Rescue and Post-Rescue of Victims of International Migration and Trafficking : An Agenda for Action

ABSTRACT

This paper focuses on the magnitude and myriad dimensions of Migration and trafficking of women and children in India, for the purpose of commercial sexual exploitation. It highlights the national and international ramifications of migration and trafficking industry, which has become a multi billion-dollar trade and is part of the transnational organised crime syndicates, which operates illegal operations such as the illegal arms and drugs trades. While there exists a legal framework to deal with the issue of trafficking - in the Constitution, the Indian Penal Code and specific legislations such as the Immoral Traffic Prevention Act, 1956, Juvenile Justice Act, 2000 and the Devadasi Prohibition of Dedication Acts of A.P. and Karnataka – the implementation of these legislations is tardy to say the least, primarily due to ambiguity on the part of the State agencies, especially the police, which views this phenomenon more as a social issue rather than as organised crime. Since the eighties, various judgements of the Apex and High Courts of India have highlighted the issue and forced the Central and State governments to take proactive steps to curb the menace of trafficking and initiate measures towards the rescue and rehabilitation of migrated and trafficked victims. The Union and State governments have taken a series of measures in the recent past to bring in law and policy change to address the issue. However, these steps are like the proverbial drop in the ocean, compared to the magnitude of the problem at hand. The paper suggests specific areas of focus and an agenda for action to address the issue of an effective rescue and post-rescue strategy for migrated and trafficked  victims in the country.

It suggests that the discussion has to be pitched at three levels – those in need of rescue, the process of rescue and the post-rescue phase. It draws attention to the role of the police, the judiciary, the district administration and civil society organizations need to play in order to address the plight of the victims. Lastly, it suggests a series of measures that need to be taken by the State and civil society organizations towards an action plan for the prevention of International Migration and  trafficking, and the rescue and rehabilitation of migrated victims.           

Introduction

International human trafficking  and Migration is perhaps one of the biggest illegal industries today, involving crime syndicates, which cut across the North-South divide. The trade has gained in size and dimension particularly in the last two decades or so. According to Omar (2007), this unprecedented spurt is an offshoot of globalization, resulting from large-scale migration of cheap labour due to impoverishment on a mass scale. Crime syndicates are operating to take advantage of this situation. Omar adds that there are an estimated 4 million women and children being trafficked every year, and the profit from this illegal trade is estimated to be to the tune of $ 7 Billion in Europe alone. According a report by Kohli (2007), the human trafficking industry worldwide is worth $ 32 Billion annually and around 1,50,000 persons are trafficked within South Asia every year.

The issue of trafficking in India has both intra and inter-country dimensions. Kohli’s  (2007) report quoting a UNODC source, says that India is a top source, transit and destination country for human trafficking (ibid.). Chhetri and Thapa’s study (2006) highlights clearly the trafficking scenario across the Indo-Nepal border. International dimensions of trafficking are now a well-established fact (Prayas, 2004). The work of Prayas in Mumbai with rescued women since the last 15 years or so also bears testimony to this fact. Women rescued from the red light areas, dance bars, massage parlours, lodges, etc. have been found to have been trafficked from all parts of the country – Andhra Pradesh, Karnataka, Maharashtra, Tamil Nadu, Kerala, Rajasthan, M.P., U.P., Bihar, West Bengal, Assam, Himachal Pradesh and Sikkim, to name a few.

As far as cross border trafficking is concerned, Prayas’ experience shows that women and children have been brought from Nepal, Bangladesh and even some of the Eastern European countries such as Uzbekistan. Currently, a large number of these women and children are found to be from West Bengal, U.P., Rajasthan, Andhra Pradesh and Bangladesh. The pattern may be different in other destination areas such as Kolkata, Delhi, Goa or Pune. Kohli’s (2007) article quotes a UNODC report that the major ‘harvesting zones’ include Bihar, Andhra Pradesh, West Bengal, Assam, Jharkhand and Orissa. High demand areas in the same report point to Goa, Maharashtra and Delhi. Delhi is used as an international transit point for trafficking to Pakistan and the Middle East. 

Another indicator of the presence of trafficking of women is the rising number of missing complaints filed with the police by families of victims. There has been a 34% increase of such complaints between 1996 and 2001 as per the National Crime Records Bureau (ibid.).

