of the street in the quest of a
more liberatory politics.
In the early 1960s urban writer Jane Jacobs wrote:
The tolerance, the room for great differences among neighbours – differences
that often go far deeper than differences of colour – are possible
and normal in intensely urban life, … streets of great cities have
built-in equipment allowing strangers to dwell in peace together on
civilised but essentially dignified and reserved terms, lowly, unpurposeful
and random as they may appear, sidewalk contacts are the
small change from which a city’s wealth of public life may grow
(Jacobs 1961).
The question then is how can one foster tolerance and coexistence
even in the presence of such hostility or fear? Would
the presence of (other) friendly or even “neutral” bodies allow
for a mutual coexistence? What kinds of spaces would enable
friendly bodies to act in solidarity? One of the factors that set
Mumbai apart from other megacities in India is the lack of
planning and concomitant separation of function. The lack of
formal order which often emanates from zoning is what allows
for a more varied interaction in public space. This means that
there are different kinds of bodies inhabiting public space and
the likelihood is that not all of these will be perceived as hostile.
The presence of the others – friendly or neutral – I would
like to suggest, creates greater possibilities for those who are
perceived to be hostile to each other to coexist.
Before going further it is important to ask the question:
What are friendly bodies? In my understanding, friendly bodies
would render a space more accessible generally making it
easier to inhabit public space. In interviews, women articulated
certain kinds of people as friendly presences on the
street. These included other women in general, college
students, pedestrians going about their business. Our research
suggests that the presence of hawkers often renders streets
friendlier. For instance, the roads alongside the Hutatma
Chowk in Fort used to have many street booksellers. In 2005,
the booksellers were removed and only a few remained at one
corner. This transformed what was a friendly street for women
commuters to walk down even after dark into one which was
much less so. Not only does the presence of hawkers contribute
to women’s access by bringing people onto the streets, adding
the street lighting and providing eyes in the street but in a
56
more general way is reflective of the right to be in public. The
recent efforts to boot hawkers off the streets in Mumbai are
therefore also counterproductive for women. 25
Often young women pointed to Bandra as the suburb of
Mumbai that they would all want to live in – for its acknowledgement
of the professional woman, but also for its busy
crowded streets even late into the night. Two women, by no
means a statistically significant number, but nonetheless worth
recounting, made the observation, that “in Bandra even the
presence of the sex worker is not anxiety inducing”. They are
simply co-users of the street. I am interested in thinking through
what makes this coexistence possible. Does the sex worker not
sexualise these particular streets? What makes the streets impervious
to such sexualisation? Alternatively, what might
make such sexualisation acceptable? Are there multiple layers
of sexualisation on some of these streets? I would like to risk
suggesting here that the more complex and multidimensional a
space, the more comfortable it is likely to be for women.
Another interesting narrative came from a young undergraduate
student at a book reading. She identified herself as a
sportsperson, and said that in the neighbourhood where she
lives in Vashi there are women hanging out, even loitering
rather late into the night. Young women and young men are
out on the streets, sometimes together but also separately and
there are a fair number of them. The number of young women
allowed out at night is growing. While she suggests a specific
sense of her own identity of that as a woman and a sportsperson
which perhaps had implications for how she experienced
and inhabited her own body and its capacities, it is nonetheless
interesting to reflect on the possibilities such narratives have
for thinking about friendlier, more accessible public spaces.
The Blank Noise project’s recent initiative, “Talk to Me”, reflects
on the question of how to make cities friendlier. One evening
they set up five tables and two chairs on a street in Bangalore
where sexual harassment often takes place. Volunteers sat at
these tables and invited strangers to talk with them. 26 The idea
was to build a dialogue across gender and class divides. This
initiative offers one way of thinking about the politics of public
space. Such initiatives valuable though they are in furthering
our engagement with the ideologies of space cannot but be
occasional performances and are thus out of the everyday.
However the idea of setting up sitting spaces is one that has
been proved to invite more people to hang out in public space.
What if more streets had such spaces inviting all kinds of
people to sit, chat and hang out? I would argue that the creation
of more spaces to hang out, thus legitimising this “loitering”
would transform streets making them busier, occupied by a
variety of different groups and therefore friendlier.
