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Questioning The Unpredictability; A Legal Insight Into Necrophilia

Introduction and the Societal View
The Indian legislature over time has been developing new laws from the basic evolution of cases. The need for an amendment in any law or a new law is only felt when one or the other cases comes up in the judicial system of India. Furthermore, there also have been instances that a law has been formulated in India from its similar implementation in other nations. One of such aspects is the cases concerning 'Necrophilia', on which there is a rapidly increasing need for the formulation of legal provisions.

By its very definition, Necrophilia refers to the act of a person committing sexual intercourse with a dead body or corpse. A Necrophiliac is a person who voluntarily indulges in such kind of activity wherein the act between the person and corpse is usually driven by the desire for erotic pleasures.

This term of Necrophilia derives its origin from its very breakdown of Necro, which means 'the dead or death', and philia which means 'love or attraction' in Greek. Clubbed together, the term Necrophilia in layman terms simply refers as act of love with the dead. A Necrophiliac indulges in such kinds of act with the knowledge of it, empowered with the voluntariness to do so.

In India, the act of Necrophilia isn't fortunate enough to get due recognition. Although there have been quite a few cases relating or connecting to the idea of Necrophilia, the Indian judicial system still doesn't have adequate legal measures or grounds based on which the act of Necrophilia could be defined properly. Due to this prospective loophole, wherein the state of Indian judiciary isn't expected to be much developed and advanced where it could voluntarily take the initiative to cover-up the loophole been created over the ages, if any person gets convicted of being a part of a Necrophiliac activity, there aren't adequate measures to counter it. Henceforth, in most of the cases, the accused gets a clean chit after just a few years of the incident.

When these types of incidents came forward to the Indian press and judicial systems, many psychologists and eminent personalities were of the view that the act of Necrophilia is mostly driven by the possibility of the insanity of mind, wherein any person having sanity of mind would never get into such acts. Thus, a person who is found to be indulged in a necrophiliac activity, or is expected to do so is considered to be facing a situation wherein he/she doesn't have accurate control over his/her senses and emotions.

They have the view of these factors to be taken into consideration and provide the accused or convict the opportunity to defend based on the insanity of mind. On the other hand, the new generation advisors or legal and press veterans who have experience with such kinds of acts have a view in contradiction to the longstanding approach.

They consider that the act of Necrophilia, wherein a person is accused or convicted of committing sexual intercourse with a dead body or corpse, is not empowered by the possibility of insanity of the mind. In many of the cases, such acts portray the wrongdoer's character of bestiality, rage, or graveness wherein the sexual act is done in the full sense and saneness of the mind, with a voluntary interest. Therefore, on the discovery of such acts being committed, the wrongdoers shouldn't be allowed to entail the prospective defence of insanity of mind and shall be punished with the adequate amount of punishment equivalent to the graveness of the offense.

Necrophilia doesn't only concern the tendency or the inclination of a person towards the commission of a sexual offense with the dead. One side of necrophiliac tendencies also indicates the romantic nature of the person wherein he/she portrays to be so possessive that they do not accept the fact that their loved ones are no longer existential in the present world and have departed towards the path of death.

In such cases where Necrophiliac people possess a romantic nature, they preserve the dead bodies of their loved ones and spend time with them[i]. They conduct several activities such as talking to the dead loved ones through which their belief that their loved ones are still among them remains preserved. These types of people are extremely sensitive, and hence are so fragile that they just cannot accept the fact that their loved ones are no longer a part of the living world.

Henceforth, even psychological experts recommend that the false belief of these people, that their loved ones are dead, should be preserved and no effort shall be made to enlighten them regarding the status of death of their loved ones. Psychologists say that due to the delicate nature of these types of people, any information conveyed to them regarding the status of death of their loved ones could result in serious mental traumatization and nervous breakdown, thereby possibly leading to a situation of depression and unexpected death through various suicidal means.