The phenomenon of commercialized prostitution in India, in the words of Kapur, (1979) “picked up speed by the beginning of the 17^th century.” She quotes Jaykar (1955, pp 353) saying that the strong tide of circumstance forced the institution of prostitution into a mercenary affair. She further adds that it spread first to port towns and gradually to the other parts of the country. The onset of the British Empire coupled with rapid urbanization and industrialization, gradually gave rise to brothel prostitution.

However, commercialized prostitution has gone much beyond the concept of red-light areas in towns and cities of India. Accordingly, trafficking is also taking myriad forms and is not any more limited to its traditional base of brothel-based prostitution. The earlier linear description of forced prostitution as involving kidnapping, rape, criminal breach of trust, wrongful confinement, etc. is not enough to describe the processes related to trafficking of women and children for the purposes of prostitution. Feminization of poverty in the rural hinterlands and the absence of social supports and security, lead to women and children being lured and seduced to take to ‘jobs’ in the entertainment sector, often seemingly on a voluntary basis.

These new age jobs in dance bars, massage parlours, tourist hubs, etc. invariably lead to the sexual exploitation of women and children. They get pushed into prostitution, through an underlying process of suggestibility, in the absence of employment options with dignity. The Prayas study (2005) on the situation of women working in dance bars, explicates the processes involved pushing a woman into exploitative situations. There is a need to redefine trafficking as including such destination areas, rather than remaining limited to a ‘brothel-based or red-light district’ approach.    

Lack of credible and systematic data on the magnitude of trafficking is a major problem. The study by the Central Social Welfare Board in 1990 was the first of its kind, which gives us some idea of the extent and nature of the problem (Mukherjee and Das, 1996). The NHRC study (2004) across 12 States of the country gives a glimpse of the widespread nature of the phenomenon of human trafficking for the purpose of sexual exploitation of women and children in India. Similarly, according to the CATW study (1996), there are more than 1000 red-light areas in the country where women and children are trafficked and forced into prostitution from different parts of the country.

As far as intervention to deal with women and children in vulnerable situations is concerned, the post-independence period witnessed a wide range of initiatives by the State and voluntary groups. However, their emphasis was on protection, care and welfare, and institutionalization was a major means to achieve these objectives. The words ‘rescue and rehabilitation’ gained parlance in this context. The women and children who were seen as being in need of care and protection were those without family support or vulnerable to crime, prostitution, destitution etc. The attempt of the State was to ‘take charge’ of such groups and make positive interventions in a pre-determined direction – institutionalization, vocational training, marriage and job placement. Laws were enacted to give a legal mandate to such interventions. The Immoral Traffic Prevention Act, 1956, was one such legislation to intervene in the situation of women and girls in prostitution.

Probably the first steps to deal with brothel prostitution by the civic authorities and the police were initiated in France and the U.S. in the mid-forties but without much success. Another step in this direction was the U.N. Convention for Suppression of Traffic in Persons for Exploitation and Immoral Purposes. India became a signatory to this Convention in May 1950, following which the Indian Parliament passed the Suppression of Immoral Traffic Act, which came into force in 1958. There were two major underlying principles behind this legislation – that prostitution involved traffic in human beings (which needed to be controlled) and that it was a fallen profession leading to decline of public morals. The same Act (ITPA) was subsequently amended in 1986 into its present form (ibid).

The ITPA provided the framework for State intervention to rescue and rehabilitate victims who had been forced into the trade. The first twenty to thirty years following Independence saw a vigorous and sustained attempt by the State to set up and activate the machinery required to deal with the problem. As per that Act, special police officers and rescue officers (the latter a unique initiative of the Government of U.P.), protective homes, rescue homes and rehabilitation schemes of the Social Welfare Departments were initiated. Caste based prostitution such as the Devdasi phenomenon was banned by the State and schemes were floated to rehabilitate such groups. These efforts of the State were boosted by efforts of individuals and voluntary groups who entered this field with an almost missionary zeal and a reformist ideology.

However, the last two decades or so have seen a watering down of such efforts by the State. Based on the experiences gained from the field by this author, it can be said with some certainty that most States have not expanded beyond the one or at the most two protective homes that they had set up in the initial phase. Hardly any State has set up separate Corrective Institutions as specified in the ITPA. There are large numbers of vacancies in these homes as far as posts of probation officers, caretaking staff and vocational instructors are concerned. There has been a view gaining ground that rehabilitation is not possible and the strategy should shift to the rescue of only minors and a policy of improvement of quality of life should be adopted vis a vis adult woman caught in the web of flesh trade. Some groups emphasise the need to legalise the profession, as a way to address the problems being faced by women in prostitution.