In our research on women’s access to public space in Mumbai,
a number of people suggested that among the factors that
contributed to making a space safe were a certain level of
crowds, open shops and in general a sense of activity. Women
often pointed out that there is an optimum level of people or
“crowds” in real sense strangers, who best facilitate access.
Too few people would make the streets appear deserted and
therefore not very safe. Too many people (think rush hour at
september 28, 2013 vol xlviii no 39 EPW Economic & Political Weekly

Churchgate station in Mumbai) would provide more opportunities
for sneaking in a pinch or a grab of valuables without
being caught and so one has to be careful. To my mind this
notion of the optimum suggests that there are enough people
to make you feel comfortable but not so many that it makes
you uncomfortable. If one thinks through this idea of the optimum
number of people one might be closer to understanding
the notion of mutual coexistence in public space with strangers
who are perceived as being a mixture of friendly, neutral
and unfriendly. I use the verb “perceived” to underscore that
the categorisation of bodies into friendly and unfriendly has
more to do with us and the way we “see” than with any objective
reality or fact.
Reflecting on these cases, it becomes increasingly clear that
the solution to the restrictions on the loitering of young women
is not to restrict the loitering by young men, or indeed anyone
else. However, conditions must be facilitated within which
more “friendly bodies” can be part of these public spaces.
While some bodies may be perceived as “unfriendly”, their
right to space needs to be acknowledged, without them becoming
the reason why young women cannot be in public space.
The idea of strangers – friendly, neutral and even unfriendly –
peopling one’s landscape is not a new one. Georg Simmel
(1908) in his seminal essay on the stranger suggested that most
forms of social interaction involve engaging with “strangeness”.
The stranger for Simmel is not the unknown outsider
from another planet (as it were) but someone who though he
does not belong to the group is known to it. “The stranger, like
the poor and like sundry ‘inner enemies’, is an element of the
group itself. His position as a full-fledged member involves
both being outside it and confronting it.” The stranger then in
Simmel’s understanding is a part of our world. He suggests
that the stranger who is really strange has to be rendered notquite-human
so not to be regarded as part of the group at all.
Michael Warner (2002) reflects on stranger-sociability
arguing that
In modern society, a stranger is not as marvelously exotic as the wandering
outsider would have been in an ancient, medieval, or early
modern town. In that earlier social order, or in contemporary analogues,
a stranger is mysterious, a disturbing presence requiring resolution. In
the context of a public, however, strangers can be treated as already
belonging to our world.
In April 2009 a young international female student in Mumbai
was drugged and sexually assaulted by six acquaintances. She
had gone out with the accused youth, whom she had met once
before as her friend’s friends, and another female friend to a
suburban bar. After the female friend left, the woman student
continued to hang out with the male friends at the bar and at
their insistence drank alcohol. Later she accompanied them to
the apartment of another of their male friend where she was
assaulted while she was unconscious. 27 This young woman
was sometimes cast as “stupid” for going out late at night with
these “strangers”.
How does one categorise people as friends and strangers?
When asked whether they would categorise the accused as
“friends” or “strangers” in relation to the young woman and
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her acquaintance with them, many undergraduate students in
a workshop in Mumbai in 2011 said “friends”. This categorisation
is important in framing our understanding of the stranger
on the street and to thinking through the ways in which we
engage with people locating them in categories based often
not on our own experience with them, but where they stand in
our larger constellation of social contracts. 28
Here it might be relevant to engage with the work of feminist
philosopher, Iris Marion Young. Young (1995) suggests
that the ideal of city life is not communities, for communities
by their very nature are exclusive, but a vision of social relations
as affirming group difference which would allow for different
groups to dwell together in the city without forming a
community. She argues that reactions to city life that call for
local, decentralised, autonomous communities reproduce the
problems of exclusion. Instead, Young imagines a city life
premised on difference that allows groups and individuals to
overlap without becoming homogeneous.
Young uses the term “heterogeneous public life” engaging in
a debate on justice, community life and the politics of difference.
She argues that justice in a group-differentiated society
demands social equality of groups, and mutual recognition
and affirmation of group differences (p 191, 1990 quoted in
Callard 2011: 485). Young’s arguments displace the idea of
community with the ideal of “(c)ity life as an openness to unassimilated
otherness” (p 227, 1990 quoted in Callard 2011: 485).