Therefore, as far as a person of necrophiliac nature is only indulged in such activities with the intention of romanticism, he should be left in such condition. Any legal or psychological action should only be undertaken in the event if the necrophiliac activities take a path driven by sexual desires, which could be in serious violation of the general order in the society and the present legal scenario.

Current Legal Stance over Necrophilia in India

The prominent history of Necrophilia dates back around 3 decades wherein during this time the cases that occurred came more into the limelight of the public. Although a belief prevails that this type of activities dated back from the 15th or 16th century itself, now with the evolution of public awareness and empowerment of the media, people are now proceeding towards the viewpoint of this activity being in serious violation of human rights. However, when we talk about the necrophiliac activities related to the previous times of the 15th century, these forms of activities were connected to only the romantic nature of Necrophilia.

At that time, historians believed that people used to have so much connectivity with souls that they couldn't just accept the fact that death is the possible reason which could separate their relation to each other. Hence, in the event when a person eternally loved by someone died, his/her corpse was preserved to continue the activities undertaken before the time of death with the other partner. These activities didn't exhibit any kind of actions that involved the occurrence of sexual activities. According to them, sexual intercourse wasn't a successful way to portray the feeling of love.

Presently in India, a case of Necrophilia is considered an offense but has not gained enough recognition for a specific law. Hence currently, necrophiliac cases are referred and concerned to other provisions available in the Indian Judicial system which were originally formulated for different types of offenses. Primarily, a case of Necrophilia is referred to the two legal provisions of the Indian Penal Code. These provisions include Section 297 and Section 377.

On the very first note, both sections do not indicate any of the activities or conduct amounting to necrophiliac tendencies. Section 297[ii] is related to the trespassing on burial grounds; wherein trespassing on burial grounds with an intention to wound the feelings of an individual, the values of a religion, or with the knowledge that through his/her conduct the feelings of a person related to that place might be wounded, amounts to an offense. However, this provision could only be invoked in necrophiliac activities, in case an act of trespass has been committed.

Furthermore, Section 377[iii] connects to unnatural offenses. Herein, any voluntarily engaged act of carnal intercourse with a man, woman or animal, against the order of nature is considered an offense. In some cases, to define this unusuality of offenses, legal personalities also invoke the provisions connecting to rape and murder. However, on the contrary, neither of these provisions is capable enough to properly execute the offense and the people committing necrophiliac activities.

Violating the Dead: Is it time India had a Law Dealing with Necrophilia?

India is witnessing an increase in the number of incidents, but still, there are no laws governing the misconduct. The problem with several Necrophilia infringements is that, besides if specific legislation exists for making the demonstrations illegal, it may become difficult to rebuff. Savagery is another such issue. There is no proof exhibiting measurements of sexual contact with creatures in the country. Many sexologists note its height in rural areas and among those residing in proximity to domesticated animals.

Corpses are not individuals. They are undoubtedly human, but once any of us kicks the bucket we become semi-subjects under the observant eye of the law. The legal position of a corpse frequently renders Necrophilia much more challenging to comprehend when we view it equivalent to the sanctity that certain families would see the corpse as holding- the person might be dead, nevertheless they remain an acquaintance or a family member.

As per the legislation, in various instances of Necrophilia, a corpse becomes a kind of property for the nearest relative, a concept that several find doubly distressing. Since, in this context, Necrophilia transforms into a horrible tragedy, not a sexual attack on a person. Necrophilia is being considered as a crime by some states in the US and as an offense by others.

The permission or penalty for the ill-treatment of a corpse was seen as misconduct and that more prominent punishments appear to be doubtlessly unreasonable in light of the way that the damage included is just a shock to reasonableness. The breach of the regards stood to corpses reverberates neglect for the deceased and the enduring classes of the dead. The handling of the departed should be considered in the same way as per the unordinary rehearses among the alive.

Laws related to Necrophilia in India: Are there Any?

