Author(s): Priya Gautam
Paper Details: Volume 3, Issue 1
Citation: IJLSSS 3(1) 52
Page No: 563 – 575
INTRODUCTION
Women’s reproductive rights are a fundamental pillar of human rights, encompassing the freedom to make autonomous and informed decisions regarding reproductive health, access to comprehensive healthcare services, and the ability to engage in family planning. These rights are essential for ensuring gender equality, empowering women, and fostering overall well-being. In India, significant legal strides have been made over the years; however, the journey toward full reproductive autonomy remains fraught with challenges. The legal framework governing reproductive rights is a complex mix of progressive statutes, outdated traditions, and deep-seated socio-cultural barriers, creating obstacles to women’s health and personal agency.
A landmark development in India’s reproductive rights landscape was the enactment of the Medical Termination of Pregnancy (MTP) Act in 1971, which allowed women to seek abortions under specific conditions. The primary objective of this legislation was to reduce the high incidence of maternal deaths and complications arising from unsafe abortions, which were alarmingly prevalent before the Act’s implementation. Despite the legal provisions, access to safe abortion remains inconsistent, especially in rural and marginalized communities where healthcare facilities are inadequate.[1] Research indicates that a significant proportion of abortions still occur outside formal medical settings, often in unsafe and unhygienic conditions, leading to preventable health complications and fatalities.
To address some of these concerns, the MTP Act was amended in 2021, extending the permissible gestational limit for abortion to 24 weeks for certain categories of women, including survivors of rape and incest, minors, and other vulnerable groups. While this amendment was a progressive step, its practical impact remains a topic of debate, as systemic issues such as inadequate medical infrastructure, lack of awareness, and social stigma continue to hinder women’s access to safe abortion services.[2]
Beyond the MTP Act, the right to reproductive autonomy is also enshrined in the broader constitutional framework of India. Article 21 of the Indian Constitution, which guarantees the right to life and personal liberty, has been interpreted by the Supreme Court to include reproductive choices within its ambit. This was reaffirmed in the landmark case of Justice K.S. Puttaswamy (Retd.) and Anr. v. Union of India and Ors., where the Supreme Court underscored the significance of bodily autonomy and the right to make decisions regarding reproductive health. However, translating these constitutional guarantees into reality remains a challenge. Inadequate healthcare infrastructure, particularly in rural areas, coupled with deep-rooted cultural and religious beliefs, often restrict women’s ability to exercise their reproductive rights freely. This highlights the urgent need for a robust legal and policy framework that not only establishes rights on paper but also ensures their practical implementation.[3]
One of the most pressing concerns within the realm of reproductive rights in India is the persistent stigma surrounding abortion. Despite legal advancements, many women, particularly unmarried women, face societal prejudice when seeking abortion services. The lack of awareness about legal provisions further exacerbates this issue, leading many women to resort to unsafe methods. Additionally, some medical practitioners hesitate to provide abortion services due to concerns over legal repercussions, moral dilemmas, or societal pressures. The Supreme Court’s 2022 ruling, which extended the right to abortion to all women, regardless of marital status, was a progressive step in ensuring gender equality and non-discrimination. However, changing societal perceptions and ensuring the enforcement of such rights remains a significant challenge.[4]
Apart from abortion rights, access to contraceptive services is another critical aspect of women’s reproductive health. Although India has implemented various family planning initiatives over the decades, disparities persist in the availability and quality of contraceptive services. Women in rural and economically disadvantaged communities often struggle to access reliable contraceptive methods due to limited healthcare infrastructure, cultural taboos, and widespread misinformation. These gaps in access not only affect women’s health but also have broader socio-economic implications, limiting their ability to make informed family planning choices and achieve financial independence.
India’s approach to reproductive rights must also be assessed in comparison with global best practices. Countries such as Canada and the United Kingdom have established comprehensive reproductive health policies that prioritize accessibility, affordability, and non-discrimination. In contrast, India’s policies have often been reactive rather than proactive, with legal reforms typically arising in response to public interest litigations and judicial interventions rather than forward-thinking legislative initiatives.[5] A comparative analysis of global models can provide valuable insights into how India can strengthen its reproductive rights framework while taking into account its unique socio-cultural context.