Probably due to the tremendous spurt in human trafficking and the exploitation of minors in this trade (consequent to the HIV/AIDS threat), there has been a revival of interest in prevention, rescue and rehabilitation.

In recent years, there has been a regrouping of interests of those who are seriously concerned about the flourishing of this phenomenon and a number of initiatives throughout the country in the area of rehabilitation. The Central and the State governments have been forced to re-examine the machinery and resources allocated to deal with rescue and rehabilitation. There is a growing realization of the need for an action plan to deal with trafficking and prevention work. International pressure, in particular, from the U.S. and U.N. agencies such as UNIFEM and UNODC is adding to the pressure on governments – both Central and the State – to take pro-active measures to tackle the situation.

The Legal Framework

The Constitution of India under Articles 21 and 23 clearly lays down that trafficking of human beings amounts to a violation of Fundamental Rights. The main legal instruments legislated by the State to deal with trafficking of persons for the purposes of prostitution are the ITPA, the JJ Act and the IPC. In fact, the IPC has defined almost every conceivable offence in the process of trafficking of persons – cheating, kidnapping, wrongful confinement, criminal use of force, simple hurt, grievous hurt, sale of minor, outraging the modesty of a woman, rape, criminal intimidation, etc. These sections, if imaginatively used by the prosecuting agencies, can be sufficient to arrest and prosecute those involved in the trade – procurers, those involved in selling of victims, pimps, brothel keepers, hotel managers, landlords, and even customers – especially if the victim is a minor (Prayas, 2004).

As far as the ITPA is concerned, it has some excellent provisions to prosecute the traffickers (refer to sections 3, 4, 5 and 6), including a provision (section 18) to close down and seal a premise where commercialized prostitution is being carried on. The problem lies with the implementation of the law. Time and again, it has been found that the sections most used under this Act are sections 7 and 8, which pertain to soliciting by women in prostitution, thus leading to a further victimization of an already victimized group. Sections 15, 16 and 17 deal with removal, rescue, temporary safe custody and rehabilitation of victims. These provisions can be effectively used by the police to rescue trafficked victims and ensure their rehabilitation under judicial supervision.

Similarly, there are provisions in the JJ Act 2000, to rescue minor girls (as children in need of care and protection) and ensure their rehabilitation under the supervision of the Child Welfare Committees constituted in every district of the country under the Act (ibid.).

With regard to prevention of caste-based sexual exploitation of women and girls, such as the Devadasi tradition, there are specific laws enacted by the States of A.P. and Karnataka^[2], which prohibits dedication of girl children to Goddess Yellamma^[3].  

In spite of all these provisions under the law, implementation remains tardy, primarily owing to the presence of vested interests both within and outside the system.  Provisions such as presence of women police and respectable women citizens while carrying out a rescue, constitution of Advisory Boards and a Panel of Social Workers attached to the police and the courts, and appointment of Special Police Officers and Trafficking Police Officers largely remain on paper in most States (NHRC, 2004, Prayas, 2004).

However, some lacunae in law continue to persist. For instance, as Ravi Nair (2006) points out, in USA, the Trafficking Victims Protection Act was passed in 2000, which specifically defines and penalizes the act of trafficking. The penalty for trafficking has been enhanced to imprisonment for twenty years or life, in aggravated circumstances. Apart from imprisonment, the Act allows for the forfeiture of the assets of the trafficker. It also provides for mandatory restitution of the trafficked victim's losses by the court.

The Trafficking Victims Protection Act 2000 in the US also provides for continued presence of a trafficked person in the United States, "if after an assessment, it is determined that such individual is a victim of a severe form of trafficking and a potential witness to such trafficking, in order to effectuate prosecution of those responsible." The law enforcement officials shall also ensure that the trafficked person and his/her family are adequately protected from intimidation, threats from the traffickers and their associates ^[4]

Unless a clause of this nature is introduced in India in the ITPA, the issue of trafficking will not be completely addressed. ^[5]

The Role of the Judiciary

The judiciary in India has played a stellar role in activating the executive and promoting policy and law change towards the prevention of trafficking as well as rescue and rehabilitation of women and minors forced into the flesh trade. In the Upendra Baxi vs. State of U.P. and others, the SC expressed its deep anguish ober the condition of protective homes in the country and set up a mechanism through the NHRC to monitor the same.^[6]

In the landmark judgements in the Vishaljeet Vs. Union of India and Others (1990) and the Gaurav Jain Vs. Union of India and Others (1997), the Supreme Court has given detailed directions to the Union and State Governments^[7] to:

v  Evaluate, monitor and implement measures to prevent trafficking

v  Initiate steps towards the rescue and rehabilitation of victims of commercial sexual exploitation

v  Take legal action against traffickers and middlemen

v  Rehabilitate victims of cultural practices

v  Constitute Central and State level Committees to combat trafficking of women and children and take steps towards their rescue and rehabilitation

v  Streamline procedures for age verification process of minors

v  Implement provisions relating to the JJ Act towards the rescue and rehabilitation of minors in the trade.

