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Cyber Stalking: Challenges In Regulating Cyberstalking At The Cyber Space

This modern world is mostly engaged in the information technology with internet and mobile phones. Information technology has become widened and has become the axis of today's global and technology development. The world of internet provides all the required information to every user. With the numerous advancement of internet, the crime using internet has also widened its roots in all directions. The cyber-crimes pose a great threat to individuals. Though there are various types of Cyber crimes, cyber stalking is theMagna Cartato all such cyber crimes. The word"stalking"means"pursuing stealthily". It is the use of the Internet or other electronic means to stalk or harass a person. The utilization of technology allows stalkers to harass their target from any part of the world. In this paper we try to explore the Cyber-crimes and the online insecurity and vulnerabilities against women in the way of cyber stalking. While Cyber Stalking affects both men and women women are disproportionately targets, especially of age group of 16-35. The paper attempts to discuss the modes of cybercrimes, categories of cyber stalkers, psychology of cyber stalkers, motives of cyber stalkers and the nature victims.

This 21stcentury fulfilled by the information technology and the usage of the modern technologies is increased. Information technology widened its usage throughout the world and it's become the axis of today's global and technology development. With the numerous usage of the internet, the crimes also increased. Today most of the crimes are the cyber crimes. The crimes are mostly happened against women. 90% cyber crime victims are the women.

Cyber stalking in one of the most important cyber crime. Stalking is mostly happened against the women. Cyber stalking is nothing but online harassment or threatening the victim for sexual purposes or misuse them. Why it is happened against the women? Why they are victimized? Whether they don't have any right or liberty? Then what about the constitutional rights?
In this paper we are discussing about the cyber stalking and how it is affect the victims life and what are the measures taken by the government to regulate the cyber stalking. We are discussed about the violations of women right in the cyber space. First part of the paper is discussing about the cyber stalking and why it is happened and how it is happening. The second part will leads the recent cases and some important cases of cyber stalking and it elaborately speaks about how women are victimized and how their rights are violated. The third part discuss about what are the measures taken by the government and legal recognition of cyber stalking and the suggestions also included.

What Is Cyber Stalking?
There is no universal accepted definition of cyber stalking. The word stalking means ‘pursue stealthily' which refers that "harass obviously".

Some scholars are defined what is cyber stalking:

Bocij, Griffiths and McFarlane (2002: 5)-cyber stalking as "a group of behaviour in which an individual, group of individuals or organization, uses information and communications technology to harass one or more individuals. Such behaviour may include, but are not limited to, the transmission of threats and false accusations, identity theft, data theft, damage to data or equipment, computer monitoring, the solicitation of minors for sexual purposes and confrontation". According to Baer, "Cyber stalking in particular is composed of words alone and therefore stands more distinctly as apart as a crime of accumulation" (Baer, 2010:154).Brennerdefines as "in a sense, cyber stalking and cyber harassment are lineal descendants of the obscene or annoying telephone call offenses that were created roughly a century ago, to address harms resulting from the misuse of a nineteenth century technology" (Brenner, 2004: 14).Ellisonand Akdeniz(1998) had construed the term cyber stalking as online harassment, which may include various digitally harassing behaviors, including sending junk mails, computer viruses, impersonating the victim, etc.

It may be noted that legally cyber stalking recognized as an offence in early 1990's. Stalking was criminalized by Michigan in 1993 through Michigan criminal code.[2]
Cyber stalking refers computer oriented harassment. The term interchangeably used as online harassment or online abuse. A perpetrator or cyber stalker does not give direct physical threat to the victim but giving online threat or giving verbal intimidation. It is a continuous function in the cyber space.

