LGBTQIA+: CONVICTION OVER CONVENTION

Lavanya Bhatt and Prerna Dimri

ABSTRACT

Every successful organization has to undergo years of struggle to establish itself to bring about the change it always wished for. LGBTQIA+, which describes someone's “gender identity" or “sexual orientation” is one such example of a community that walked down a long road to equality. Inter-sex relationships and marriages were criminalized in laws for several years. During all this time, the community had to face atrocities like harassment, discrimination, violence, assault, etc. But their struggles for so many years made a mark on the world. Masses joined hands with them and raised voice in support of the community and finally achieved a historical victory when Section 377 was de-criminalized and the discrimination against the community was laid to peace. After this LGBTQIA+ affairs were paid special attention to, both legally and socially. Today, they are not only supported in huge numbers but also their spirit and identity are celebrated in the form of Pride Months and Parades. Although the society still expresses its concerns over gay parenting and other related matters, yet today there has been an enormous reach of the community, encouraging everyone via different platforms. In addition, International Forums have been set up to help the community spread its word. The long-led struggles and hardships finally yielded them their recognition in the society and this fight became an inspiring tale for the whole world. This article also talks about how the third gender prevailed in early civilizations and realms, also quoting various religious texts which predominantly shape our minds. Furthermore, it helps us understand how we as a part of the society can do our bit to resolve the persisting problems. This article is an ode to the LGBTQIA+ community, for their consistent struggle for identity, acceptance and a better tomorrow, not only in India, but all over the globe.

“We declare that human rights are for all of us, all the time: whoever we are and wherever we are from; no matter our class, our opinions, our sexual orientation.”

~ Ban Ki-moon, former UN Secretary-General

INTRODUCTION

As we unfold the pages of history, we come across words like 'motsoalle', two-spirited, ‘ostraca'. Ancient history and varied civilizations have accorded the evident existence of 'homoeroticism’ prevailing over all realms and generations. All primordial cultures have stories of "neither male nor female, but instead someone with two-souls" to tell, all narrowing it down to the existence of a Third Gender. Gradually, down the years when it was felt that the rights of this third gender were being neglected, a community was formed and established to aid these people with the support they desired. Today, we know this community as the LGBTQIA+ community. With its ubiquitous influence being felt all across the globe, it has been successful in bringing about a change in the lives of many, who were confused and faced a loss of their identity and sought hands for support. LGBTQIA+ by definition is the abbreviation for "lesbian, gay, bisexual, transgender, and queer, or questioning, intersex and asexual or allies". They have existed as long as humanity itself. These terms are used to define someone's “gender identity" or “sexual orientation”.

Initially, India had no laws to protect the LGBTQIA+ community. Later, on the 6th of September, 2018, a change was brought by abolishing the historic legacy of Section 377 of the Indian Penal Code adapted from British colonial rule, when the Supreme Court of India ruled that consensual homosexual act would no longer be considered a crime. The judgment, Navtej Singh v. Union of India is considered as the Landmark Judgement of such cases. [1]

It is important to know what Section 377 is, and what was the need to abolish it. Section 377 of the Indian Penal Code, which came into force in the year 1862, criminalizes a segment of people for being a part of the sexual minority.  No action was taken, even though the 172nd report of the Law Commission of India counselled the elimination of Section 377. In December 2013, it upheld the criminalization of gay sex while refusing the LGBTQIA+ community their universal right to sexual orientation, sexuality, and choice of a companion. Several people stood up and raised their voices against it. They wished for protection under sexual minorities and the recognition that every other human being received. They argued that Section 377 brought out discrimination based on sex and also restrained them from their fundamental rights. Thus, to provide them with equal rights and recognition, Section 377 was abolished by the Supreme Court of India.

The change did not happen overnight. In India, it took almost 70 years and two-decades-long battles against the law to prune this old age law that harassed and exploited the ones who decided not to give up and fight for the recognition of their gender and sexuality.