In the recent Prerana Vs. State of Maharashtra and Others (Criminal Writ Petition No. 1694 of 2003) judgement, the High Court has passed detailed directions to implement the various provisions of the Immoral Traffic Prevention Act, 1956, including setting up of ‘Anti-Trafficking Cells’ in the police at district and State levels, appointment of advisory boards and panel social workers attached to the Special Police Officers and Magistrates, appointment of counselors and probation officers in protective homes, provide legal aid to victims by the Maharashtra State Legal Services Authorities, formulate an effective rehabilitation programme for rescued victims and frame Stat Rules under the ITPA. 

These judgments have in the least, helped in highlighting the issue of trafficking of women and children and the plight of the victims of commercial sexual exploitation, and at most, forced the State to take some proactive measures to address the issue.

Efforts of the State

The Ministry of Women and Child Development, G.O.I. and Departments of Women and Child Development of the State Governments have been taking a series of measures in the recent past to address the issue at hand. The Ministry of WCD, G.O.I., following the Vishaljeet and Gaurav Jain judgements, initiated a National Plan of Action to Combat Trafficking of Women and Children. A Central Advisory Committee has also been functioning since then to address the various issues relating to trafficking of women and children in India and take steps towards the rescue and rehabilitation of trafficked victims. Meetings are regularly held where officials from the Central and State governments and civil society organizations meet to discuss the take stock of the progress to deal with the situation.

The Ministry of WCD, G.O.I., has initiated schemes towards the rescue and rehabilitation of victims of trafficking, as also to prevent trafficking of potential victims in the source, transit and destination areas^[8]. 

However, the magnitude and dimensions of problems relating to trafficking of women and children is so huge that all these measures are nothing more then the proverbial drop in the ocean. What is required is the political will towards a concerted action plan and an implementation mechanism, which can address the issue from its various angles and points of entry.

Suggested Areas of Focus

While the issue of trafficking of women and children needs to be addressed at the prevention, rescue and post-rescue levels, this paper is focused on the latter two, since it is borne out of the experiences of a project works has worked at these two levels. For the purpose of clear identification of what is required to strengthen the rescue and rehabilitation process, the following three areas need discussion:

·         Those in need of rescue

·         The process of rescue

·         Post-rescue phase i.e. rehabilitation 

In focusing on those in need of rescue, one would have to identify situations and places where such persons could be found. The current rescue policy/approach of the police and voluntary action groups is largely on the established red-light areas of the cities and towns. The reality however is that other spots such as railway stations, bus depots, hotels and lodges, beer bars, massage parlours, beaches, and a host of other such places may require attention in order to identify those in need of rescue.

Presently, the only legal action being pursued with respect to such places is penal action under the Indian Railway Act, Bombay Police Act and other local laws with the objective of ‘clearing’ these places of undesirable elements under pressure from citizens’ groups. The fact that there may be persons in need of rescue here is completely lost sight of by the authorities concerned. It is assumed that all persons found in such places are willingly into the trade. This amounts to oversimplification of the reality.

Many a time, during a rescue operation, its connection with rehabilitation is overlooked. The fact that the purpose of any rescue is to effectively rehabilitate the rescued person needs to be highlighted. The pros and cons of these methods need to be systematically analysed, from the point of view of identifying method/s that could more effectively lead to the rehabilitation of the rescued persons. One would also have to draw out a range of suggested rescue initiatives for discussion and action.

The issue of rehabilitation is the most crucial and vexed part of the process. A lot has already been written about this subject and there is no dearth of literature in this area. We have to put our heads together to consolidate this available knowledge. Examining the efforts of various State and NGO interventions, and their attempts at collaboration and networking could suggest the way forward.

The experiences and suggestions of the women themselves i.e. those who are currently in prostitution (and in contact with NGOs) as well as those who are trying to or have got out of prostitution, should form the basis of any proposed rehabilitation plan. An effort at matching what is already being done in the area of rehabilitation with what emerges from these narratives could form the basis of a sound rehabilitation strategy.