Cyber stalking vs. offline stalking
# Cyber stalking is online threat and there is no direct relationship between the victim and cyber stalker. offline stalking is direct physical threat to the victim and there is some relationship between the victim and the stalker.
# Cyber stalking is universal. If a Russian or a Canadian can stalk a Indian women or men. offline stalking is particular.
# No prior clear identidy about the cyber stalker. Clear identification about the offline stalker.
# Direct physical threat in offline stalking. Cyber stalking is posting a nude or semi nude photo in the internet and using obscene language and verbal intimidation.
# Enforcement of law is easier in offline stalking. Cyber stalking sometimes requires extradition.[3]

But now a day's cyber stalking crimes is more than offline stalking. Because finding of the perpetrator is not easier. America is the first country mostly affected by the stalkers. 2,00,000 people are real stalkers in America, roughly 1 in 1250 persons.[4]90% of the victims are women and 95% of stalkers are men. Mostly the teenagers are victimized.

Age group Percentage
20 or under 23.40
21-30 14.40
31-40 22.80
41-50 26.90
51-60 9.00
61-70 1.80
71-80 1.20
81-90 0.60

Kinds of Cyber Stalking:
There are three kinds of cyber stalking.
·E-mail stalking
·Internet stalking
·Computer stalking

E-mail stalking:
E-mail stalkingis one of the most common forms of stalking in the physical world involve telephoning, sending mail, and actual surveillance, cyber stalking which can take many forms .Unsolicited e-mail is one of the most common forms of harassment, including hate, obscene, or threatening mail. Other forms of harassment include sending the victim viruses or high volume of electronic junk mail. It is important to note here that sending viruses or telemarketing solicitations alone do not constitute stalking. However, if these communications are repetitively sent in a manner which is designed to intimidate (that is, similar to the manner in which stalkers in the physical world send subscriptions to pornographic magazines), then they may constitute concerning behaviors which can be categorized as stalking.

Internet Stalking:
Here in this case stalkers can comprehensively use the Internet in order to slander and endanger their victims. In such cases, the cyber stalking takes on a public, rather than a private dimension. What is particularly disturbing about this form of cyber stalking is that it appears to be the most likely to spill over into physical space. Generally, cyber stalking is accompanied by traditional stalking behaviors such as threatening phone calls, vandalism of property, threatening mail, and physical attacks. There are important differences between the situation of someone who is regularly within shooting range of her/his stalker and someone who is being stalked from two thousand miles away. While emotional distress is acknowledged in most criminal sanctions, it is not considered as serious as actual physical threat. Thus, the links between stalking, domestic violence, and feticide have been empirically demonstrated in real life, much cyber stalking remains at the level of inducing emotional distress, fear, and apprehension. However, this is not to say that causing apprehension and fear should not be Criminally sanctioned.

Computer Stalking:
The third mode of cyber stalking is computer stalking which exploits the Workings of the Internet and the Windows operating system in order to assume control over the Computer of the targeted victim. It is probably not widely recognized that an individual Windows based computer connected to the Internet can be identified and connected to another computer through to the Internet. This connection is not the link via a third party characterizing typical Internet interactions, rather it is a computer-to-computer connection allowing the Inter lopper to exercise control over the computer of the target. A cyber stalker mostly communicates directly with their target as soon as the target computer connects in any way to the Internet. The stalker can assume control of the victim's computer and the only defensive option for the victim is to disconnect and relinquish their current Internet address. The situation is like discovering that anytime you pick up the phone, a stalker is on-line and in control of your phone. The only way to avoid the stalker is to disconnect the phone completely, and then reconnect with an entirely new number. Only one specific example of this technique was used in stalking for instance, a woman received a message stating "I am going to get you", the interloper then opened the women's CD-Rom drive in order to prove he had control of her computer. More recent versions of this technology claim to enable real-time key stroke logging and view the computer desktop in real time. It is not difficult to hypothesize that such mechanisms would appear as highly desirable tools of control and surveillance for those engaging in cyber stalking.

Reasons Behind Cyber Stalking
1) Harassment:

The main intention of the stalker is to harass. The women sexually harassed by the stalker at many times. The stalker has or created a photo of the victim and he threaten the victim to have sex with him otherwise he will upload the photo or video. The stalker has some affection to victim, if she denied that then he will do against the victim. The thing is the stalker has intention that' if she not mine of himself, she will not mine of anyone. 'Then the stalker doing all those things.