Several countries do not have strict legislation against Necrophilia, and India is one of them. In reality, a strange necrophiliac tradition existed in India at one time. If a woman who had been engaged, passed away before her wedding, her fiancé had to deflower her before she could be buried.[iv]

Not long ago, several accusations have been made in our nation, by families of dead women, that the corpses of their relatives have been defiled in the dark by Dieners, although none have been confirmed. [v] Even if these charges are proven, there is no legislation in India to prosecute such criminals.

Section 297 of the Indian Penal Code
, pertaining to intrusion on burial grounds, is the only legislation relating to corpses in our country. For an individual to be convicted under this section, he/she should have intruded into the cemetery with the objective to offer dishonour[vi] to the dead, this humiliation may entail having sexual intercourse with it, i.e., committing Necrophilia.

Therefore, for an individual to be prosecuted for Necrophilia under this section, the requirement is that the person must first have intruded the gravesite and then had sexual intercourse with the body after pulling it out of the grave, or otherwise. This keeps those who commit Necrophilia otherwise than intruding into a cemetery out of the claws of Indian legislation.

For example-the Dieners, technically, if a Diener is engaged in sexual intercourse with a corpse, he may not be prosecuted for offering humiliation to the body since he has not intruded on the gravesite and there is no legislation to prosecute someone who offers disgrace to the dead body (has intercourse with it) without intruding into or outside the gravesite under Indian Penal Code. Further, even though such an incident is proved, where the individual had intercourse with the body after intruding into the gravesite, the person who performs it will be penalized with a period of incarceration of not more than one year or a fine, or both. This punishment, not been prolonging one year, in any wise human's opinion, is very little for such inhuman crimes of offering disgrace to any dead body in the form of intercourse.

Maybe the drafters of the Legislation did not wish the act of Necrophilia to be prosecuted in this section, if they had wanted to do so, they would have explicitly specified that in the Code, and the penalty would also have been more than that given for in section 297 of the Code. It is because of this gap in our penal law that in the Nithari Case[vii], the two accused, Mohinder Singh Pandher, a wealthy businessman, and his chef, Surendar Koli, were not penalized for Necrophilia.

In this case, on the intuition of the homicide of a 19-year-old girl who was one of many girls who had disappeared from the village of Nithari, who went to the accused's place, the police raided the perpetrator's house and found various CDs of pornography and photos of nude women and kids.

This was accompanied by a large-scale inquiry and submitting a document to the court that gave a clean chit to Pandher because of lack of evidence, and a case was brought against Koli who agreed to the kidnapping, raping, murder and defiling of the bodies of females after their death under S. 302 (punishment for murder), 376 (punishment for rape), 201 (causing disappearance of evidence of the offense, or giving false information to screen offender) and some other provisions of the IPC, since Necrophilia is not an offense in India, hence no case could be lodged against him for engaging in sexual activity with the deceased.

Another case of this nature surfaced in Mumbai. As per the Indian Express newspaper, the accused tricked the woman victim to his apartment where he battered her to death and then brutally raped her. The accused admitted that he had killed the woman and sexually abused her corpse.[viii] Nevertheless, he was penalized for rape and murdering the victim and not for post-death intercourse, again because Necrophilia is not an offense in India and no case could be filed against him for this act.

Discussions have been held as to whether Section 377 of the IPC could be applied in such situations. The section issues a punishment of sentence of life imprisonment or incarceration of up to ten years and a penalty for any individual who willingly participates in sexual intercourse with any man, woman or animal against the natural order.

Although having intercourse with a dead body is not natural and thus comes under the class of an unnatural crime, however, one of the key components of this provision is voluntariness and there is no manner in which permission could be obtained from the dead body and, if the consent is not received, the intercourse will therefore be involuntary, thereby dissuading from the section.

The second aspect is that the intercourse should be done with a man, a woman or an animal; nevertheless, a dead body is considered a dead body since it is no longer people [ix]. They are most unquestionably human, but once an individual dies, he/she becomes quasi-subject to the law.

