Tag: #GuardiansandWardsAct

S.no	Contents
1.	INTRODUCTION
2.	WHO IS A MINOR?
3.	CAN MINORS ENTER INTO A CONTRACT?
4.	CONTRACTS OF BENEFICIAL NATURE
5.	BENEFICIARY TO A CONTRACT
6.	RESTITUTION
7.	NO ESTOPPEL AGAINST MINOR
8.	RATIFICATION BY A MINOR
9.	VOIDABLE AT THE OPTION OF A MINOR
10.	CONCLUSION

INTRODUCTION

The capacity to contract is a crucial aspect of contract law, which refers to the ability of a person to enter into a legally binding agreement. In other words, it is the legal competence or power of an individual or entity to enter into a contract that creates enforceable rights and obligations between the parties involved.

To be bound by a contract, the parties must have the legal capacity to agree. This means that they must have the mental capacity and legal status required to form a legally binding contract. The law recognizes that certain individuals or entities may not have the necessary capacity to enter into a contract, and therefore, any agreement they make may not be legally binding.

For example, minors, individuals with mental incapacities, and individuals under the influence of drugs or alcohol may not have the legal capacity to enter into a contract. In such cases, any contract they enter into may be deemed void or unenforceable. Similarly, corporations and other legal entities must also have the capacity to contract. This means that they must have the legal authority and power to enter into a contract, as well as the necessary authorization from their board of directors or shareholders.

Overall, the capacity to contract is a fundamental element of contract law, as it ensures that contracts are entered into freely and voluntarily by parties who have the legal competence and power to be bound by them.

WHO IS A MINOR?

According to Section 3^[1] of the Indian Majority Act, of 1875, an individual is considered to have achieved the age of majority once they turn 18 years old, with the exception of two scenarios

• If a guardian has been appointed for a minor’s person or property under the Guardians and Wards Act, of 1890, then the minor will remain a minor until they complete the age of 21 years.
• If a Court of Wards has assumed the superintendence of a minor’s property, then the minor will also remain a minor until they complete the age of 21 years, even if they have already turned 18 years old.

Under the act, minors enjoy a privileged position whereby they can bind others to contracts, but cannot themselves be held accountable for any breaches. This means that a minor cannot be held personally responsible for any wrongdoing they may commit.

CAN MINORS ENTER INTO A CONTRACT?

According to Section 11^[2] of the Indian Contract Act, of 1872, it is explicitly prohibited for a minor to enter into a contract. This prohibition means that any contract entered into by a minor, regardless of whether the other party was aware of their age, will be considered void-ab-initio, or invalid from the outset. This means that even if a minor is just one day away from turning 18, they will still be considered a minor in the eyes of the law, and any contracts they enter into will be deemed void.

Let’s take an example to understand the legal concept of minors and contracts;

In this case, Mr D, a minor, mortgaged his house for Rs.20,000 to a moneylender, who paid him only Rs.8,000. Subsequently, Mr D filed a lawsuit to set aside the mortgage agreement.

The court held that as per Section 11 of the act, a minor is not capable of entering into a contract, and any contract entered into by a minor is void. Therefore, the mortgage agreement between Mr D and the moneylender was void-ab-initio, as Mr D was a minor at the time of the agreement. The court further held that since the contract was void, Mr D was not liable to repay the moneylender any amount of the mortgage. The court allowed Mr D’s request to set aside the mortgage agreement, and the moneylender was not entitled to claim any rights on the property mortgaged by Mr D.

It is a well-established legal principle that minors are generally unable to enter into contracts, given their lack of legal capacity. However, there are two notable exceptions to this rule;

CONTRACTS FOR NECESSARIES

These are goods and services that are necessary for the minor’s support and maintenance. In such cases, a minor can enter into a contract for necessities, and the contract will be binding on the minor to the extent that it is reasonable and necessary.

CONTRACTS OF BENEFICIAL NATURE

 This type of contract is entered into for the benefit of the minor and is therefore binding on the minor. Examples of such contracts may include contracts for education or to advance the minor’s business interests. It is important to note that in both cases, the contracts must be entered into for the benefit of the minor in order to be legally enforceable. These exceptions to the general rule regarding minors and contracts serve to protect the best interests of minors and ensure that they can enter into necessary and beneficial agreements. The principle that a minor cannot enter into a legally binding contract has been firmly established in various landmark cases. One such notable case is Mahori Bibi v/s Dharmodas Ghose^[3], where the court held that a minor’s contract is void ab initio and unenforceable, even if the minor has misrepresented their age or misled the other party into believing that they were of age. The case has been widely cited and has played a pivotal role in shaping contract law in India, reaffirming the principle that minors cannot be held liable for obligations under a contract and can seek to have the contract set aside if necessary.