In U.S.A the stalker neighbor of the victim, has semi nude photo of the victim aged 16 and the perpetrator threaten the victim to have sex with him otherwise he will posted it into the public media. This way he harassed her for 1 year, afterwards it was founded by her parents and they informed it to the police. The stalker gets that photo from the facebook and he morphed it as a semi nude photo of the victim.

2) Fascination
This is a one side love or online romance. The stalker has love of affection towards the victim and if she refuses to accept his proposal then he will become the stalker. The rejected could not accept the end of relationship with her. This kind of stalkers some time being a abnormal persons. Sometimes the victim may be killed by the accused. In Tamil nadu 2012, the college girl affected by the acid attack, done by her one side lover. This is not kind of stalking but sometimes this kind of persons turned into the stalkers[5].

3) Revenge
This is kind of revenge against the victim. If the victim was refused his proposal then he made revenge against the victim. In Germany the victim refused to accept the stalker's proposal. Then he upload her photo into the social media and written above that ‘if anybody want's to sex with me contact me' and he wrote her address and phone number. The victim does not have knowledge about this and many persons are contacted her and some knocked her door in the midnight and sexually harassed her.

4) Boasting Or Showoff
This is kind of showing his talent how he harass a girl. This is happened in the friends circle. The stalker challenged to his friends about he will easily make her cry and sometimes it turns into aggravated form. This is kind of show off his talent in front of his friends.

Behaviour Percentage
Sent you threatening or abusive e-mail messages 39.88
Made threats or abusive comments via Instant Messenging software, such as MSN 38.69
Made threats or abusive comments in chat rooms 47.62
Posted false information (e.g. rumours) about you to a bulletin board or chat room 24.40
Impersonated you in e-mail messages to your friends, family or work colleagues 8.93
Encouraged other users to harass, threaten or insult you e.g. other members of a chat room 23.81
Ordered goods or services in your name, possibly charging items to your credit cards 2.98
Attempted to damage your computer system by sending malicious programs to you, such as a computer virus 40.48
Attempted to monitor your actions by inserting Trojan horse software (e.g. key logging programs) on your computer system 26.79
Attempted to access confidential information stored on your computer, such as credit card numbers, e-mail messages, etc. 17.26
Any other behaviour you found distressing in any way 27.98

Types of Stalkers[6]
A. Simple Obsessional.
In this type the victim and the perpetrator has prior relationship. The main intention of the perpetrator is to coerce or to re-enter into the relationship. Most of the stalkers who belongs to this type. 47% of the stalkers are in this category.

B. Love Obsessional
In this type the perpetrator has great affection or love towards the victim and mostly they one side lovers. The perpetrator was never accept that he was denied by his lover. Mostly the perpetrator suffering from a mental disorder such as schizophrenia or bipolar disorder. 43% of perpetrator belongs to this category.

C. Erotomanic
In this kind the stalker possess the delusion that the victim's behavior is has love with him. Then he was falling with her and then it is become known to him the same then he become a stalker.

Methods of Cyber Stalking
# The stalker collecting all the information about the victim through watching her activity and following her online activities.
# The stalker has series of collection about the victim and he threaten the victim for his personal use.
# Then he posting it into the internet and invite them to have sexual treatment with the victim.
# People of all kind from nook and corner of the world start calling the victim and compel her and sexually harass the victim
# Subscribe the e-mail of the victim into the pornographic and sex sites.[7]

Cases And Position of Women In The Cyber Space:
I) Manish Kathuria Case

The first reported case of cyber-stalking in India and the reason for the 2008 amendment to the IT Act,[8]the Manish Kathuria case involved the stalking of a woman named Ritu Kohli. Kathuria followed Kohli on a chat website, abused her by using obscene language and then disseminated her telephone number to various people. Later, he began using Kohli‟s identity to chat on the website "". As a result she started receiving almost forty obscene telephone calls at odd hours of the night over three consecutive days. This situation forced her to report the matter to the Delhi Police. As soon as the complaint was made, Delhi Police traced the IP addresses and arrested Kathuria under Section 509 of the Indian Penal Code. The IT Act was not invoked in the case, since it had not come into force at the time when the complaint was filed. While there is no record of any subsequent proceeding, this case made Indian legislators wake up to the need for a legislation to address cyber-stalking. Even then, it was only in 2008 that Section 66-A was introduced. As a result, now cases are being reported under this section as opposed to Section 509 of the Indian Penal Code, as was the case where a Delhi University student was arrested for stalking a woman from Goa by creating fake profiles on social networking websites, uploading pictures on them and declared her to be his wife. It is hoped that the decision in this would favour the victim.