The legal position of a corpse often makes Necrophilia all the more difficult to comprehend as we think about it in comparison to the sanctity that certain families see the body as holding- the individual may be gone, but they stay a cherished one. And, in the legal sense, a corpse becomes a sort of property for the next of kin, which renders Necrophilia a vandalism, and not a sexual assault against an individual.

Laws in other Countries vis-a-vis India

When it comes to the legislation of other nations, as we obey the common law framework, let us begin with the USA. The United States does not have any federal legislation on Necrophilia; it is left to the respective States to make legislation in this respect. About forty out of fifty U.S. states have some or the other form of legislation that describes criminal activities concerning dead bodies.

There are four states viz: Arizona, Georgia, Hawaii, and Rhode Island, which specifically uses the term Necrophilia in their particular legislation, and the other thirty-six states have several legislations that refers to Necrophilia[x], for which sentences range from one year (in several states) to fifteen years (in Georgia) and twenty years (in Massachusetts).

In addition, section 250.10 of the Model Penal Code (Official Draft, 1962)[xi] lays out that it is a crime to handle dead bodies in a manner that displeases ordinary family sensitivities. Where there is no federal legislation on Necrophilia in the United States, Section 70 of the Sexual Offences Act, 2003 of the United Kingdom specifically renders it a crime for a person who deliberately, sexually penetrates, knowingly or recklessly, any portion of his body into any part of the corpse.

Punishment for such crime is incarceration for a period not extending six months or a penalty or both. Although, while there is legislation related to Necrophilia, it may not seem to have been enforced by the UK court in an instance where the perpetrator had admitted to killing his wife and subsequently had intercourse with her corpse in a police interrogation but was punished only for the murder.

The Criminal Code of Canada, 1985, renders Necrophilia unlawful without the explicit usage of the term Necrophilia, penetration or any sex-oriented word. Section 182 under Part V of the Law implies that:
whoever behaves indecently or improperly or offers indignity to the dead body or its remains is guilty of the offense and is liable to imprisonment for a term not exceeding five years.[xii]

The phrasing of this provision is, to some degree, is close to that of S. 297 of the IPC, which also contains the terms offers any indignity to any human corpse, although the distinction is that the comprehensible interpretation of S. 182 of Canadian law renders Necrophilia an offense under it, Section 297 of IPC, however, does not render Necrophilia an utter crime, since it renders it a crime only when there is an intrusion into burial ground whereas the Canadian legislation makes such action a crime whether the corpse is buried or not i.e. whether the offender trespasses into the burial ground or not. Also, the sentence under S. 182 of the Criminal Code of Canada is five years, which is five times the sentence under S. 297 of the IPC.

Even the French Penal Code does not use the term Necrophilia or such, but the easy implication on the straightforward understanding of Article 225-17[xiii] renders the conduct well within its scope and thus an offense. The sentence for incarceration under French Legislation is just one year (at most two years) but, the fine levied for these activities is large (€15.000-€30.000) at least from an Indian point of view that is quiet on the magnitude of the penalty to be applied. On one side, where there are nations that have poor or vague legislation on Necrophilia, there are countries such as Louisiana, North Carolina, Oklahoma and Kansas, on the other side, which simply authorizes intercourse with the deceased i.e., dead bodies[xiv], thereby rendering Necrophilia a lawful act.

Availability of the Prospective Defences

The cases related to Necrophilia in the present legal system are the most easily avoidable cases, wherein each and every accused or convict of having engaged in necrophiliac activities enjoys a state of liberation. In the absence of a substantial legal provision used in order to defend the law and provide room for the accused, whenever any necrophiliac activity being taken place is detected, the judicial system most of the time finds itself helpless to procure justice.