THE JOURNEY

The strength of the LGBTQIA+ community is represented by its rainbow flag that symbolizes unity in diversity and the power of light, enlightenment, and progress. The first rainbow flag for LGBTQIA+ was designed by a famous artist Gilbert Bakerback in 1978 who openly claimed to be a gay and drag queen. Harvey Milk,one of the first openly gay elected officials urged him to create a symbol of pride for the third gender community. Baker saw the flag as a powerful emblem of dignity, honour, and power. He wanted the flag to be as natural as the preference of one's sexual orientation and hence he chose 8 different colours, each representing its own unique aim. The first version of this flag was flown on June 25, 1978, for San Francisco Gay Parade. After which Baker wanted to mass-produce the flag for consumption by all. However, due to the shortage of material production, turquoise and pink were eliminated whereas indigo was replaced by the primary blue which merged as the contemporary six-striped flag consisting of red, orange, yellow, blue, green, and violet. The varied vibrant colour came together to reflect the idea of unity of the LGBTQIA+ community. [2]

Even back in the year 1900s, there was an ongoing struggle for an identity for the third gender. People like Oscar Wilde, Alan Turing, Barney Frank, Troy Penny, and many other well-known and unknown people were haunted by anti-LGBTQIA+ laws, and many jurisdictions repented. They kept on playing their parts and did everything possible, for their community leaders, even though they were arrested, harassed, and sent to jail for voicing out their opinions on this matter. Regardless of all the hatred and hardships they faced, they never gave up on the struggle and did their bit to bring out the change they desired.

Although they are no longer with us, their magnanimous efforts have left a legacy behind that we follow today. LGBTQIA+ members like Michelle Douglas, Brent Hawkes, Laxmi Narayan Tripathi, Ashok Row Kavi, Gauri Sawant, and many more activists have always been at the forefront of the movements, joined by people in a huge number from all generations, doing their bit in making the society a better place for the LGBTQIA+ community. [3]

From running NGOs, representing cases in the apex courts, to conducting various campaigns for encouraging them. They all have a story to tell and an initiative to lead and have continued to play that role in all possible ways. Not only have NGOs organized initiatives, but also an International Forum has been established that brings together more than 1,300 LGBTQI+ groups from around the world. It is called The International Lesbian, Gay, Bisexual, Trans and Intersex Association (IGLBTIA or ILGA). Formed almost 42 yearsago, it still plays an active role in campaigning for LGBTQIA+ rights and civil rights, regularly petitioning the United Nations and governments of its ally countries. They are represented in 140+ countries and have been accredited by the United Nations, for NGO Ecosoc consultative status. [4]

With all the support and awareness, the LGBTQIA+ community has been successfully making its way through heterosexist and societal bigotry towards a more empowered future. Social Media on the other hand has efficiently portrayed a constructive role in invigorating people, unifying and helping them recognize their strength. The widespread yet powerful reach of the social media influencers has had a puissant impression on the lives of many, especially the ones who initially hesitated to open up themselves without the fear of being judged. Priyanka Paul, Durga Gawde, Dr. Trinetra Haldar Gummaraju, Anwesh Sahoo are one of the few names who have been proudly sharing and encouraging others through the story of their life. They have successfully broken the glass ceiling and proved that knowledge, education, and skill are greater than any traditional faiths and beliefs. [5]

CHAIN OF EVENTS IN SUPPORT OF THE COMMUNITY [6]

People of the LGBTQIA+ community have been through a lot of struggles and operations for centuries. The “Buggery Act” of the 1500s during the period of Henry VIII was, in fact, an infamous anti-homosexuality law. Many people came forward to declare themselves bisexuals in the 1970s. A statement named “Ithaca Statement on Bisexuality” was issued and the formation of the “National Bisexual Liberation Group” took place in the year 1972, followed by the opening of “San Francisco Bisexual Centre” in the year 1976. Inspired by the “Gay Liberation Movement” of the early 1700s, a movement that portrayed gays and lesbians as a minority emerged. Back in 1974, the first MP of the Labour Party in the UK was Maureen Colquhoun, who was then a part of heterosexual marriage. Several others came out openly, like Tony Whitehead (gay trainee), Anita Bryant (Former Miss America Contestant and orange juice speaker), Diane Felix (DJ), etc. Various books were written, protests and movements took place, events were covered in newspapers and magazines. A conference named the “War Conference” consisting of 200 gay leaders was held in Virginia in the year 1988. The closing statement of the campaign called for an annual planning conference and a media campaign. This event is considered as the origin of National Coming Out Day by the Human Rights Campaign. The first Gay Pride March was held on June 24, 1994, in the Philippines. The 1900s witnessed several LGBT youth movements, alliances, and activism. The Hijras also campaigned for recognition as the “third gender” in India. The Netherlands was the first country to allow same-sex marriage in 2001, followed by Belgium in 2003, and Canada and Spain in 2005. As of 2021, same-sex marriages are allowed in various other Nations, Iceland being the first to legalize it in the year 2010, with a unanimous vote count of 49-0. In India, on 6 September 2018, consensual gay sex was legalized by the Supreme Court.