ii) Karan Girotra V. State
The only reported case till date to reach the judiciary on cyber-stalking is also merely an application to grant anticipatory bail. this case dealt with a woman, Shivani Saxena, whose marriage could not be consummated; as a result she filed for divorce by mutual consent. In the midst, she came across Karan Girotra while chatting on the internet, who told her he loved her and wanted to marry her. On the pretext of introducing her to his family, Girotra invited Saxena over to his house, drugged her and assaulted her sexually. He continued to assure her that he would marry her and began sending her obscene pictures from the night she was assaulted. He also threatened to circulate the pictures if she did not marry him. As a result, an engagement ceremony was performed between the two after which he continued to assault her and eventually called off her engagement to her. As a result, Saxena filed a complaint under Section 66-A of the IT Act.

Though the Court rejected the plea of anticipatory bail on the ground that nude and obscene pictures of Saxena were circulated by Girotra, an act which requires serious custodial interrogation, nonetheless it made some scathing remarks. According to the Court Saxena had failed to disclose her previous marriage to Girotra merely because she agreed to perform the engagement ceremony, even though such mention was made when Girotra had first professed his love to Saxena. The Court also took noted that there was a delay in lodging the FIR by Saxena. What is more shocking is that the Court held that Saxena had consented to the sexual intercourse and had decided to file the complaint only when Girotra refused to marry her.

This case highlights the attitude of the Indian judiciary towards cases involving cyber-stalking. It is appalling that factors as redundant as a delay in filing the FIR have a huge bearing on the outcome of the case. It is for this reason that more stringent legislations are the need of the hour.

iii) Vinu Priya Case
This is very recent case. In this case the victim was a 21 years old, who finished her B,sc chemistry. On June 23, when the first photograph appeared, she informed her parents who lodged a complaint with the Cyber Crime Cell. The police, either lacking the investigative skills to trace the origin of the morphed photograph or simply displaying lack of interest, told Vinupriya's father that it will nab the culprit in two weeks. Two weeks? Seriously? Do those cops in Tamil Nadu's Cyber Crime Cell understand the trauma Vinupriya and her family would have gone through? That is not all. One of the officers in the Cyber Crime Cell allegedly asked for a mobile phone if the father wanted the investigation to be done. Vinupriya's father says he bought a cell phone worth Rs 2,000 for the cop and bemoans that despite taking a bribe, the officer did not deliver justice. On June 26, another obscene photograph was posted on Facebook, leaving Vinupriya traumatized. The investigating officer had already assumed that she must have sent those pictures to someone and now they were being posted, perhaps by a jilted lover. The line of questioning to Vinupriya was on those lines. When she was alone at home on June 27, she killed herself[9].

The second photograph that had appeared on June 26, disappeared within hours of news of Vinupriya's death becoming public. Proof, that the pervert was lurking somewhere close by or was part of Vinupriya's friend circle.

iv) President Pranab mukharjee's daughter stalking case
Sharmistha Mukherjee, daughter of President Pranab Mukherjee, was allegedly harassed by a man, who posted sexually explicit messages on her Facebook page.[10]She lodged a complaint with the Cyber Crime unit of Delhi Police. Police said the "lewd" messages were sent to the complainant through Facebook Messenger. The profile of the sender mentions him as a resident of Nauhati in Hooghly, West Bengal. Mukherjee shared screenshots of the messages sent to her and said she decided to speak up against online harassment as ignoring it would only encourage him further. She also tagged the man who has now deleted his profile from Facebook.