As stated earlier, in the absence of a law specifically made for necrophiliac activities, the accused and the convicts of such activities are usually dealt with legal provisions made for serving other purposes, like Section 297 and 377 are invoked however the former one is operated in the event of defiling of a corpse or in event of trespassing on burial grounds, and the latter one is made operational in case of unnatural offenses committed of carnal intercourse.

If considered in relation to the accused or the convict of Necrophilia, the most commonly used defense turns out to be the insanity of mind. Each and every case of Necrophilia mentions the possibility of the unsound nature of a person wherein he/she whenever found involved in a Necrophiliac activity doesn't have absolute control over his/her mind and senses, and therefore commits such an offense.

Now, since the person is not having control over his/her senses, the pleading towards the court always calls for the classification of the person of unsound nature, and therefore instead of punishing, admits him/her to a mental rehabilitation centre. This step undertaken by the court not only infringes with the rights available to the family of the victim but also questions the infliction of justice in society.

This defence of insanity of mind in the very first place turns out to be highly unethical as it is a generally deducible saying that not every time each accused of Necrophilia could be a victim of unsound nature. Many-a-times the sole act of indulging in necrophiliac activities suggests and indicates the severity of the crime, in addition to the bestial nature of the person involved. In even the most basic understanding, a person indulging in sexual activities with a corpse is considered as an act that is evident in the presence of bestial nature.

But unfortunately, the highly knowledgeable class of the legal fraternity is capable enough to turn the whole idea in a case of Necrophilia from bestial nature towards the unsound nature of a person. In recent years, there have also been incidents wherein the occurrence of necrophiliac ativities is just a result of the presence of rage and graveness within men. This rage inside grows within and overcomes the insight which then leads towards becoming the motivation for committing activities of Necrophiliac nature. These activities are generally centered towards firstly murdering a person, and then indulging in sexual intercourse with the corpse.

Mental and Clinical Reasons

Several analysts have tried to explain the reasons and clinical motivation to Necrophilia. The most popular reason they have identified is lack of confidence and apprehension of dismissal, as explained by Rosman and Resnick. They have explained how necrophiles find corpses as a carnal article that would not ignore them.

They find corpses satisfying their poor morale wants, and an accomplice who would not get exhausted of them without any issues. He generates an energizing fantasy of intercourse with a Corpse, in some instances after introduction to a corpse.

As Ernest Jones mentioned, The dead individual who adores will cherish perpetually and never be tired of giving and getting touches. Necrophiles have been depicted as mentally weak, incompetent for acquiring a consenting sexual companion.

Connectivity behind Necrophilia and Sexual Murders

With the concept of Necrophilia being relatively new, the society in addition to the jurists, most of the time co-relates the activities related to Necrophilia with the acts concerning sexual murders. However, both of these concepts are in exact contrast to each other and therefore depict different sets of activities. With this amount of confusion being in existence on the very basic level, it is therefore quite difficult to formulate a separate set of legal provisions for both of them.

If properly executed, the legal provisions formulated in respect to Necrophilia as well as the sexual murders shall not only define the very acts itself but shall also mention the respective amount of punishments to be inflicted on the convicts, in addition to the conservation of the rights of the families of the victim. Furthermore, the provisions shall also be set-up in such a way that they are capable enough to restore the harmed rights of the victim through compensatory measures.

By its very definition, Necrophilia concerns the activities undertaken by a human being with a dead body or a corpse that are particularly sexual in nature. Necrophilia differs itself from the rest through the manner the offense is committed. In the case of Necrophilia, a person commits activities that are sexual in nature with a dead person or a corpse, i.e., a person who is already died is used for the satisfaction of unusual sexual desires.

In many of such cases, Necrophilia also connects with the idea of defiling of the dead [xv]. This term is usually related to manipulations committed with burial grounds. In these cases, a person who is already dead is defiled from the graveyard and is then used for the purpose of satisfaction of sexual desires.