THE ALAN TURING LAW [7]

Alan Turing was the person behind the shortening of World War II by four years. He broke the “Enigma Code” responsible for decrypting Nazi messages. He was gay at a time when homosexuality was illegal in Britain. He started his relationship with his gay lover, Murray. After he filed a report of a burglary at his house and acknowledged his sexual relationship with Murray, both men were charged with “Gross Indecency” and were convicted under Section 11 of Criminal Law Amendment Act 1885. Turing pleaded guilty and also tried injecting female hormones by chemical castration. He was rendered impotent and was debarred from continuing his work with GCHQ. He killed himself, using cyanide poison, though the reports filed suggest that his death was an accident. During those days, around 75,000 gay men were convicted under the Sexual Offenses Act. [8]

“Turing Law”, formally known as “The Policing and Crime Act 2017”was passed to introduce “statutory pardon for the men convicted historically for their sexuality.” Alan Turing was officially pardoned in the year 2013 after the Queen signed the Act. Thousands of dead gay men, who were convicted under such laws against homosexuality were granted “automatic pardon” after the implementation of this new Law in the year 2017. [9]

THE SIRAS ACT

This Act is a law to accord an “ex post facto pardon” to all those who were sentenced for committing a crime under Section 377 of the Indian Penal Code (IPC) would do poetic justice to the LGBTQIA+ community and Professor Ramchandra Siras. A biographical drama film titled “Aligarh'', based on this act and directed by Hansal Mehta was released on February 26, 2016. [10]

Prof. Ramchandra Siras was an Indian linguist, an author, and a professor at “Aligarh Muslim University”. On the 8th of February, 2010, two men from a local TV channel’s crew broke into his house and caught him having consensual sex with another man. The case was reported, and on the 9th of February, he was debarred by the AMU for “gross misconduct”.

The case was taken to the Allahabad High Court, where it was fought on the premise that Siras could not be penalized under “Section 377” which then criminalized homosexuality. The case was exacerbated by the “involvement of students in the covert taping and ambush of Siras and his lover”.

Siras got his job and accommodation back, till his retirement. But, later in the month of April 2010, he was found dead at his apartment in Aligarh. The police found traces of poison and suspected suicide. Later, it was found out that it was a “case of murder” involving six individuals. Although on April 19, it was stated by the Superintendent of Police that “three journalists and four officials” of AMU were a part of the crime, the case was closed due to lack of evidence. [11]

This case and the mysterious death of Professor Siras raised questions of shame and justice. R. Raj Rao has rightly pointer that, “homosexuality has always been looked upon with disfavour by three agencies universal to mankind: religion, law, and medicine. Among them, the law committed the unkindest cut of all”.

Siras’s case, on the lines of the famous Alan Turing Law, continued to be a reminder for the law to push its viewpoints in the line of justice. In a democracy, individuals ought to reserve the option to have intercourse, thoughts, and qualities as indicated by their human dispositions. Acts of prejudice that incite disdain violations and push individuals towards death should be reclaimed by the law. Until then, justice cannot reach the victims of endless violence.

THE TRANSGENDER PEOPLE (PROTECTION OF RIGHTS) BILL, 2019 [12]

This bill was passed to “provide transgender people the protection of their rights and their welfare and for matters connected therewith and incidental thereto”. The transgender community vehemently rejected the bill citing some of the provisions as an infringement of their fundamental rights. This includes the various points:

  1. The infringement of their right      to determine their sexual orientation.

  2. The punishment for ‘sexual      abuse against transgenders’ was only 2 years, whereas for any sexual abuse      against a female the punishment is up to 7 years.