HISTORICAL BACKGROUND
In 1945, the United Nations Charter established the obligation to “promote universal respect for and observance of human rights and fundamental freedoms for all without discrimination as to race, sex, language, or religion.” However, it did not define these rights. Three years later, the United Nations adopted the Universal Declaration of Human Rights (UDHR), marking the first international legal framework outlining human rights. Notably, the UDHR did not specifically mention reproductive rights.
The concept of reproductive rights emerged in international discussions in 1968 with the Proclamation of Teheran, which affirmed that “parents have a basic human right to determine freely and responsibly the number and the spacing of their children.” This principle was later reinforced by the UN General Assembly through the 1974 Declaration on Social Progress and Development, which emphasized that the family is a fundamental societal unit and should be supported to fulfil its responsibilities. It further asserted that parents have the exclusive right to determine the number and spacing of their children.[6]
By the late 1970s and early 1980s, the feminist and women’s health movements had gained momentum worldwide, advocating for women’s rights and reproductive autonomy.[7] In this context, the International Contraception, Abortion, and Sterilization Campaign (ICASC) organized the fourth International Women and Health Meeting (IWHM) in 1984, with the theme “No to Population Control… Women Decide!”
The 1994 International Conference on Population and Development (ICPD) in Cairo expanded upon previous declarations, asserting that women of reproductive age have rights including access to information, healthcare, and protection of their health. The 1995 Fourth World Conference on Women in Beijing further broadened the scope of reproductive rights, affirming that women have the right to make decisions regarding their sexuality and reproductive health without coercion, discrimination, or violence. It emphasized mutual respect, consent, and shared responsibility in sexual and reproductive matters.
In the United States, a landmark legal precedent for reproductive rights was set in 1965 with the Supreme Court ruling in Griswold v. Connecticut, which recognized a fundamental right to privacy that extended to contraceptive use. This right was later expanded to include unmarried couples in Eisenstadt v. Baird (1972), and in 1974, a federal ruling granted unmarried minors the right to purchase contraceptives.[8]
The reproductive rights movement inevitably turned its focus to restrictive abortion laws. In the 19th century, abortion was outlawed after 16 weeks of pregnancy, and by the early 20th century, it was entirely banned in many places. Despite the legal prohibitions, women continued to seek abortions, often resorting to unsafe procedures performed by unlicensed practitioners or self-induced methods, which posed significant health risks. Feminist organizations argued that the ability to control one’s pregnancy was essential for achieving gender equality. Additionally, growing concerns about overpopulation and environmental impact further underscored the importance of accessible birth control.[9]
Attitudes toward abortion became more progressive in the 20th century, and by the 1970s, the procedure had been legalized in many European countries, Japan, and the United States. The pivotal 1973 Supreme Court ruling in Roe v. Wade established federal protection for abortion rights, superseding state bans. However, restrictions on later-stage abortions remained in place. The evolution of reproductive rights has been shaped by legal battles, advocacy movements, and international agreements, reflecting an ongoing struggle for women’s autonomy and equality.
REPRODUCTIVE RIGHTS: LEGAL AND JUDICIAL PERSPECTIVES
Reproductive rights encompass various aspects of reproductive autonomy. In India, the legislative framework on reproductive rights can be categorized into six key areas:
a) The right to have or not have a child.
b) The right to access birth control measures.
c) The right to decide the number and spacing of children.
d) The right to be free from coercion, including forced sterilization and abortion.
e) The right to choose the method of childbirth.
f) The right to adequate reproductive healthcare.
Each of these rights plays a crucial role in reproductive autonomy:
a) The Right to Have or Not Have a Child: This right pertains to a woman’s choice regarding reproduction, forming the foundation of reproductive autonomy. In India, the right to not have a child has been partially recognized, with evolving legislative and judicial approaches to abortion. The Indian Penal Code (IPC) of 1860, reflecting the moral and social values of Indian society, includes provisions concerning harm to an unborn child, emphasizing the sanctity of human life.
Section 312[10] of the IPC states that anyone who voluntarily induces a miscarriage in a pregnant woman, unless done in good faith to save her life, faces imprisonment of up to three years, a fine, or both. If the woman is in an advanced stage of pregnancy, the punishment increases to seven years. The section also makes it clear that a woman who causes her own miscarriage is also considered an offender. The IPC does not explicitly use the term “abortion,” likely to avoid offending traditional sentiments. However, in common understanding, miscarriage is often synonymous with abortion, referring to the expulsion of an immature foetus before full growth. While miscarriage typically refers to a spontaneous abortion, the deliberate termination of pregnancy under Section 312 is considered a criminal offense. The law historically permitted abortion only on therapeutic grounds, primarily to save the mother’s life.