If following Young, we were to construct public space as
more generally unfriendly, a space to be negotiated rather
than welcomed into, would competing claims to public space
look different? If we give up our warm and fuzzy notions of the
public, would young women’s access to public space be built on
different assumptions? If we stopped accepting sanitised, deodorised
spaces as a substitute, would our claim to public space
be articulated differently? If we claim not the right to safe public
spaces but the right to negotiate violence in public space in
the same way that we do in other spaces such as the home,
how would this transform our engagement with public space?
Imagining (Unconventional) Utopias
We are sometimes asked “so how will you operationalise loitering?”
How indeed? It is important that we keep on asserting
and reasserting the value of wandering aimlessly and hanging
out on the streets without purpose as a means of claiming not
just citizenship but the right to fun.
Can we imagine a city that allows the people, the “public” to
find their/our own “public” – to create our own spaces to hang
out as we please, where we please without the threat of being
on the wrong side of the law. It is ironic to be in a city where
globalisation has made some kinds of risks such as those related
to international finance legitimate while rendering the
everyday risks of hanging out on the streets questionable.
I conclude with the image of a loitering space that I am
familiar with. Near the campus where I teach in an unremarkable
eastern suburb of Mumbai is a space where diverse people
appear to loiter. There are a number of shops ranging from a
chemist, to a clothing boutique to a hardware shop, a car rental
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SPECIAL ARTICLE
service and several closed shops that once housed groceries,
ATMs and the like. Rumour has it that only the chemist makes
money – the other shop spaces are supposedly unlucky. The
shops are at an elevation of about four or five feet which means
a long ledge of steps ideal for people to sit on. There is a taxi
stand and an awning under a peepal tree where the taxi drivers
sit and play cards, and in my personal though certainly not
representative experience they often refuse fares and prefer to
continue their card game. There is a bus depot across the road
and bus conductors and drivers frequent this space and can often
be seen laughing and back-slapping each other. Students and
faculty “hang out” here at odd hours often (tho ugh not necessarily)
escaping from the no smoking zone of the campus. There
is a chai stall, a vada pav (a snack popular in Mumbai) stall and a
paan-shop at the edges of a nalla that is currently being built over.
In fact, usually, there is some digging or filling activity sponsored
variously by the electricity, telephone, cooking gas or internet
cable companies or the water and sanitation departments.
Students, faculty, taxi drivers, bus and other drivers, bus
conductors, construction workers engaged in digging the
roads all frequent this space. Friends, romantic couples,
colleagues, and strangers smoke, drink cutting chai and chew
tobacco as they sit or stand and chat animating this space long
after it is dark. They move in an intricate layered dance and
rarely interact with each other. But day after day in the kind of
visceral everyday practice that Michel de Certeau wrote of and
the kind of implicit treating of strangers as already belonging
to a larger cityscape that Michael Warner suggested, these
different kinds of people co-inhabit this space.
I do not want to exoticise or romanticise this space, though
perhaps it may appear as if I am doing exactly that. I am acutely
aware that a large number of the middle and upper-middle
class bodies inhabiting this space belong to my workplace and
these bodies transform the space as only a space outside a
campus may be transformed. Interestingly, it is hardly an
aesthetically welcoming space – it is often dusty, noisy and one
is frequently in danger of being run over. Yet this space of
transient strangers offers a strange kind of hope that friendly
and unfriendly cities are not really binaries and it is possible to
imagine new ways of engaging both.
Notes
1 There are several examples that make this case.
One is the Marine Drive rape case in 2005 where
a constable raped a college student. Another is
the New Years Eve 2008 incident where a mob
of men molested two women in Juhu. A third is
the December 2012 Delhi gang rape and most
recently the Mumbai attack. All of these received
wide press coverage for several days and
were accompanied by public outrage.
2 For instance, in the 2006 case involving
Abhishek Kasliwal was followed by the media
until it appeared that the victim was a sex
worker, after which the coverage died down as
did the case itself. Most recently the police
have thus far failed to arrest Asaraam Bapu
who has been accused of raping a minor girl.
3 “Soumya Murder: Sheila in Dock over Remarks”,
The Indian Express, New Delhi, 2 October 2008,
http://www.indianexpress.com/news/soumya
-murder-sheila-in-dock-over-remarks/368692/
accessed on 12 January 2013.