Some of its relative cases also consider the act of murder in addition to the activities of Necrophilia. In this sort of case, a person kills the other person and furthermore commits acts of sexual intercourse with the corpse. These activities usually involve a sense of rage and vengeance and therefore within that sense, commits the act. However, even after this severity of actions the rage of a person drives towards the activities concerning Necrophiliac nature.

On the other hand, Sexual Murders reflect the exact contrast to Necrophilia. Sexual Murders refer to those activities wherein a person engages into sexual activity with a living person and then to avoid suspicion and procurement of evidence, kills the other person. Such sexual activities committed before the killing of the person are usually non-consensual in nature and thus amount to rape. Fortunately, these types of activities have separate legal provisions wherein the offense is described properly, in addition to the mentioning of the appropriate punitive measures to the convict, as well as the compensatory measures to the victims.

Accountability behind the cases over the time

The dire need for legal provisions to be formulated is only realized when there are cases that require substantive applicability. With the concept of Necrophilia being in the picture, the cases have been arising from a couple of years due to which an undoubted need is felt for the legal provisions specifically centred to serve the offenses of Necrophiliac tendencies. In India, since the cases have started occurring which directly or indirectly indicate Necrophilia, it is now required that the Indian judiciary shall now execute a separate law for Necrophilia, and shouldn't merge it with some other legal provisions.

In the Indian context, the Nithari Case [xvi] of 2006 is considered as the onset of Necrophiliac cases. Although there were some previously occurred cases too, they weren't big enough to gain satisfactory media attention. The Nithari case not only gained successful media attention but was also the most severe and intense at that time on the measure of cruelty and bestiality. The facts of the case relate to the accused being a bungalow owner Moninder Singh Pander and one of its employees Surendra Koli.

The case involved the conduct of Necrophiliac activities by both of the accused within a span of almost 2 years, with almost 19 people held as victims of the bestial activity[xvii]. Rough estimates call for proper identification of 9 female children, 2 male children, and 5 female adults among the victims. The rest of the victims weren't exactly in the state of being identified.

The case connects with Koli being one of the main culprits, who was accused of being involved in kidnapping, rape, murders, Necrophiliac activities, bestiality activities, etc. With the case coming to light through police investigation, Koli later confessed of their activities concerning murdering, slaughtering and eating of the dead bodies, and then further disposing the dead bodies in the nearby drainage line which ultimately led towards the discovery of all the victims and, clearly indicated the people involved of being fiercely bestial, and intensely evil-minded[xviii]. His confession led towards the conviction of Pander as well as Koli, with finally awarding of death sentences to both of them.

One of the latest cases concerning Necrophilia, the Palghar case [xix] dates back to July 2020 amidst the time of countrywide lockdown due to the pandemic. Within this period, the case occurs wherein a shopkeeper, aged 30, allegedly kills a woman, aged 32, and then sexually assaults the corpse of the lady. The offense was said to be committed in furtherance of an argument taken place on the issue of the price of some goods from the shop of the accused, due to the fact he slapped the victim, dragged her by the hair, strangulated her, and slit her throat. With the rage still in the picture, the accused had then committed sexual intercourse with the corpse. The accused was convicted through CCTV footage and was finally convicted for murder and rape.

Conclusion
It seems that one of the factors for burning corpses after death in certain communities (most famously Hindus) or the burial of the bodies or in hard granite and marble tombs was to avert their breach by necrophiles. Necrophilia is, presently, though a poorly known occurrence, nearly all nations have legislation against Necrophilia; some have powerful ones and some have poor or ambiguous. India comes within the lowest level of the latter class of nations since its legislation in this context is poorer and more ambiguous than others.

This fragility and uncertainty have contributed to a deliberate question on Sections 297 and 377 of the existing IPC as to whether it renders Necrophilia a crime or not, taking into account the growing prevalence of Necrophilia[xx], it is time for the parliament to clear its stance by taking steps to criminalize it, either by making amendments in the IPC or by adding a new section to it. Unless, surely, the administration is not waiting for an occurrence of the intensity of Nirbhaya rape case to take place in this context, bringing the public back on the paths to grieve, demonstrate, and seeking stringent laws against Necrophilia.