BENEFICIARY TO A CONTRACT

It is recognized that a minor can serve as a promisee or beneficiary in a contract and that a contract that is advantageous to a minor can be enforced by them. Notably, there are no limitations on a minor serving as a beneficiary, such as in the role of a payee or promisee within a contract. In light of these considerations, it follows that a minor possesses the ability to purchase real property and may initiate legal action to recover possession of the property after tendering payment for its purchase.

RESTITUTION

Where a minor has received benefits under a contract, he is bound to make restitution or return the benefits received. For instance, if a minor enters into a contract to purchase a car and has paid some amount of money, the seller is required to return the money to the minor and take back the car. If a promissory note is executed in favour of a minor, they have the right to enforce it accordingly.

Furthermore, a minor who has extended a loan to someone and experiences a refusal by the borrower to repay the loan based on the voided agreement has the entitlement to reclaim the loaned funds. In a legal context, these principles are crucial for contracts in which minors are involved. It is important to note that this legal principle regarding the capacity of minors in contracts has been demonstrated in various legal cases. For instance, the case of General American Insurance Co v/s Madanlal Sonulal^[4] illustrates how a minor was able to recover insurance funds after a loss, despite the fact that the goods in question had been insured on behalf of the minor. Such cases serve to affirm the legal rights and entitlements of minors in contractual matters.

NO ESTOPPEL AGAINST MINOR

The legal principle of estoppel is intended to stop a person from arguing something or asserting a right that refutes what they formerly said or agreed to by law. However, it is important to note that this principle does not apply to minors in the context of contractual agreements. Specifically, an infant or minor is not estopped from setting up the defence of incompetence due to minority. This is because the law of contract is designed to protect minors from incurring contractual liability, given their limited legal capacity. As such, the defence of estoppel cannot be used against minors in contractual matters.

In situations where a minor misrepresents their age and induces another party to enter into a contract with them, the minor cannot be held liable for the resulting contract. Specifically, no estoppel can be asserted against a minor in such cases. This means that the minor cannot be prevented from pleading their infancy as a defence in order to avoid the contractual obligation.

This is because the law recognizes the limited legal capacity of minors and aims to protect them from the consequences of their contractual agreements. As such, a minor cannot be held responsible for a contract that they entered into while still legally considered a minor, regardless of any misrepresentation that may have occurred. Ultimately, the principle of no estoppel against a minor serves to safeguard the rights and interests of minors in contractual dealings.

According to the ruling in Vaikuntarama Pillai v. Athimoolom Chettiar (1915 Madras H.C.)^[5], “There is a clear statutory provision that minor being incompetent to contract is incapable of incurring any liability for any debt, the law of estoppel cannot overrule this provision to make him liable.” This statement emphasizes that minors are not legally responsible for debts incurred through contracts and that the doctrine of estoppel cannot be used to make a minor liable for a contractual debt. The ruling underscores the importance of protecting minors in contractual matters and ensuring that they are not unfairly subjected to legal liabilities.

RATIFICATION BY A MINOR

Ratification refers to the act of confirming or validating a contract that was entered into while the person was a minor, after they have attained the age of majority. Once a minor attains majority, he or she has the option to either affirm or disaffirm the contract. If the minor chooses to affirm or ratify the contract, then the contract becomes binding and enforceable. By doing so, the minor becomes bound by the terms of the contract and can be held liable for any breach of the contract. It is essential to note that once a contract has been ratified, the right to disaffirm the contract is lost and cannot be exercised again. Ratification can be expressed or implied, and it can be done through words or actions. For example, if a minor purchases a car and continues to use it after attaining the age of majority, then it can be considered an implied ratification of the contract.

VOIDABLE AT THE OPTION OF A MINOR

In cases where a minor enters into a contract that is not for necessaries or of a beneficial nature, the contract is considered voidable at the option of the minor. This means that the minor has the option to either ratify the contract or repudiate it. If the minor chooses to repudiate the contract, then he or she is not bound by the terms of the contract and is not liable for any breach of the contract.