4 The Delhi and National Capital Region police in
particular have been quoted as saying women
Women and Work
Edited by
Padmini Swaminathan
should stay home and that they are only asking for
trouble. (Abhishek Bhalla and G Vishnu (2012),
“The Rapes Will Go On”, Tehelka Magazine,
Vol 9, Issue 15, 14 April, http://archive.tehelka.
com/story_main52.asp?filename =Ne140412
Coverstory.asp, accessed on 1 March 2013).
5 “PM Warns of ‘Footloose Migrants’ from Rural
Areas”, Hindustan Times, New Delhi, 27 December
2012. (http://www.hindustantimes.com/
India-news/NewDelhi/PM-warns-of-footloosemigrants-from-rural-areas/Article1-981257.aspx,
accessed on 14 January 2013.)
58
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september 28, 2013 vol xlviii no 39 EPW Economic & Political Weekly

6 After the incident on New Years Eve 2008, discussed
earlier, without awaiting any evidence,
“outsiders”, specifically north Indian men were
cast as the culprits responsible for “disrespecting
women” and “giving Mumbai a bad name”
by the Shiv Sena. The implication clearly was
“remove these men from our city and our
women will be safe”. Ironically, at least half the
suspects who were apprehended turned out to
be Marathi-speaking young men. “Migrants
Are Defaming City: Uddhav – Says Sena Will
Not Tolerate Atrocities against Women”, Daily
News & Analysis, 5 January 2008, http://www.
dnaindia.com/mumbai/1143275/report-migrantsare-defaming-city-uddhav,
accessed on 2 January
2013).
7 Similar analyses in the African contexts point
out that “While research on women since
the 1970s accumulated deep insights into the
impli cations of socio-economic change, poverty
and increasing workloads for African women,
similar insights on men were not documented.
In attempts to make African women’s work
visible some analyses slipped into representing
African rural men as not doing very much at
all” (Whitehead 2000).
8 Saskia Sassen (2010) argues that unlike earlier
when countries go to war today, cities become
“a key frontline space” (p 34). This takes place
even outside of wars in the form of bombings
and other kinds of attacks. She suggests that
“asymmetric war”, that is war between a “conventional
army and armed insurgents” have
located cities as sites of the theatre of war. Sassen
quotes the US Department of State’s Annual Report
on Global Terrorism which suggests that
“from 1993 to 2000, cities accounted for 94%
of the injuries resulting from all terrorist attacks,
and for 61% of the deaths” (p 36).
9 Nor is it just violence that makes us uncomfortable.
As I have argued elsewhere, it is only unstructured
violence by strangers that raises all
kinds of anxieties. Violence at home is pervasive
but women are rarely warned about the
dangers of the home. Further, violence enacted
in the name of preventing public attack is articulated
as family honour, protection, and even
love. What we need to claim then is the equal
right to negotiate violence in public as we do in
private (Phadke 2010).
10 Sometimes, it is women’s families who place
obstacles to loitering, deeming them too risky.
One blogger talks about one endeavour among
a group of professional women to “loiter” on a
street in Hyderabad and the kinds of restrictions
that came up (Bolar, Suman, “The Importance
of Loitering”, http://www.talkingcranes.com/
In%20the%20news/the-importance-of-loitering,
accessed on 15 May 2013).
11 The large numbers of cases of honour killings,
various diktats by community groups against
jeans, mobile phones and even headgear worn
on two-wheelers bear this out.
12 Interestingly in the wake of the 16 December
2012 Delhi gang rape, an article on the internet
addressed the neighbourhood Aunty exhorting
them not to moralise or pass judgment on
“Girls of These Days”. (Shridhar Sadasivan,
“A Letter to the Neighbourhood Aunty from the
‘Girls of These Days’ ”, 30 December 2012,
http://www.womensweb.in/2012/12/girls-ofthese-days/,
accessed on 15 January 2013.)
13 Here is a link to an excerpt from the film, Jor Se
Bol: http://www.youtube.com/watch? v=EO
M6M9uUYy8
14 Sharma Kamayani (2012), Not Your Ma Behen:
A Nation of Victims, 27 December http://ultraviolet.in/2012/12/27/not-your-maa-behen-anation-of-victims/
accessed on 2 January 2013.