Recognizing the need for legal reforms, the Government of India in 1964 established a committee to review Section 312 and explore the possibility of relaxing abortion laws. The Indian Parliamentary and Scientific Committee, under the leadership of Lal Bahadur Shastri, proposed abortion as a remedy for contraceptive failure. That same year, the Central Family Planning Board (CFPB) recommended forming a dedicated committee to study the issue further. Consequently, the Health Ministry set up a committee under the leadership of Shantilal Shah, a CFPB member. The comprehensive report by this committee laid the foundation for the Medical Termination of Pregnancy (MTP) Act of 1971, which introduced legal provisions for abortion under specific circumstances.
THE MEDICAL TERMINATION OF PREGNANCY ACT, 1971
The Medical Termination of Pregnancy (MTP) Act, 1971, was formulated in alignment with the United Kingdom’s Abortion Act of 1967. The primary objective of this legislation was to establish a qualified right to abortion while ensuring that pregnancy termination was not recognized as a routine option for expectant mothers. The preamble of the Act states its purpose as providing for the termination of specific pregnancies by registered medical practitioners and addressing related matters.
The Act outlines specific conditions under which pregnancy termination is permissible. Section 3 of the MTP Act stipulates the circumstances under which abortion may be performed, including:
i) When there is a risk to the life of the pregnant woman or a significant threat to her physical or mental health. ii) If the pregnancy is a result of rape. iii) When there is a substantial risk that the child, if born, would suffer from severe physical or mental disabilities. iv) In cases of contraceptive failure for married couples attempting to limit family size. v) If the pregnant woman’s current or foreseeable environmental conditions pose a risk to her health.[11]
A key feature of this Act is that it prohibits the termination of pregnancy beyond twenty weeks. Subsection (2) of Section 3 sets forth additional prerequisites:
i) The termination must be performed by a registered medical practitioner. ii) If the pregnancy duration is within twelve weeks, a single registered medical practitioner can approve the procedure. iii) If the pregnancy extends beyond twelve weeks but does not exceed twenty weeks, at least two registered medical practitioners must form an opinion in good faith that: (a) Continuing the pregnancy would pose a risk to the woman’s life or cause severe physical or mental harm. (b) The child, if born, would likely suffer from severe physical or mental disabilities. The Act takes precedence over Section 312 of the Indian Penal Code (IPC). Therefore, as long as the conditions specified in Section 3 of the MTP Act are fulfilled, no legal liability arises under Section 312 of the IPC. However, any abortion conducted in violation of the Act is punishable as a criminal offense under both the MTP Act and the IPC, as they constitute separate offenses. The validity of the MTP Act was challenged before the Rajasthan High Court in Nand Kishore Sharma v. Union of India. The petition contended that Sections 3(2)(a) and (b), along with Explanation I and II, were unethical and violated Article 21 of the Indian Constitution. However, the court upheld the Act, stating that its primary purpose was to safeguard pregnant women’s lives, prevent harm to their physical or mental health, and reduce the risk of disabilities in newborns.[12]
The Supreme Court of India further examined reproductive rights in the case of Suchita Srivastava v. Chandigarh Administration. The court affirmed that a woman’s right to make reproductive choices, including the decision to conceive or not, is an integral part of personal liberty under Article 21 of the Constitution. The ruling emphasized that reproductive choices encompass both the right to procreate and the right to abstain from procreation. It also underscored the importance of respecting a woman’s privacy, dignity, and bodily autonomy, including her right to refuse sexual activity or insist on contraceptive use. Thus, the provisions of the MTP Act, 1971, serve as reasonable limitations on reproductive choices, ensuring both autonomy and legal safeguards.[13]
PRE-CONCEPTION AND PRE-NATAL DIAGNOSTIC TECHNIQUES (PROHIBITION OF SEX SELECTION) (PC AND PNDT) ACT, 2003
Another crucial piece of legislation that partially addresses reproductive rights is the Pre-Conception and Pre-Natal Diagnostic Techniques (Prohibition of Sex-Selection) Act, 2003 (PC and PNDT Act). India has a long-standing history of female infanticide. The primary objective of this Act is to prevent the misuse of medical technologies in pre-conception and prenatal care, which have been exploited in India to determine the sex of a foetus. The core principle of the PC and PNDT Act is to prohibit discrimination based on sex through any diagnostic technique, whether pre-conception, intra-conception, or post-conception. Consequently, sex-selective abortions are declared illegal under this Act. Determining the sex of an unborn child for the purpose of female feticide (aborting a female foetus) is a punishable offense, and no pregnant woman can be forced to undergo such tests. Additionally, advertising services related to pre-birth sex determination or abortion for female foeticide is strictly prohibited. Under this Act, it is presumed that if a pregnant woman undergoes such a test, she was coerced by her husband or relatives, making them liable for abetment unless proven otherwise.[14] Thus, the Act strengthens the right to give birth to a child, irrespective of its gender.