"This pervert Partha Mandal is sending me dirty sexual messages. My 1st reaction was to ignore and block him. But then I thought the silence would encourage him to find other victims. Just blocking and reporting is not enough. I strongly feel such ppl shd be publicly exposed and humiliated. I'm posting screenshots of his profile and messages he sent me. I'm also tagging him. Please share this post and tag this rat as a message that these pervert acts will not be taken lightly," she wrote.[11]

v) Cassidy stalking case
Cassidy was a miss teen U.S.A, was stalked over a year. She was stalked by Jared james Abrahams, who he was higher secondary friend of Cassidy. He input a malware into the cassidy's laptop through he collected lot of information about Cassidy and he upload a semi nude photo of Cassidy in the social media and then it was informed into the FBI and they found the culprit.

Other Cases
·Amanda Todd was a bright and bubbly13-year-old from Canada. During an Internet chat session, a stranger asked her to bare her breasts. In a fleeting moment, she complied. Amanda had no idea he'd recorded it. The stranger contacted her again, and threatened to release the file unless she posed nude forhim.She refused, and the photograph was released to her peers. After being subjected to relentless bullying as a result, Amanda committed suicide.

·A 12-year-old Washington girl was sentenced on Wednesday to probation and community service for a cyberstalking incident in which she and another 11-year-old girl doctored a classmate's Facebook account with explicit photos and solicitations for sex.

But the mother of the victim, also 12, said she has "mixed feelings" about the sentencing of the girls who hacked her daughter's Facebook page, and she isn't satisfied with the judge's ruling.

·The case dealt with the posting of sexually explicit material by Abraham Jacob Alkhabaz, a student of the University of Michigan under the pseudonym "Jake Baker". Baker posted stories on an internet newsgroup titled "alt. sex. stories" describing the torture, rape and murder of a woman who had the same name as one of Baker‟s classmates at the University of Michigan. In addition, e-mails were exchanged between Baker and a man named Arthur Gonda from Ontario, Canada, who was a reader of his story. Over forty e-mails were exchanged between the two men discussing their desire to abduct and physically injure women of their area. As a result, a complaint was filed against Baker under the Interstate Communications Act.[12]

Constitutional Validity
With the brief analyzing of these cases the thing is being a women is very dangerous in this society. Why it is so happened against the women mostly. why the women are victimized at every time? The world has to answer for these questions! Even the males also using the internet, online and etc.. But they are not victimized as like females. This is happened against all kind of females such as poor, rich, familiar, children and etcetera. Where there is no right for the female or where there is no protection for female. Whether the modesty of women is safeguarded by the law and order?

The provisions are saying to protect the women and safeguard her modesty but in reality there is no protection for women and violation of her modesty is easily happened at all. All kind of females are affected then what is the use of constitutional provisions such as right to life, equality clauses, freedom of speech and expression. The rights are given but the enforcement of these rights are not happened.

In Vinupriya case the girl was stalked by unknown person, who was a one side lover, even though there is no protection for women, if the rights are protected the suicide of Vinupriya was not happened. She proved she is innocent through her death, when she is committed suicide there after only the police department took a immediate action because this case was familiar. Even though the complaint was given 2 weeks before her death. But there is no action taken by the police department. If they founded the culprit there is no suicide of Vinupriya. Even her parents also does not believed her.

The injustices happened in all the forms against women. Constitution of india,1950 declares' both the men and women are same' whether there is equality prevails in all the situation. Both men and women has right to access internet. The right is enforced but what about the protection? If they are came into social media they are stalked. Then what is the fulfillment of these rights? There is no protection for women at all.

If women are protected means the nirbhaya case[13]was not happened. Even many cases happened before nirbhaya case but the Indian government recently inserted a provision in Indian penal code,1860[14]about stalking is an offence .if serious crimes are happened then only the laws are created. Every law has some murders of women behind that.

Right To Privacy Vs. Freedom of Speech And Expression
Every person has both the rights. If the stalker were arrested, whether is freedom of speech and expression was violated? If he doing like this then how can women exercise her right to privacy? Article 19(2) gave some restrictions to the exercise of freedom of speech and expression. It gives that he exercises his freedom not to violative of any other rights of others.