This provision is based on the understanding that minors are not legally competent to enter into binding contracts. Therefore, if a minor is to be held responsible for a contract, it must be a contract that is for necessaries or of a beneficial nature, or one that has been ratified after the minor has attained the age of majority. If a minor decides to repudiate a contract, he or she must do so before attaining the age of majority. Once the minor attains the age of majority, he or she can no longer repudiate the contract. If the minor does not repudiate the contract before attaining the age of majority, then the contract will be considered valid and enforceable.

It is important to note that if the minor ratifies the contract after attaining the age of majority, then the contract becomes binding on the minor, and he or she can be held liable for any breach of the contract. Therefore, it is essential for minors to carefully consider the consequences of their actions when entering into contracts, and to seek legal advice if necessary.

CONCLUSION

It is crucial to recognize that strict rules must be applied to contracts made by minors. It is often questioned why a minor who is one day away from attaining majority and has committed a breach in the contract should get away with it. However, it is important to understand that the law exists to provide a reliable framework to protect individuals’ rights when they have been infringed. Minors are considered to lack the capacity to make informed decisions as they are not yet fully accustomed to the complexities of the real world. Therefore, it is essential to ensure that minors are provided with adequate protection until they reach the age of majority. By adhering to these strict rules, we can create a consistent legal system that protects everyone’s interests, including minors who may be vulnerable in contractual relationships.

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Endnotes:

1. The Majority Act, 1875, Act No. 9 of 1875
2. The Indian Contract Act, 1872, Act No. 9 of 1875
3. Mahori Bibi v/s Dharmodas Ghose, UKPC 12, (1903) LR 30 IA 114 (India).
4. General American Insurance Co v/s Madanlal Sonulal, (1935) 37 BOMLR 461, 158 Ind Cas 554 (India).
5. Vaikuntarama Pillai v. Athimoolom Chettiar, (1914) 26 MLJ 612 (India).

This article is authored by Sohini Chakraborty, a first-year law student at RGNUL Patiala.

S.no	Contents
1.	FACTS AND PROCEDURAL HISTORY
2.	ISSUES RAISED
3.	LAWS RELATED
4.	ANALYSIS
5.	CONCLUSION

CITATION

1984 AIR 469

DATE

6/02/1984.

FACTS AND PROCEDURAL HISTORY

Background of the case

Laxmi Kant Pandey, an advocate practising in the Supreme Court of India, wrote a letter in the form of a complaint regarding various welfare agencies and social organisations indulging in various malpractices through the adoption of Indian children by foreign parents. It was found out that the letter was based on a detailed investigation report carried out by a reputed foreign magazine called “The Mail.” It was alleged that when foreign parents adopt Indian children, they are prone to long, tedious journeys and are ill-treated by placing them in shelter homes. Moreover, they are prone to be treated as beggars and prostitutes and other sexual harassment and exploitations. This letter came to be recognized as a writ petition on 1st September 1982. A notice was issued by the Supreme Court to the Indian Council of Social Welfare, Indian Council of Child Welfare, and the Government of India to assist the court in answering the writ petition by stating the principles and rules to decide the matter of adoption by foreign parents as well as to lay down the guidelines to ensure the maximum safety and welfare of the child while being adopted to foreign countries by foreign parents.

Written Submissions and Later Developments

On 30th September 1982, the first set of reports and written arguments based on the court’s notice was submitted by the Indian Council of Social Welfare. Various essential suggestions and recommendations were laid down in the report, which the court must take care of while setting out the guidelines and rules for approving the adoption law. Many organizations like Barnes Framfoer Allt Adoption (Swedish organization), S.O.S Children’s villages of India, etc., and social welfare communities voluntarily expressed their desire to submit their reports and arguments to help the court and participate in the court’s hearing. 

The writ petition was further adjourned to 9th November 1982 as the court issued an order allowing these organizations to submit their arguments. As Indian Council for Child Welfare and Indian Council for Social Welfare were already engaged in offering the adoption of Indian children abroad, the Supreme Court directed the Union of India to gather the submissions and required information from every other organization except these two. 

Union of India, Indian Council for Child Welfare, and Indian Council for Social Welfare were also asked to provide the court with the names of foreign agencies that are engaged in aiding foreign parents to find Indian children. 