The Supreme Court of India has played a crucial role in safeguarding this right. In the landmark case of Centre for Enquiry into Health and Allied Themes (CEHAT) v. Union of India, the Supreme Court directed the Central Government to raise public awareness about sex determination and female foeticide and to rigorously implement the provisions and regulations of the PNDT Act, 1994. The court also instructed the Central Supervisory Board (CSB) to convene every six months. Additionally, in the case of Chetna, Legal Advisory WCD Society v. Union of India, the court noted that, if necessary, the National Human Rights Commission could be approached to ensure the proper enforcement of the Act. In another ruling, Centre for Enquiry into Health & Allied Themes (CEHAT) v. Union of India, the court mandated state governments to conduct surveys to prevent unregistered clinics from operating illegally.
RIGHT TO BIRTH CONTROL MEASURES
The right to birth control measures is a significant component of reproductive autonomy. This right ensures that neither the state nor any individual can interfere in reproductive decisions. Women must have the freedom to choose their preferred method of birth control without restrictions. The terms ‘Birth Control’ and ‘Family Planning’ are often used interchangeably, though they have different implications. ‘Birth Control’ refers to an individual’s choice to regulate fertility and determine family size, whereas ‘family planning’ represents state policies aimed at controlling population growth.[15]
Women worldwide possess the fundamental right to decide whether and when to have children, with access to the necessary information and resources to make informed decisions. Denying them this right infringes upon their ability to control their fertility, health, and overall well-being. Limited access to contraception and inadequate information increase the risk of unintended pregnancies, maternal mortality, and complications from unsafe abortions. In India, more than half of all abortions are unsafe, contributing to an estimated 12,000 maternal deaths annually due to clandestine abortion-related complications.[16]
This right is largely addressed through family planning services and policies. India has well-structured family planning services implemented primarily through administrative measures. The policy was formally introduced in 1976, emphasizing the promotion of family planning through political and administrative initiatives.[17]
BARRIERS TO ACCESSING REPRODUCTIVE HEALTH SERVICES
Addressing these barriers requires a comprehensive approach that integrates policy reforms, healthcare system improvements, community engagement, education, and advocacy. Efforts to enhance access to reproductive health services should emphasize equity, inclusivity, and respect for individual rights and autonomy while addressing the underlying social, economic, and cultural factors influencing health.[18]
A significant barrier is the lack of information and education. Limited access to accurate, comprehensive, and culturally appropriate information about reproductive health and rights can hinder individuals from making informed choices about their reproductive well-being. Inadequate sexuality education in schools, along with prevalent misinformation and misconceptions about contraception, family planning, and sexually transmitted infections (STIs), can lead to poor reproductive health outcomes and discourage healthcare-seeking behaviours.
Financial constraints also pose a major challenge, preventing individuals from obtaining essential reproductive health services such as contraception, prenatal care, maternal healthcare, and safe abortion services[19]. High healthcare costs, including consultation fees, diagnostic tests, medications, and hospital expenses, create substantial barriers, particularly for low-income individuals and marginalized communities. Geographical limitations, including inadequate healthcare infrastructure and the uneven distribution of medical facilities, further restrict access to reproductive health services, particularly in rural and remote areas. The scarcity of hospitals, clinics, and trained healthcare providers often results in long travel distances and additional transportation costs, making it difficult for individuals to receive essential care. Social and cultural norms, along with stigma and discrimination related to reproductive health issues such as contraception, abortion, and sexuality, can deter individuals from seeking necessary healthcare.[20] Fear of judgment, social exclusion, or even violence from family members, communities, or healthcare providers may discourage individuals—especially women and adolescents—from accessing these vital services. Gender inequality also plays a crucial role in limiting access to reproductive healthcare. Discriminatory gender norms and power imbalances can undermine women’s autonomy in making decisions about their bodies and health. Societal expectations that prioritize male authority, restrict women’s mobility, and limit their financial independence can further hinder their ability to access contraception and other reproductive health services.[21]
SPECIFIC REPRODUCTIVE RIGHTS ISSUES IN INDIA
India faces several reproductive rights challenges that stem from its diverse socio-cultural, economic, and legal landscape.
