By Akshita Mishra, CNLU Patna
Editor’s Note: A lot of jurisprudential ink has flown in the attempt to afford the necessity for the protection of the children and maintaining the best interest of them and the society, at large. Undoubtedly, the tender age requires special treatment and the same raises significant questions with regard to the juvenile justice system in India. The author, in this paper, attempts to elucidate on this issue highlighting the various provisions in the Juvenile Justice Act, analyzing the flaws in the law and the gross violation in its implementation. She highlights the necessity of juveniles being treated properly by the enforcement agencies including the police officials and authorities at the remand home. Finally, in the light of the international perspective, she submits certain necessary suggestions that may seen indispensable in the contemporary scenario.
The dynamics of Juvenile offenders is completely different from that of other offenders. The role of the police officer in the Justice system is noteworthy and has an evident impact on the juvenile. Our paper seeks to bring out the various facets of Juvenile Justice System, emphasizing particularly on the role of Police interacting with the Juvenile offender/accused. The paper shall also deal with the legislation and the implementation, analyzing the flaws in the law and the gross violation in the implementation of the rights that take place die in Diem. 21st Century India faces umpteen number of challenges in the promulgation and safeguarding the interest of a Juvenile offender or accused as the case may be.
Some glaring issues which our paper emphasis on is farcical implementation of Juvenile Justice Act leaves much to be desired. The researchers have used doctrinal method of research, carrying out qualitative as well as quantitative data analysis, triangulating on major empirical sources. The researchers feel that there is an urgent need for us to fight against all that is degrading and demeaning our society today, for only and only then will we give our children something to fight for tomorrow. The need of hour is to identify the venerable group, create awareness and to educate the young population of India. The educated need to aware the uneducated, for the lack of awareness is a major challenge. The researchers have tried to address the issues subsequently identifying the strategies to deal with the same.
JUVENILE JUSTICE ACT: AN OVERVIEW
A ‘juvenile’ or a ‘child’ refers to a person who is yet to complete eighteen years of age. As per the definition given by Juvenile Justice Act, 2000 under section 2(k), a boy or a girl under 18 years of age is a juvenile[i]. The first contact that an immature juvenile delinquent has with the juvenile justice system is with a police official. The nature and state of affairs of this police contact are likely to be noteworthy and have a long-lasting inkling on a young person. The problematic nature of dealings between police and young people has time and again been highlighted in the research works. Interactions between police and young people are often characterized by disagreement and stress, with high levels of annoyance, fear and mistrust on both sides.
While girls have historically made up a small percentage of the juvenile justice population, offending by girls is on the rise. Not only is the overall number of juvenile delinquency cases for non-violent crimes on the rise, but girls are also accounting for a larger proportion of the delinquency pie than they did during the 1980s[ii].
The ratio of girls to boys committing IPC Crimes in 2012 was reported 1:19, the same was 1:20 in 2011.[iii] Most assessment tools and treatment models used with youth in the justice system were designed for use with male offenders and have not been adequately tested with females. Until we have more research, we cannot know if these assessments and interventions are effective with offending girls. The age of juvenility of a boy child under JJA 1986 was below 16 years and that of a girl child was below 18 years of age[iv].
Those working in the field of children had campaigned to increase the age of boy juveniles to bring it on power with girl juveniles. The age of a boy juvenile has been increased to 18 years by JJA 2000 mainly to bring juvenile legislation into conformity with the Convention on Rights of Children which the Government of India had ratified on 11th December 1992. Section 83 of IPC states that ‘Nothing is an offense which is done by a child above seven years of age and under twelve, who has not attained sufficient maturity of understanding to judge of the nature and consequences of his conduct on that occasion’.