By 9th November 1982, the Supreme Court recognised eight specified institutions and permitted them to submit of the affidavit before 27th November 1982. The State of West Bengal was asked to submit its affidavit by the Supreme Court before 9th November 1982. Also, a quarterly report regarding the orders made in the last five years in the Guardians and Wards act, 1890, entrusting the custody of Indian children to foreign parents, was asked to be submitted by the court to the Superintendent of Tees Hazari courts. The final hearing of the writ petition was adjourned to 1st December 1982. The first judgment was passed in the year 1984 followed by a supplement judgment dated 27^th September 1985 stating the norms and guidelines for inter-country adoptions.

ISSUES RAISED

1. Whether the Honourable Supreme Court should accept the writ petition or reject it in the name of no substantial law being involved considering the severity of the issue raised.
2. Whether the Honourable Supreme Court should provide more laws for better clarity after affirming the fact that the laws existing with respect to inter-country adoption are not sufficient.

LAWS RELATED

Guardians And Wards Act

Certain rights and duties of the guardian are covered under the Guardians and Wards Act of 1890. 

Section 7 gives the court the authority to issue a guardianship order. According to this clause, the court may appoint guardians for the benefit of minors.  A guardian will be able to look after the minor and their belongings. The court may terminate any guardian. The court can also remove the guardian who is chosen by the court

Section 8 of this act discusses the child’s welfare and states that the child’s welfare should be the primary motive for adoption. The procedures and norms to be followed in the matter of adoption to safeguard the children’s rights were stated in this act.

Section 9 of the Guardians and Guardians Act 1890 gives the court jurisdiction to consider the application. If the application concerns the guardianship of a minor, the court in which the minor’s guardian resides enjoys jurisdiction.

If the application involves the property of a minor, the district court may have jurisdiction either where the minor lives or where the property is located.

Section 11 outlines the application qualification process. This provision states that the court will set a preliminary hearing once it is convinced of the basis for the proceedings. The notification was sent as the C.P.C. (Civil Procedure Code 1908) authorized.

Section 17 lists factors to take into account when choosing a guardian.  The court will decide based on the minor’s interests, development, and overall case conditions. In accordance with section 17 (5) of the statute mentions that the court cannot appoint a guardian contrarily or oppose the minor’s wishes.

Section 26 concerns excluding the minor from its ambit. If the child disappears from or is separated from the possession of guardians whom the court appoints, then the court will issue an order for the return of the ward to the guardians.

Article 14

Article 14 of the Indian constitution discussed equality before the law and equal protection of the law. Clause (3) of Article 15 is an exception and states that special provisions can be made for children and women. Article 15 was brought to light in this case.

Article 24

Article 24 abolishes child labour and states that children under 14 should not be made to work in hazardous industries, mines, or factories. This article discussed the importance of child welfare and safeguarding them from being exploited in this case.

Article 39

Article 39(e) and (f) mention that the state is required to guide its policies towards ensuring that young children are not molested and that they are not coerced into careers that are out of character for the children’s age, ability, and capacity to grow in a positive way out of financial necessity.

CARA- Central Adoption Resource Authority 

It is a legislative body with the authority to oversee and control both domestic and international adoptions of Indian children. It serves as the coordinating body for such adoptions. With its affiliated, reputable adoption agencies, CARA deals with the adoption of orphan, abandoned, and surrendered children. The parents who want to adopt a kid must be authorised by a social organisation or child welfare organisation approved by the nation’s government where the international pair lives. It is a legislative body with the authority to oversee and control domestic and international adoptions of Indian children. It serves as the coordinating body for such adoptions. With its affiliated, reputable adoption agencies, CARA deals with adopting orphan, abandoned, and surrendered children. The parents who want to adopt a kid must be authorized by a social organization or child welfare organization approved by the nation’s government where the international pair lives.

ANALYSIS

The adoption of children is a concept that has existed in Indian culture since time immemorial. The importance placed on having a “firstborn son” in Hinduism resulted in the notion of adopted sons to conduct family rituals and rites. The established prevalence of adoption in India has ensued in drafting laws, such as the Hindu Adoption and Maintenance Act 1956[1], to ensure that the adoption process is overseen by agencies entrusted with regulating it. However, the pre-existing adoption laws failed to foresee inter-country adoption’s emergence.