It is becoming clearer to those involved in rehabilitation that it is important to disaggregate the needs of women in this trade in order to be effective in addressing rehabilitation concerns. For instance, age and marital status as well as whether the rescued person is planning to go back to her native State or wants to settle down (at least for the time being) in the same city where she was trafficked are important considerations.  Whether the person is a minor or an adult, unmarried or deserted (and now single), with or without children, young or middle aged – these are details that would have a bearing on the process of reintegration. Further, at what point of her life the rescue has been affected (i.e. within three months of being trafficked, within one year or more than three years), would significantly influence the chances of rehabilitation. More importantly, how she sees her future in terms of whether she wants to go back to her family or wants to strike out a life of economic self-reliance would need to be factored into any intervention effort.

Another issue relevant to the concerns of this paper is of women/girls who come back or get re-trafficked to the same city/area, after a period. The NHRC Study (2004) found that 24% of rescued victims are pushed back into the flesh trade. We need to draw out the factors that force them to come back, in order to prepare a more effective rehabilitation plan. An attempt would have to be made to suggest an appropriate support structure and mechanism for the repatriation of such women.

In this context, it is important to examine the role of the police, the department of women and child development, civic authorities, district administration and the NGO sector in the prevention of trafficking, rescue and rehabilitation processes. The discussions around this issue should focus more on the role of the State from deterrence to rehabilitation and suggest a rehabilitation scheme for victims of trafficking. This is particularly important because trafficking involves serious and organised crime and should not be confused or seen as a ‘social problem’ alone, as is often done by the State agencies, and in particular, the police.

An Agenda for Action

Trafficking includes luring, cheating, sale, use of force, kidnapping, rape, confinement and trapping persons who have left their homes (without support) and migrated to cities in search of economic options^[9]. It implicates informal networks in the family and community which lead to victims landing up in exploitative situations and the tie-up of these networks with criminal networks consisting of investors, carriers/transporters, sellers, buyers and persons who run these rackets.   

Since almost all the above-mentioned processes are illegal, there is some violation of law involved in each of the acts being committed. A detailed enumeration of which sections of the law are being violated in IPC, ITPA, BP Act, Child Labour Act, JJ Act (or any other special laws) will help in defining the crimes relating to trafficking. The need for a special law to deal with trafficking in humans, along the lines of laws enacted to deal with trafficking in drugs, antiques and wild life poaching needs to be reviewed.

The role of the police and the judiciary to deal with the above-mentioned processes and violation of laws is critical to address the issue. Some questions need to be raised in this context. Specifically,

v  What or how are the police doing currently to deal with the situation?

v  What is the response of the judiciary towards those arrested under various sections of the law for trafficking related offences?  

v  What role can the district administration play in terms of anti-poverty and welfare schemes to identify and reach out to vulnerable families and persons?

v  What role can the community and NGOs (specifically those working with women and children) play in preventing such persons from being trafficked? 

Most importantly, if one has to address the issue of prevention of trafficking of persons for sexual exploitation, one will have to start by mapping of supply and demand regions/areas/districts/pockets so that the machinery to deal with trafficking could be strengthened in these areas.

Conclusion

It is obvious from the thrust of this paper that if one has to address the issue of trafficking of women and children, especially for the purposes of their commercial sexual exploitation, it is necessary to develop an action plan at the National, State and district level. The efforts would have to be directed towards:

1. Establishing a national database on source and destination districts with a special focus on women headed households.

2. Identification of supply areas through analysis of existing records of the police, case files of trafficked victims available with CWCs/JJBs, Protective Homes and Children’s Homes/Special Homes.

3. Identifying the modes of entry especially in the context of the multi-layered process discussed earlier. This could be achieved by interviewing the police, staff of Children’s/Protective Homes, NGOs and the victims themselves.

4. Creation of Anti-Human Trafficking Wing in the Police at the Central, State and district levels along with creation of an Intelligence wing to deal with Inter and Intra Country trafficking of human beings for various purposes. The CBI has already been given the responsibility of playing the role of a Nodal agency in this regard, but structures to perform this function are not yet in place. The structures should be along the lines of those that have been created to deal with trafficking of narcotics, terrorism, wild life and antiques.

5. Strengthening the role of anti-trafficking groups, which are especially focusing on anti-trafficking measures through networking with SHGs, CBOs and women’s organizations, by providing them with infrastructure and financial support. 