  3. The bill neglected the malignancy and      acts of barbarity that transgenders encounter within their own family.

  4. The bill seeks to provide      ‘inclusive education and opportunities’ but fails to lay down a concrete      plan for achieving the same.

The Bill, in other words, further exposed them to oppression and discriminated against them based on their sexualities.

EVOLUTION OF LGBTQIA+ [13]

1. Naz Foundation Govt. v. NCT of Delhi (2009): The judgment of Delhi High Court, in this case, held that Section 377 pressed unreasonable restriction on two adults engaging in consensual sexual intercourse in private and thus violated their fundamental rights under “Articles 14, 15, 19 and 21” of the Indian Constitution.

2. Suresh Kumar Koushal vs Naz Foundation (2013): After fighting for eight long years, finally when the community felt a sigh of relief, the Supreme Court of India, in this case, overturned the judgment of the Delhi High Court and re-criminalized Section 377. This decision resulted in an upsurge of activism in India.

  1. National Legal Services Authority v. Union of India      (2014): In simple words, the Supreme Court in this landmark      judgment, gave the hijras or      transgenders an identity of “third gender” for education, healthcare,      employment, and other facilities.

4. K.S. Puttaswamy v. Union of India (2017): The Judgement, in this case, observed that sexual orientation also falls within the ambit of the right to privacy under Article 21 of the Constitution of India. It sparked hope amongst the queer community that Section 377 would be soon struck down by the court.

  1. Navtej Singh Johar v. Union of India (2018): Under this judgment on      September 6, 2018, the Supreme Court of India finally rationalized Section      377 as vague and an infringement of human rights. The Supreme Court also      directed the Government to spread awareness to eliminate this stigma.

CONCERNS OF THE SOCIETY

Time and again there has been a huge difference of opinions about whether the Third gender parents are competent enough to adopt and raise a child to the best of their interest. There have been arguments across the world stating how a child raised by gay or lesbian parents may hinder their frame of mind and lack appropriate role models. They believe that this is against the law of nature, and how even the bible states it as a sin. Some even claiming that children would grow up to be lesbian or gay themselves. The school of thought encouraging transgression against the LGBTQIA+ rights has always existed in all societies but the community itself decided to never give up and constantly fought for their rights.

LGBTQIA+ movements have been opposed by several people and organizations. Some say that granting them the right to marry within the same sex would unnaturally increase the chances of polygamy and unhealthy behaviour. Many proponents have even claimed that educating about sexuality in schools would inculcate immoral values in children.

PRESENT SCENARIO

In the past few years, we have witnessed a growth in the mindset of the people. The number of people in support of the LGBTQIA+ is increasing. Studies suggest that this shift is a result of the younger generation taking over the less supportive and orthodox older generations. Many people who identify themself with the LGBTQIA+ community are coming out fearlessly, and being supported by famous personalities of all fields. Also, growing numbers of LGBTQIA+ community characters on television and movies address and promote the community. Today, many developed nations like the United States, Canada, and Australia have come forward and helped people identify the LGBTQIA+ Community, offering them equal opportunities and equal rights and celebrating them in every colour of the rainbow. [14]

India is considered as one of the most democratic nations whose Constitution's diversity and laws have put a step forward in recognizing the third gender and helping them rise above social discrimination of being identified as incapacitated, thus, bringing everyone under its umbrella of justice. In a recent case on June 7, 2021, Madras High Court made a ground-breaking judgment in favour of the LGBTQIA+ community issuing guidelines for creating a safe and healthy environment for them, ensuring that they are not persecuted by the police or any other sentinels of law during investigations of missing people filed by the parents or people from the society. The high court bench of Justice Anand Venkatesh has been helped to gain insight on this matter by a psychologist and members of the LGBTQIA+ community itself to deliver an informed judgment. The court has directed the Union Ministry of Social Justice and Empowerment to approach the LGBTQIA+ communities in order to facilitate safeguarding and shielding their rights. [15]

The current status proves how these years of struggle across the globe have helped them gain an identity, strength, and the confidence to proudly accept themselves as who they are. They have gained recognition not only in our country but in almost 131 countries all over the globe. [16]