Inter-country adoption is a way of adoption that developed due to the improved connectivity of countries with the advent of technology and better transportation methods. It allowed foreign parents to adopt underprivileged children from other countries, usually from countries with lower economic statuses, to provide them with a better life and opportunities. The United Nations validated it in the Draft Guidelines of Procedures Concerning Inter-Country Adoption in 1981. It was seen as a method to ensure that the underprivileged children would receive a congenial environment to grow up in, as they would with their biological parents. Though the thought behind the idea was noble, the lack of regulations made it susceptible to human trafficking, wherein the system in place would be misused. Thus, many children who underwent the process of inter-country adoption would end up getting trafficked and subjected to inhumane living conditions, a stark contrast to the life they were promised. 

The case of Laxmi Kant Pandey vs Union of India[2], which shed light on the severe lack of regulations surrounding inter-country adoption and the need for a legal framework to protect the rights of the adopted children, saw the judiciary take part in judicial activism to ensure that the process of inter-country adoption from India would be as shielded from malicious activities as possible. This was done by ensuring that every step of adoption from India would be precise and regulated.

In the judgment for Laxmi Kant Pandey vs Union of India, the Supreme Court laid out guidelines for inter-country adoption. It thus ushered in a new era concerning adoption in India, wherein the government had till then not taken much cognisance of the lack of guidelines regarding inter-country adoption. The judgment, which was delivered by a three-judge bench headed by Justice P.N Bhagwati, recognised the lack of safeguards with respect to inter-country adoption and chose to formulate a detailed set of guidelines to ensure that the adoption of children from India by foreign guardians would only occur under exceptional circumstances, and only if it was deemed that the children were adopted in a hospitable environment, similar to what they would ideally receive from their biological parents.

The bench made one explicitly clear: adopting the child would put the child’s welfare first and foremost. This was in conjunction with the United Nations Declaration of the Rights of the Child[3], where a child’s right to be loved and grow up in an environment where they can receive the affection they deserve was recognised. The judgment stated that the primary focus of the adoption agencies should be to ensure that the child could be reunited with its biological parents, as the care provided by the child’s biological parents would be the ideal environment for the child to grow up in. To ensure this, the adoption agencies should take the necessary steps to track the biological parents and attempt to reunite the child with them. If needed, social service agencies can facilitate these families in reuniting as, in many instances, the children may be given up by their parents due to financial difficulties or mental incapacity to take care of the child. Only if all attempts by the social service agencies fail after 3 months can the adoption agencies move to the next step: aiding the adoption process of the child domestically

The court noted that, as the welfare of the children is what is essential, the next best step other than reuniting the children with their biological parents would be to find adoptive parents for the child in India, as they would thus grow up in the same environment that they are familiar with and would not have to deal with the stress of adapting to a new country’s culture and norms at their tender age. Securing adoptive parents from the native country would be done for two months. At that point, if the child has not been adopted domestically, the adoption agencies will allow applications for inter-country adoption.

As there is no statutory enactment in India providing for the adoption of a child by foreign parents or laying down the procedures to be followed in such cases, the court has instructed that the provisions of the Guardian and Wards Act 1890[4] should be used to facilitate such adoption. This act provides for the appointment of a guardian by a court for the care of a minor or a person of unsound mind.

In the guidelines issued for foreign adoption in the country, the apex court stated that all applications from foreigners seeking to adopt a child must be sponsored by a social or child welfare agency recognised or licensed by the government of the country in which the foreigner resides. It is important to note that social welfare agencies in India working in inter-country adoption or institutions where the juvenile court commits children should not entertain applications directly from foreigners. The bench also emphasised the child’s age’s importance in inter-country adoption cases. The court has stated that a child should be adopted before the age of three in such cases, allowing the child to assimilate more easily into the new environment and culture.

The process for foreign adoption of Indian children involves applying to the court for appointment as guardian, with notice sent to a child welfare agency. The agency must be licensed and maintain a register of children proposed for adoption. The court must be satisfied that the child is legally available for adoption, and the application must be sponsored by a recognised agency in the foreigner’s country of residence. 

The judgment in Laxmi Kant Pandey vs Union of India was instrumental in ensuring that inter-country adoption would not fall victim to malpractices like human trafficking and thus helped secure the rights of adopted children in India. Following the judgment, the Government of India instituted the Central Adoption Resource Agency (CARA). CARA serves as a centralised source of information for monitoring both domestic and international adoptions. 