Despite governmental initiatives to promote family planning, access to a comprehensive range of contraceptive methods remains limited, particularly in rural and underserved areas. Factors such as financial constraints, lack of awareness, cultural norms, and gender biases contribute to low contraceptive usage, leading to unintended pregnancies.
Unsafe abortions remain a pressing public health issue, significantly impacting maternal morbidity and mortality. Restrictive abortion laws, limited access to safe abortion services, societal stigma, and misinformation often force women to resort to unsafe procedures, endangering their health and lives.
A deeply ingrained preference for sons has fuelled sex-selective practices, including sex-selective abortion and female infanticide. Despite legal prohibitions, gender-based discrimination persists, resulting in skewed sex ratios, especially in certain regions of the country.
India continues to grapple with high maternal mortality rates due to inadequate access to maternal healthcare, poor quality of medical services, delays in seeking care, and socio-economic inequalities. Strengthening maternal healthcare infrastructure, ensuring skilled birth attendance, and improving emergency obstetric care are crucial to addressing this issue. Although child marriage is illegal, it remains prevalent in many parts of the country, particularly in rural and marginalized communities. Early marriage often leads to adolescent pregnancies, increasing health risks for young girls, including pregnancy-related complications and limited opportunities for education and economic independence. Gender-based violence—including domestic violence, sexual assault, and marital rape—continues to be a major concern, severely affecting women’s reproductive rights. Fear of violence may prevent women from seeking reproductive healthcare or making autonomous choices about their bodies. Additionally, limited access to comprehensive sexuality education in schools contributes to misinformation about reproductive health, contraception, consent, and healthy relationships. Providing young people with comprehensive sexuality education is vital to fostering informed decision-making, preventing unintended pregnancies, and addressing gender-based violence.
DISCOURSE ON REPRODUCTIVE RIGHTS IN INDIA
The right to bodily autonomy is fundamental to the broader movement for gender equality and women’s empowerment. In India, reproductive rights encompass several key aspects, including access to contraception, safe abortion, maternal healthcare, and protection from forced sterilization or coerced pregnancies.
Advocacy and awareness initiatives play a vital role in safeguarding and promoting reproductive rights. These efforts aim to educate people on reproductive health, challenge societal stigma and discrimination, empower women to make informed choices about their bodies, and push for policy changes to address systemic barriers to reproductive healthcare.
- Promotion of Contraception and Family Planning: Advocacy campaigns emphasize the need for comprehensive access to various contraceptive methods and family planning services. These initiatives focus on ensuring individuals can make informed decisions regarding their reproductive choices while reinforcing reproductive autonomy.
- Safe Abortion Awareness: Campaigns work to combat the stigma surrounding abortion, educate the public on the legal provisions governing abortion in India, and promote access to safe, high-quality abortion services. They also highlight the importance of post-abortion care and counselling.
- Maternal Health Advocacy: Efforts in this area aim to enhance maternal healthcare services, including prenatal care, skilled birth assistance, emergency obstetric care, and postnatal support. These initiatives seek to lower maternal mortality and morbidity rates by promoting timely healthcare-seeking behaviour and addressing systemic obstacles in accessing maternal healthcare.
- Gender Equality and Reproductive Justice: Advocacy efforts focus on advancing gender equality, challenging patriarchal norms, and advocating for reproductive justice for all individuals, regardless of gender identity, sexual orientation, caste, class, or disability. These initiatives strive to create a more inclusive and equitable society where everyone has the right to make autonomous reproductive decisions.