The pride of LGBTQIA+ is celebrated in different countries in the form of Pride Month. The purpose is to “recognize the impact that lesbian, gay, bisexual, and transgender individuals have had on history locally, nationally, and internationally.” Pride month is celebrated in different months in different countries, representing the significant development of their LGBTQIA+ community. June is marked as pride month in many countries including India, marking the commemoration of the Stonewall riots, which occurred at the end of June 1969 in the US that left a significant impact on the world. [17]The month features an assortment of occasions – everything from gatherings and shows to workshops and learning openings. Huge city marches, however, are by and large the most noticeable components of LGBT+ Pride Month. The rainbow flag is displayed throughout the month. Even in the Covid 19 Pandemic, it was celebrated through virtual workshops, talks, virtual parades, etc. All these celebrations are dedicated to the LGBTQIA+ community and their right to live a dignified life. It is all about teaching acceptance, equality, education about pride, history, above all, love. The events serve as a demonstration of legal rights such as consensual intercourse, same-sex marriage, also, self-acceptance, achievements, and pride. In India and South Asia, the first pride walk took place in Kolkata on 2 July 1999. It was named “The Friendship Walk ''. Kolkata was chosen as the venue of the first pride walk because of its history of movements for human and political rights. The walk represents a voice for the equality of all. Some of the pride parades called “pride festivals” are even sponsored by the government of the country and corporate sponsors to promote tourist attractions.

However, even today in few parts of the world, the LGBTQIA+ community is still struggling against “violence, workplace discrimination, housing discrimination, unequal healthcare, criminal justice, and even some basic human rights”. Gender and sexual minorities everywhere across the world are intensely affected by the mentalities as well as convictions of people who surround them. Low degrees of acknowledgment are attached to tormenting and savagery, emotional and physical well-being issues, and underrepresentation in places of community initiative. Furthermore, exclusion can bring about lower levels of workforce usefulness and diminished business benefits. In the Supreme Court’s judgment, it was held that consensual homosexual relationships cannot be considered a crime under the Indian Constitution scheme and therefore had a limited scope. India lacks a comprehensive and anti-discrimination code. The movements going on in the support of the LGBTQIA+ community is quite old, but it did not succeed in becoming cohesive and even after 2 years, battles prejudice.

SUGGESTIONS AND PROPOSALS [18]

LGBTQIA+ activists, after struggling and dealing with numerous hardships have reached a huge milestone. Below mentioned are some suggestions to achieve LGBTQIA+ equality at a greater level.

  1. Increasing the activism for supporting the community.

  2. Leadership and essential support from the UN for LGBT rights      overseas.

  3. Involving parents of LGBTQIA+ people to educate them and stop the      hesitation of coming out in fear of family loss.

  4. Western governments can sometimes interfere wherever required and      essential.

  5. Teaching the context in informative ways to understand hardships      faced by the community.

  6. Standing up against Homophobia, to tackle bullying cases.

  7. Integration of LGBTQIA+ topics in the curriculum, so that students      can have authentic learning about the world around them.

  8. Making sure that the school is inclusive, safe, and affirming for      LGBTQIA+ youth.

  9. Stop the violence around the world. Works to prevent violence      against the community needs to be carried out.

  10. Use of the TV and Film industry to spread the word in a faster and      efficient way. Media advocacy is a flexible and efficacious tool to reach      mass audiences and grow acceptance.

  11. Use of courts to deal with the discriminations faced and to summon      the laws and policies that encourage discrimination.

  12. Creative ideas like art, culture, dialogues, and media campaigns      can help in increasing acceptance.

  13. Credit and acknowledge the efforts of activists and social workers      for their works in progressing the rights for their local or national      LGBTQIA+ communities.

CONCLUSION

Throughout the history of Hindu and Vedic texts, we find narratives of 'demigods', saints, and even the Supreme Lord surpassing gender norms and manifesting multiple mixtures of gender and sex. Several instances of same-sex depictions and Union of God and goddesses have been found in the much famous and appreciated ancient Indian poetry essays. One of the Vedic Sutra, "Kamasutra" affirms and recognizes same-sex relations and several other temples have carvings depicting both woman and man engaging in homosexual acts. Even much later, during different empires across the world, it was common to see Kings having male sexual partners, who appeared feminine-like or functioned roles that were routinely carried out by women and were often referred to by the term 'Mukhannathun' meaning "ones who resemble women". The third gender was considered privileged with two-spirit that held the symbolic value as the incarnation of another form of Lord Shiva, "Ardhanarishvara", which means "the Lord whose half is a woman". This form is a union of Lord Shiva and his wife Parvati that gives birth to a completely new avatar. The Third Gender was believed to have miraculous powers, commonly said "strength of a man yet graceful like a woman”. These examples have been brought to your notice as proof that the Third Gender is not a novice concept and that it has prevailed in all civilizations. [19]