Right to privacy was very important right for the individual. Any person can personally do some acts not to violate anyone. A women has right to access internet and if any person has right to expose her body without her consent. But this happened usually.In cassidy's casethe defendant arguing that this is his freedom, he can watch anybody and make a sense of it. No one cannot pick up his right. The judge not accepted his argument because this is very silly defence what means of right to privacy, whether his freedom is to expose another's body or any other personal things.

Right to privacy is very important for women. She has a right to life, right to life includes right to dignity. No one cannot violate her modesty i.e., right to dignity.[15]

The provisions alone saying every person has rights. But the enforcement of these rights in not accessible. The documents and provisions are saying, people are writing page and page about women rights but whether exercising of their rights is happening. Whether the enforcement of these rights are happening or not, but the violation of these rights are happening usually. Even after the period till now the position of the women was very critical. The forms of crime are changing but the protection of the women is unchanged.

Legal Recognition And Challenges In Regulating Cyber Stalking:-
Legal Recognition:

# California is the first country adopted the stalking law as a result of murder of actress Rebecca schaeffer by Robert bardo in 1989.
# The stalking law was enforced in 1990
# New York enacted penal laws, it says that stalking is an offence.
# Australia adopted stalking statute in 1993.

Position In U.S.A:
U.S.A is mostly affected country by cyber stalking. U.S.A adopted various laws at the center and state level.
# The first Act is Interstate communication Act.[16]
# Another federal legislation is telephone harassment statute[17]
# Interstate Stalking Punishment and Prevention Act.[18]
# Michigan was the first state to include online communications in its stalking laws in 1993.
# And many other states were adopted the stalking statute.

Position In U.K:
The UK does not have a specific legislation to deal with cyber-stalking. There are three legislations that seek to criminalize such behaviour. The first of these legislations is the Telecommunications Act, 1984. Under this Act, it is an offence to send a message that is "grossly offensive or of an indecent, obscene or menacing character" or a message with the purpose of "causing annoyance, inconvenience or needless anxiety" and knows that the message is false, by means of a telecommunications system.[19]

The second legislation on the point is the Protection from Harassment Act, 1997, which makes the offence of criminal harassment and the offence involving fear of violence subject to civil and criminal measures.[20]
The third legislation on the point is the Malicious Communications Act, 1988. By the Criminal Justice and Police Act, 2001, this legislation was amended to include electronic communications as well.[21]

Position in India:
India also lacks a specific legislation on cyber-stalking. The general legislation on the point is the Indian Penal Code which makes the use of "words, sounds or gestures or exhibition of an object" with the intent to insult the modesty of a woman or even the intrusion of a woman's privacy an offence punishable with imprisonment for one year or with a fine.[22]

This deficiency was sought to be rectified by the enactment of the Information Technology Act, 2000. The IT Act was enacted with the purpose of recognizing electronic commerce in furtherance of the United Nations Model Law on Electronic Commerce. Therefore, the first problem with the Act lies in the Preamble itself where the statute adopts a more commercial outlook and does not even attempt to recognize in the Preamble, the intention of the statute to regulate non-commercial criminal behaviour perpetrated through an electronic mode.

Nonetheless, the provisions of the IT Act do attempt to penalize acts of cyber-stalking. Prior to the 2008 amendment, the first section that dealt with the issue is Section 67 which makes the publication of any material that is "lascivious or appeals to the prurient interest or if its effect is such as to tend to deprave and corrupt persons" punishable with imprisonment up to five years and fine up to one lakh rupees which may increase to ten years and fine of two lakh rupees if the offender is convicted for the second time. The second provision on cyber-stalking is Section 72, which penalizes the disclosure of information obtained from "electronic record, book, register, correspondence, information, document or other material" without the consent of the concerned person with imprisonment up to two years and a fine up to one lakh rupees. The generality of these provisions cannot be over-emphasized and it is quite evident that a number of issues such as the use of innocent third-persons of the sending of innocent e-mails which may nonetheless amount to harassment remain unaddressed by these provisions

In 2013 the Indian penal code was amended on the impact of nirbhaya rape case. Sections 354A, 354B, 354C, 354D was inserted on the recommendation of justice j.s varma committee.
Section 354D deals with stalking of a women. This Is very limited because there is no provision for stalking of a men. And there is no law for if stalker is foreigner. The Indian penal cade,1860 is extra-territorial but there is no effective extradition laws.