End-Notes:
  1. Necrophilia; Is it an Offence, Rostrum's Law Review, Volume III, Issue 1. Retrieved from https://journal.rostrumlegal.com/necrophilia-is-it-an-offence/
  2. Section 297, Indian Penal Code, 1860.
  3. Section 377, Indian Penal Code, 1860.
  4. Masters REL, Lea AEE. Perverse Crimes in History: Evolving Concepts of Sadism, Lust-Murder, and Necrophilia—From Ancient to Modern Times. The Julian Press, New York, 1963. As cited in Dr. A. Aggarwal, Forensic and Medico-Legal Aspects, 6, CRC Press, New York, (2011)
  5. Dr. A. Aggarwal, Forensic and Medico-Legal Aspects of Sexual Crimes and Unusual Sexual Practices, CRC Press, 310, New York, 2008.
  6. Ratanlal & Dhirajlal, the Indian Penal Code, 487 (Lexis-Nexis, 34th ed., 2014). Ibid c 2.
  7. Mohinder Singh Pandher and Surendra Koli v. State of Uttar Pradesh, Indlaw ALL 237; 2009 (8) ADJ 251.
  8. Youth gets Life in Jail for killing teen, sexually abusing her body, The Indian Express, 10th Dec 2010
    Retrieved from http://archive.indianexpress.com/news/youth-gets-life-in-jail-for-killing-teen-sexually-abusing-her-body/722762/
  9. John Troyer, 'Why we are so fascinated by people who want to have sex with dead bodies', The Conversation. Retrieved from https://theconversation.com/why-we-are-so-fascinated-by-people-who-want-to-have-sex-with-dead-bodies-28622
  10. J. Troyer, Abuse of a corpse: a brief history and re- theorisation of Necrophilia laws in the USA, 13.2 Mortality, 134, (2008).
  11. Section 250.10, Model Penal Code, (Official Draft, 1962)
  12. Section 182, Criminal Code of Canada, 1892
  13. Article 225-17, Code Penal (France), 1994
  14. A. Weinstein, Gawker, here are the States Where Blowjobs Are Illegal but Necrophilia's Cool, available at: https://gawker.com/here-are-the-states-where-blowjobs-are-illegal-but-necr-1563878569 , T. Bigler, Necrophilia is legal in These States, available at: https://gawker.com/here-are-the-states-where-blowjobs-are-illegal-but-necr-1563878569
  15. Shivam Kunal and Ishita Sapre, The Curios Case of Necrophilia in India: Why Defiling the Dead should be a penal offence, Centre for Criminal Justice Administration, RMLNLU Lucknow. Retrieved from https://ccjarmlnlu.wordpress.com/2020/08/14/the-curious-case-of-necrophilia-in-india-why-defiling-the-dead-should-be-a-penal-offence/
  16. Surendra Koli v State of Uttar Pradesh, Criminal Appeal No. 2227 of 2010.
  17. Peeyush Khandelwal, 'Nithari Killings: Surendra Koli given death penalty in 10th case', Hindustan Times (Noida, 03 March 2019).
  18. Anubhav Pandey, 'All you need to know about Nithari serial killings', IP Leaders. Retrieved from https://blog.ipleaders.in/need-know-nithari-serial-killings/
  19. Palghar stunned by Necrophilia, a man raped woman's corpse, The Tribune, 04 July 2020. Retrieved from https://www.tribuneindia.com/news/nation/palghar-stunned-by-necrophilia-a-man-raped-womans-corpse-108480
  20. Nitin B, 'Violating the Dead: Is it time India had a law dealing with Necrophilia, The News Minute, Retrieved from https://www.thenewsminute.com/article/violating-dead-it-time-india-had-law-dealing-necrophilia-35631

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