Looking at the present-day scenario, there has been enormous growth and advancements in LGBTQIA+ Rights around the world and locally. The situation of the community acts as a good litmus test of the current scenario of human rights in the country unequivocally on the grounds that it is a particularly vulnerable minority. Numerous large-scale changes in society have navigated a major part of the significant acknowledgment of LGBT rights, like more impartial relations between sexual orientations and the more prominent regard for individual autonomy. We have witnessed the LGBT population steadily coming out, so individuals unexpectedly found that a gay-sibling, child, neighbour, or close associate lived by, which began forming public discernment and supported the social changes.

Being Lesbian, Gay, Trans, Bi, Inter, is not a “problem”, instead, it is a part of one's "identity", and they have the right to make choices for themselves, be it their desire to dress a certain way or their gender preference. Article 15 of the Constitution of India prohibits discrimination on the grounds of religion, race, caste, sex, or place of birth.LGBTQIA+ Community has the same rights as that of every other individual. It has never been about what any religion, customs, or traditions say, but has always been a matter of humanity. All we need is understanding, tolerance, laws, and policies that will protect everyone’s dignity and a world where people can enjoy their basic human rights irrespective of the choices they make. [20]

REFERENCES

  1. Mahapatra, D., 2014. Supreme Court recognizes transgenders as 'third gender' | India      News - Times of India. [online] The Times of India. Available at: https://timesofindia.indiatimes.com/india/supreme-court-recognizes-transgenders-as-third-gender/articleshow/33767900.cms     [Accessed 14 June 2021].

  2. McAndrews, M., 2018. Historic LGBTQ activists and artists who changed the world.      [online] Culture. Available at:

https://www.nationalgeographic.com/culture/article/historical-lgbt-figures-activists-culture[Accessed 14 June 2021].

  1. Roth, K., 2015. LGBT:      Moving Towards Equality. [online] Human Rights Watch. Available at: https://www.hrw.org/news/2015/01/23/lgbt-moving-towards-equality [Accessed 14 June 2021].

  2. Armbrecht, A., 2016. Explainer: the state of LGBT rights today. [online] World      Economic Forum. Available at:

  3. https://www.weforum.org/agenda/2016/01/explainer-the-state-of-lgbt-rights-today/ [Accessed 14 June 2021].

  4. Srivastava, T., n.d. Homosexuality in India. [online] Legalservicesindia.com.      Available at: http://www.legalservicesindia.com/articles/h1omo.htm     [Accessed 14 June 2021].

[1] Rajagopal, K., 2021. What is Section 377, and why does it matter? [online] The Hindu. Available at:

https://www.thehindu.com/news/national/what-is-section-377-and-why-does-it-matter/article24483691.ece#:~:text=Section%20377%20criminalises%20a%20section,inherent%20in%20all%20human%20beings [Accessed 4 June 2021].

[2] Gonzalez, N., n.d. How Did the Rainbow Flag Become a Symbol of LGBTQ Pride? [online] Encyclopedia Britannica. Available at:https://www.britannica.com/story/how-did-the-rainbow-flag-become-a-symbol-of-lgbt-pride[Accessed 8 June 2021].

[3] Menjiver, J., n.d. 11 Young Activists Leading the Way for LGBTQ+ Equality. [online] DoSomething.org. Available at:

https://www.dosomething.org/us/11-young-activists-leading-the-way-for-lgbtq-equality [Accessed 8 June 2021].

[4] Ilga.org. n.d. The International Lesbian, Gay, Bisexual, Trans, and Intersex Association | ILGA. [online] Available at: https://ilga.org/ [Accessed 9 June 2021].