15 Of course assaults of various kinds have taken
place on the surburban railway network
in Mumbai.
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16 See for instance this news item on shutting
down of such spaces: http://indiatoday.intoday.in/story/verify-all-school-buses-close-discotheques-by-1-am-in-delhi-government-panel/
1/241512.html, accessed on 1 April 2013.
17 More information on this work is available
here: http://www.isea2008singapore.org/exhi
bitions/air_gendered.html
18 This group of students were guided by a very
engaged faculty, Alex Mitchell and we are
grateful to him and his students.
19 Our research on parks in Mumbai suggested that
Shivaji Park was one of the most friendly and
accessible parks for its lower wall, its hawkers
at the edges and the fact that it was populated
late into the night (Phadke et al 2011).
20 In the few weeks that we were there in 2008,
different groups could be found in specific
malls. For instance, Filipina maids congregated
in Lucky Plaza on Orchard Road; Bangaldeshi
construction workers tended to occupy the
street and the open ground on Serangoon
Road near Mustafa; the Chinese migrants
headed to Chinatown; the Indonesians occupied
City Plaza in Katong; the Thai people
went to Golden Mile near Beach Road; and the
Myanmar migrants could be found in Peninsula
Plaza in City Hall.
21 Personal conversation, July 2008.
22 In a recent piece, Yamini Vasudevan (2012)
writes about how safe she felt growing up in
Singapore, compared to her life in Chennai.
She writes, “What would make me safer would
be conscientious policemen and women, and
all those in power, who would wield their
authority in the right way. In Singapore, there
was always the confidence that if anyone misbehaved
with me, at any time, all I had to do
was to hail a policeman nearby or rush to the
nearest police station. Something would be
done – I knew that much. And it wouldn’t matter
whether I was dressed in jeans or shorts. If a
complaint was made, action would be taken.
And it wasn’t just the police – bus drivers would
stop the bus if someone raised an alarm. I could
hop off at train stations and report to the person
at the control station. But there was never
such a need – not in the 16-plus years I lived
there.” This suggests to me certainly that it is
authoritarian structures that are perceived to
provide this safety – again not unlike in a mall
Yamini Vasudevan (2012) “I’m Envious of Their
Freedom”, Hindu Business Line, 26 December
2012, http://www.thehindubusinessline.com oncampus/
i-am-envious-of-their-freedom/article4241751.ece,
accessed on 26 December 2012.
23 If as Selvaraj Veluthan (2004) suggests Singapore
is a state that gives its people the gift of
material comfort, it then demands a quid pro
quo, in the shape of the disciplined modern citizen;
then one might suggest that Mumbai is a
city that gives its citizens very little, often not
even the certainty of citizenship. This lack of
giving and the common acknowledgement of
the lack allow people to act in defiance of the
demands of law and order. For if the state can
renege on its promises, what binds the citizens?
24 See Phadke (2007) for an engagement on the
desirability of negotiating risk.
25 This has been widely reported in the media.
See one such feature article. Arefa Johari,
“Stalled”, Hindustan Times, !3 February 2013,
http://www.inclusivecities.org/wp-content/
uploads/2013/02/Hindustan_Times_Mumbai
2013-02-03_page13.pdf, accessed on 1 March
2013. See this link for more articles on the
issue: http://www.inclusivecities.org/blog/
mu mbai-hawker-evictions/
26 Sarah Goodyear, “Can a Couple of Tables
Make Bangalore’s ‘Rapist Lane’ Safe Again?”,
3 July 2013, http://www.theatlanticcities.
com/neighborhoods/2013/07/can-couple-tablesmake-bangalores-rapist-lane-safe-again/6094/,
accessed on 8 July 2013.
27 On 6 October 2010 the Sewri Sessions Court in
Mumbai acquitted all six accused in the case,
citing lack of evidence and the unreliable testimony
of the victim. On 29 June 2011, the Bombay
High Court upheld acquittal by dismissing the
appeal filed by the Maharashtra government
challenging the earlier verdict of a trial court
in the case, citing lack of evidence and the unreliable
testimony of the victim.
28 Further, though it is well documented, it is
worth reiterating that the largest number of
attacks are committed by people known to the
victim/survivor.
References
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Chakravarti, Uma (2000): “State, Market and Freedom
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