This judgment also influenced the creation of the Juvenile Justice (Care and Protection) Act 1986, revised in 2000[5]. This new legislation considered the provisions of the United Nations Convention on the Rights of the Child[6] and other pertinent international treaties. The law adopted a child-centric approach, ensuring that children requiring care and protection receive appropriate care, protection, treatment, and rehabilitation.

Though no formal legislation was enacted to solely overlook the process of inter-country adoption in India, the precise nature of this judgment has ensured that the scope for malpractices with the process of inter-country adoption has decreased gradually and has thus made the process more secure and favourable for the adopted children and the foreign guardians. 

CONCLUSION

The case of Laxmi Kant Pandey v. Union of India was and will serve to be the landmark judgement not only for the statutes and amendments that the judgment brought in but also from a petition letter turning into a writ petition. The significance is that the modification of the judgement in 1987 clarified the guidelines. This case also became sensational, starting from one petitioner, i.e. a litigator of S.C., to six petitioners filing six applications. Also, how Indians and other executives came to know about the scam of illegal sale of babies under the cap of Inter-country adoption. This case is considered one of the substantial ones as it not only dealt with exploitation or trafficking that happens in adopting Indian Children by foreigners but also explained how the guidelines and provisions are to be followed. This was due to population restraint and various policies like the one-child policy by developed countries. So this increased the scope for various illegal and non-reputable adopting agencies that sell Indian children for reasonable sums, and the adopted child ended up as a beggar and prostitute. The case will serve and is serving a scrutinised adoption procedure to adopt Indian children, which will create fear in the minds of illegal or profit-making adoptive agencies. 

The case of Laxmi Kant Pandey vs Union of India brought in the most productive and safe guidelines and procedures like the three to five-tier adoptive process. Starting from whether the adoptive parents can care for the child to create a fixed deposit for the adopted child. The court also ensured that the child being adopted would be able to adapt to the surroundings and culture of the adoptive country and the people around. The other significant outcome of the judgment is how the maintenance of registers by the Social Welfare Department of India and the Embassy of the country the child is being adopted to keep an eye on the address and other details of the adopted kid from time to time ensure the safety kid. Then the modified judgment also solved and provided remedies for a quick adoption process yet a safer one as there was a delay in inter-country adoption. The big question is whether the judgment is efficacious on inter-country adoption. This case also served as an inevitable precedent that led to the introduction of the Central Adoption Resource Agency (CARA) and later following a few more judgments leading to the Juvenile Justice (Care and Protection of Children). Also, the statistics show that during the past four years, close to 2,134 Indian children have been adopted by parents from five countries.

This case is an excellent illustration of how procedure development in public interest litigation has eased standing limitations in India, leaving the judicial framework more accessible to disadvantaged members of society. It also serves as an illustration of the Indian Supreme Court’s judicial activism. The Supreme Court did not think twice about setting specific instructions to control adoptions and safeguard kids from prostitution and enslaved labour when faced with a legislative gap on a significant social concern. In totality, talking about inter-country adoption is like a double-edged sword with advantages and disadvantages On the one hand, international adoption may be a lifeline for kids who have been abandoned, orphaned, or abused. It may give kids’ devoted families access to higher education and superior medical care. It can also allow escaping poverty, prejudice, and other harsh conditions.

Conversely, international adoption may be troublesome if not conducted ethically and openly. The global adoption system has seen child trafficking, corruption, and abuse. Additionally, some critics contend that international adoption may contribute to exploiting marginalised people and perpetuating system imbalances.

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Endnotes

1. The Hindu Adoptions And Maintenance Act, 1956, No. 78, Act of Parliament, 1956 (India).
2. Laxmi Kant Pandey v. Union of India, 1987 AIR 232.
3. UN General Assembly, Declaration of the Rights of the Child, 20 November 1959, A/RES/1386(XIV).
4. The Guardians And Wards Act, 1890, Act No. 8 Of 1890.
5. The Juvenile Justice (Care and Protection of Children) Act, 2000, No. 56, Act of Parliament, 2000 (India).
6. UN General Assembly, Convention on the Rights of the Child, 20 November 1989, United Nations, Treaty
   Series, vol. 1577, p. 3.
7. http://lexpeeps.in/child-abuse-and-the-laws-to-prevent-it/

This case analysis is done by Vishal Menon, from Symbiosis Law School, Hyderabad.