[5] Senzee, T., n.d. 20 LGBTQ People Who Changed the World. [online] Advocate.com. Available at: https://www.advocate.com/world/2016/7/08/20-lgbt-people-who-changed-world#media-gallery-media-1 [Accessed 10 June 2021].

[6]En.wikipedia.org. 2021. LGBT social movements - Wikipedia. [online] Available at: https://en.wikipedia.org/wiki/LGBT_social_movements#LGBT_rights_movement_(1972%E2%80%93present) [Accessed 4 June 2021].

[7] Tahir, T., 2019. Alan Turing: How the mathematician and computer scientist helped win WW2. [online] The Sun. Available at: https://www.thesun.co.uk/news/8174744/alan-turing-how-the-mathematician-and-computer-scientist-helped-win-ww2 [Accessed 4 June 2021].

[8] Hodge, H., 2021. How Alan Turing helped win WW2... before being persecuted for his sexuality. [online] The Sun. Available at: https://www.thesun.co.uk/news/2013875/who-alan-turing-gay-how-die/ [Accessed 14 June 2021].

[9] Napley, K., 2020. Disregarding Convictions - the Turing Law and its limitations | Lexology. [online] Lexology.com. Available at: https://www.lexology.com/library/detail.aspx?g=2efa4a6d-717e-44cd-a28e-c922bc72eafc [Accessed 5 June 2021].

[10] Rajagopal, K., 2021. What is Section 377, and why does it matter? [online] The Hindu. Available at:

https://www.thehindu.com/news/national/what-is-section-377-and-why-does-it-matter/article24483691.ece#:~:text=Section%20377%20criminalises%20a%20section,inherent%20in%20all%20human%20beings [Accessed 4 June 2021].

[11] En.wikipedia.org. 2021. Ramchandra Siras - Wikipedia. [online] Available at: https://en.wikipedia.org/wiki/Ramchandra_Siras [Accessed 14 June 2021].

[12] 2019. The Transgender People (Protection of Rights) Act 2019. [online] Available at: http://socialjustice.nic.in/writereaddata/UploadFile/TG%20bill%20gazette.pdf[Accessed 5 June 2021].

[13] Rai, D., 2021. Evolution of LGBT Rights in India and taking the narrative forward. [online] iPleaders. Available at:

https://blog.ipleaders.in/evolution-of-lgbt-rights-in-india-and-taking-the-narrative-forward-living-free-and-equal/ [Accessed 4 June 2021].

[14] R. Flores, A., 2014. National Trends in Public Opinion on LGBT Rights in the United States - Williams Institute. [online] School of Law, Williams Institute. Available at:

https://williamsinstitute.law.ucla.edu/publications/trends-pub-opinion-lgbt-rights-us/ [Accessed 5 June 2021].

[15] SP, B., 2021. In historic order, Madras HC gives guidelines against discrimination of LGBTQI+ people. [online] The News Minute. Available at:

https://www.thenewsminute.com/article/historic-order-madras-hc-gives-guidelines-against-discrimination-lgbtqi-people-150236 [Accessed 6 June 2021].

[16] R. Flores, A., 2014. National Trends in Public Opinion on LGBT Rights in the United States - Williams Institute. [online] School of Law, Williams Institute. Available at:

https://williamsinstitute.law.ucla.edu/publications/trends-pub-opinion-lgbt-rights-us/ [Accessed 5 June 2021].

[17] Windor, M., 2021. LGBT Pride Month 2021: What to know about its history, events, parades. [online] ABC News. Available at: https://abcnews.go.com/US/lgbt-pride-month-2020-history-events-parades/story?id=71017699 [Accessed 6 June 2021].

[18] The Guardian. n.d. 13 steps to greater LGBT equality. [online] Available at: https://www.theguardian.com/global-development-professionals-network/2016/feb/16/13-steps-to-greater-lgbt-equality [Accessed 14 June 2021].

[19] En.m.wikipedia.org. n.d. Hinduism and LGBT topics - Wikipedia. [online] Available at: https://en.m.wikipedia.org/wiki/Hinduism_and_LGBT_topics [Accessed 14 June 2021].

[20] En.m.wikipedia.org. n.d. LGBT rights in India - Wikipedia. [online] Available at: https://en.m.wikipedia.org/wiki/LGBT_rights_in_India [Accessed 14 June 2021].