CHALLENGES AND LIMITATIONS
Despite ongoing advocacy and awareness campaigns, several significant challenges continue to hinder the protection of reproductive rights and the promotion of bodily autonomy in India:
- Entrenched Patriarchal Norms: Deep-seated patriarchal beliefs shape societal attitudes toward women’s rights and roles, often limiting their autonomy and ability to make independent decisions about their reproductive health.[22]
- Legal and Policy Restrictions: Regulatory limitations, such as the gestational cap under the Medical Termination of Pregnancy Act and the absence of comprehensive legislation on reproductive rights, create obstacles to accessing safe and legal abortion services and holistic reproductive healthcare.
- Healthcare Access Inequality: Unequal access to healthcare, particularly in rural and underserved regions, prevents many women from obtaining essential reproductive health services, including contraception, safe abortion, and maternal care.[23]
- Stigma and Discrimination: Persistent stigma surrounding reproductive health topics such as abortion, contraception, and sexuality leads to social exclusion, discrimination, and reluctance to seek necessary healthcare services.
- Intersectional Disparities: Socioeconomic and cultural factors such as caste, class, religion, and disability intersect with gender inequalities, further restricting access to reproductive healthcare and rights for marginalized communities.[24]
Overcoming these challenges requires continuous advocacy, legal reforms, community engagement, and coordinated efforts across multiple sectors to advance gender equality, reproductive justice, and bodily autonomy for all individuals in India.
CONCLUSION
Reproductive rights and bodily autonomy are fundamental to achieving gender equality and empowering women in India. While there has been progress in acknowledging and safeguarding these rights, numerous challenges remain, including legal constraints, deeply ingrained socio-cultural norms, disparities in healthcare access, and overlapping inequalities related to caste, class, religion, and disability.
To ensure reproductive rights and bodily autonomy for women, a comprehensive approach is necessary one that dismantles systemic barriers while fostering an environment that upholds women’s dignity, agency, and freedom to make informed choices about their reproductive health. Strengthening advocacy efforts, increasing awareness, implementing policy reforms, and engaging communities are essential steps toward overcoming stigma, discrimination, and patriarchal norms that continue to restrict these rights.
[1] Banerjee, A., Ghosh, S., & Das, P. (2019). Unsafe abortions in India: Challenges and policy recommendations. Journal of Public Health Policy, 40(2), 223-235.
[2] Basu, R., & Roy, S. (2019). Contraceptive access and barriers in rural India. Reproductive Health Journal, 16(1), 112-124.
[3] Choudhury, M. (2021). Legal challenges in reproductive rights implementation in India. Indian Law Review, 5(3), 45-67.
[4] Mohr, J. C. (1978). Abortion in America: The Origins and Evolution of National Policy, 1800-1900. Oxford University Press.
[5] Garg, P., & Sinha, K. (2020). Medical practitioners’ perceptions on abortion laws in India. Indian Journal of Medical Ethics, 25(4), 55-69.
[6] Connelly, M. (2008). Fatal Misconception: The Struggle to Control World Population. Harvard University Press.
[7] Eisenstadt v. Baird, 405 U.S. 438 (1972).
[8] Mohr, J. C. (1978). Abortion in America: The Origins and Evolution of National Policy, 1800-1900. Oxford University Press.
[9] 97Roe v. Wade, 410 U.S. 113 (13).
[10] Indian Penal Code,1860
[11] Medical Termination of Pregnancy Act, 1971, Section 3(2)(i)
[12] Nand Kishore Sharma v. Union of India, AIR 2005 Raj 114.
[13] Suchita Srivastava v. Chandigarh Administration, (2009) 9 SCC 1.
[14] Ibid., Section 24.
[15] Ministry of Health and Family Welfare, National Population Policy, 2000.
[16] Guttmacher Institute, Abortion & Maternal Health in India: Key Statistics, 2017.
[17] Government of India, Family Planning Programme of India: Historical Perspective, 1976.
[18] World Health Organization (WHO), Sexual
[19] The Lancet Global Health, Barriers to Reproductive Health Access in Low-Income Communities, Vol. 8, Issue 3, 2021.
[20] Human Rights Watch, Stigma and Barriers to Reproductive Healthcare in South Asia, 2018.
[21] World Bank, Economic Constraints on Women’s Access to Healthcare, 2019.
[22] United Nations Population Fund (UNFPA), Gender Norms and Reproductive Autonomy in India, 2020.
[23] Ministry of Health and Family Welfare, Rural Healthcare Accessibility Report, 2019.
[24] Center for Reproductive Rights, Intersectionality and Reproductive Health Barriers in India, 2020.