6. Creating mechanisms in the police and district administration including dedicated manpower and resources to prevent trafficking and accelerate the process of rescue.  

7. Reviewing thoroughly, the registered cases of trafficking and their follow-up from court records, to identify the lacunae in the existing law enforcement machinery.

8. Establishing and strengthening structures for the rehabilitation of victims of trafficking with a special focus of creation of shelters for women and children right down to the taluka level.

9. Improving the rehabilitation programme in Protective Homes and Correctional Institutions with a focus on trauma care, counseling, legal aid, livelihood training, income generation, planned repatriation and provision of alternate shelter options for women in vulnerable situations such as open shelters, group homes and reservation in working women’s hostels.

10. Creation of protective homes in all destination districts with sufficient human resource and infrastructure to give a fillip to the rescue process, since one of the major complaints of the police as of now is the lack of availability of institutional care and rehabilitation structures, especially in non-metro and district places.

11. Involving NGOs working in the area of anti-trafficking, income generation, counseling, vocational training and rehabilitation in prevention, rescue and rehabilitation work, based on the principle of partnership. Specific MoUs should be signed to the responsibilities are worked out and the process does not lead to handing over of State functions to the private sector.

12. Linking women in vulnerable situations and those living in custodial institutions to the welfare/NGO sector through an apprenticeship programme, whereby women receive training or skill upgradation within the protected environs of welfare organizations. A decent stipend to cover support costs should be paid by the government while the women are receiving training in these NGOs for a period ranging from one to three years.

13. Arranging for shelter, medical care and education of children of women in difficult circumstances or those living in custodial institutions (including women prisoners), so that the pressure to earn a livelihood to support them is taken off their shoulders, at least for some time. This can be achieved through the existing network of childcare institutions under the supervision of the CWCs established under the JJ Act, 2000.

14. Reaching out to vulnerable families/persons in the source/supply districts through facilitating convergence of existing anti-poverty schemes such as the NREGA, schemes for SC/STs, OBCs, women and children in order to reach vulnerable families and individuals in the source areas, thus preventing them from being trafficked.

In conclusion, the phenomenon of human trafficking, especially women and children for the purpose of their sexual exploitation can only be tackled if there is an all round and coordinated effort on the part of the State, civil society organizations and citizens in general. The seriousness of the issue needs to be highlighted among all sections of civil society and the State. There has to a zero tolerance approach to the issue of trafficking and proactive measures need to be taken to rescue and rehabilitate trafficked victims. Trafficking has to be viewed as a heinous crime that enslaves vulnerable sections of society to a demeaning practice, which should have no place in a civilized society. Lastly, only when we create effective mechanisms to support those already into the flesh trade to come out of it, can we speak of prostitution as a choice that some women take to in order to earn a livelihood. Negative choice can never be passed off as a choice people make to fend for themselves.

References

1. Kapur P. (1979). The Indian Call Girls, New Delhi: Orient Paperbacks.

2. Mukherjee K.K. (1996). Prostitution in Metropolitan Cities of India, CSWB, New Delhi: Das, Deepa.

3.  CATW Trafficking in Women and Prostitution in the Asia Pacific, 1996 Coalition Againist Trafficking in Women – Asia Pacific, Manila

4. Ralph R.E. (2000). Testimony before U.S. Senate Committee on Foreign Relations Sub-Committee on Near Eastern and Far Eastern Affairs, Washington.

5. National Human Right Commission-  A Report on trafficking in Women and Children in India, 2004, 2002-03, Institute of Social Sciences, National Human Rights Commission and UNIFEM, New Delhi.

6. Prayas  Report of the National Workshop to Review the Implementation 2004 of Laws Related to Trafficking: Towards an Effective Rescue and Post-Rescue Strategy, Mumbai.

7. Prayas, A Report on the Socio-Economic Situation and 2005 Rehabilitation Needs of Women in Dance Bars, Mumbai.

8. Chhetri, Anju &Writing Against Trafficking, ASMITA Women’s Thapa, Manju Publishing House, Media Resource Organisation, Kathmandu, 2006    

9. Omar I., Theme Paper on Human Trafficking, 30^th Annual Conference of 2007 the Indian Society of Criminology, Kolkata.

10. Nair, Ravi Unpublished (Email transmission to Prayas), South Asia Human      2006          Rights Documentation Centre, New Delhi.

11. Namita Kohli  Seduced, Imported, Sold, article in Sunday Hindustan Times, pp 8, 2007 October 14, Mumbai.

Samya Roy Choudhury