The enforcement of these laws are still a question mark. Many cases was filled under information technology act before this amendment.

# There is no effective law of cyber stalking.
# We don't have a separate stalking law like U.S.A
# Section 354D is limited, because there is no specific provisions for if a male stalked.
# The extradition law of India is too weak. There is no effective extradition.
# The stalkers are using modern technologies but the cyber crime technology is weaker then the stalkers.
# There is no immediate action from the police department, if it is happened the suicide of Vinupriya is not happened.
# If The poor girls are filling a case against the stalkers, the action of the police is question mark because of bribery.
# If the stalker is political party's son or a billionaire there is no immediate action from the police.
# The enforcement of stalking law is still too weak.
# The information technology Act,2000 has no specific provision for cyber stalking.
# The loop holes of the law accuted the stalker easily.
# There is no fear of punishment from the stalker's side.

·The government has to take a prior step to the effective enforcement of the stalking law.
·Separate stalking law must be enacted.
·People have to protect themselves first.
·Women have not to do disclose her personal to anyone.
·Giving fake name, address, phone number is remedial measures to avoid these inconveniences.
·Respect with one another is very important, because if you respect a woman u will never do a crime against the women.
·The state should enforce law and order effectively.

With a detailed analysis of these topic we have conclude that the men have the responsibility to protect the people, the change is within them only. They will give the full respect to the women. Then only the percentage of crime against women will reduce. As per the Tamil song lyrics' the thief have to change himself, then only the level of theft will reduce' the enforcement law was not give a full remedy. As like that the stalkers should have to change themselves.

Gandhiji said that" when the women walk freely at midnight without any fear then only it consider as freedom"but still it is not happened. So there is no complete freedom in the society for the women. Now a day's some persons are saying women are empowered, they are doing all the work as like men. But this is not true, because they are doing all the work but there is no safety for the women at all. So there is no empowerment. There is no freedom, liberty and etc.

When the women is freely walk in the society, freely doing all the works without any fear or any other disturbances then only it is amount to freedom.

Co-Authored by: B.Aravinth Raj & T.Kalaiyarasi

1.An introduction to cyber crime and cyber law by R.k. chaubey, second edition, kamala law house, Kolkata.
2.Commentary on Information technology Act,2000 by Apar gupta, second edition, lexis nexis.
3.Criminal law (incorporation of 2012 amendment) by P.S.A pillai, 12 th edition, lexis nexis.
8.Article on cyber crimes by Missouri law house.
9.The Hindu news paper, Tamil edition
10.Times of India news paper.

[1]III Year B.A.B.L.(Hons), School of Excellence in Law, The TN Dr. Ambedkar Law University.
[2]Michigancriminal code 1993 section 28.643(8)
[3]p. Bocij, cyber stalking: harassment in the internet age and how to protect your family 7 (2004
[4]California universitystatisticsabout stalking.
[5]Challenges in regulating cyber stalking(2013) by nirmal.k.vijayan
[6]Studies conducted by the Los angels police department's threat management unit.
[7] Cyber crime and cyber law by r.k. chaubay
[8]P.shah‘cyber stalking and legal enforcement of the laws in india' 2012
[9]The hindu news paper, tamil edition, dated on 01-07-2016
[10]Times of india
[11]She wrote on her twitter page.
[12]United states vs. jakes baker
[13]Delhi rape case,2012
[14]Criminal law amendment act,2013
[15]Article 21 of the constitution of india,1950
[16] 18 U.S.C s. 875 (c)
[17] 47 U.S.C S. 223
[18] 81 U.S.C s. 2261(A)
[19]Telecommunications Act, 1984, S.43
[20]Protection from Harassment Act, 1997, SS2(2),4(4).
[21]Malicious Communications Act, 1988, S.1; Criminal Justice and Police Act, 2001, S.43.
[22]Indian Penal Code, 1860, s.509.

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