DOCTRINE OF DOLI INCAPAX
The rate at which kids mature varies significantly among individuals. Due to their wide-ranging developmental trajectories, they learn the difference between right and wrong and between behaviors that are gravely wrong and those that are merely disobedient or mischievous at different ages. The legal principle of doli incapax recognizes the varying age at which children grow up to be mature and decide good and bad for themselves. Doli incapax is sometimes considered as a rebuttable legal belief that a child is ‘incapable of crime’ under legislation or common law. As according to this principle, during the trial process, the prosecution is accountable for rebutting the presumption of doli incapax and proving that the accused juvenile was able at the applicable time to adequately make a distinction between right and wrong. A contested trial can only result in a conviction if the prosecution effectively rebuts this belief.
ROLE OF THE POLICE
It is principally the police who arrests the juvenile and produces him before the Juvenile Justice Board. It is seldom, that a juvenile is produced by a non-public party or voluntary organization. Hence, a juvenile’s first contact with the juvenile justice system is through the police. A non-public party or voluntary organization producing a juvenile before the Juvenile Justice Board ought to preferably inform the police regarding such production. Pending production before Board, the juvenile is to be kept within the Observation Home. Under no scenario should a juvenile be kept within the police lock-up or jail[v]. The SJPU or juvenile welfare officer should inform the parent or guardian or any other person of the juvenile’s choice regarding the juvenile’s apprehension. It is the police who investigates a juvenile case, and submits the charge-sheet before the competent authority and also on completion of inquiry, accompany the juvenile to the Special Home, or to his place of residence when below eighteen years of age[vi].
The dispensing of distinct treatment to juveniles as supposed under juvenile legislation is defeated if the police treat juveniles in the same manner as they treat hardened offenders. So the Statement of Objects and Reasons of JJA 2000 embody ‘creating special juvenile police units with a humane approach through sensitization and training of police personnel’[vii]. Consequently, JJA 2000 envisages the setting-up of the SJPU in each district and town, and also the designation of a minimum of one police officer hooked up to a police headquarters as “the juvenile or the child welfare officer”[viii].
JJA 2000 provides the police the authority to immediately on apprehension release a juvenile on bail[ix]. The same provision was contained in JJA 1986 and BCA 1948. however the police, but insignificant the crime speculated to have been committed, do not release a juvenile on bail as they would, an adult, alleged to have committed a bailable offense. This can be the right practice. In the case of a juvenile it is not the offense that determines whether or not he ought to be discharged on bail or not, but the juvenile’s situation, which can solely be determined by a body having the requisite experience and assistance. Moreover, the police’s call to grant bail is also based on extraneous reasons, and lead to capriciousness.
A juvenile’s behavior and attitude make a difference in a police officer’s use of discretion. A youth who is polite and respectful is more probable to induce off with a reprimand, whereas a negative and hostile perspective is probably going to lead to a court referral. The welfare of the juvenile is the principle on which all juvenile systems are based[x].
Special juvenile police unit includes the law enforcement officials who oftentimes or exclusively manage juveniles or are primarily engaged within the prevention of juvenile crime or handling of the juveniles or youngsters under this Act to perform their functions more effectively; they shall be specially tutored and trained. In every police headquarters, a minimum of one officer with the ability and appropriate training and orientation is also designated as the ‘juvenile or the child welfare officer’[xi] who can handle the juvenile or the child in coordination with the police. Special juvenile police unit, of which all the law enforcement officials designated as above, to handle juveniles or youngsters will be members, may be created in each district and town to coordinate and to upgrade the police treatment of the juveniles and the children.
INTERACTION OF THE POLICE WITH THE JUVENILE OFFENDERS
The first contact that an immature juvenile delinquent has with the juvenile justice system is with a police official. The nature and state of affairs of this police contact are likely to be noteworthy and have a long-lasting inkling on a young person. Children and juveniles are involved in a wide range of law violations ranging from status offenses to more grave offending and present unique challenges for the policing function. For juveniles, the police role is said to be especially significant, as a young person’s view and outlook toward law enforcement are shaped by their first encounter with a police officer[xii].
Juvenile offenders are involved in a strangely hefty number of crimes relative to their fraction of the population, so they present a special challenge for law enforcement. The role of police with juveniles is lengthened because they handle many noncriminal issues referred to as status offenses, including running away, curfew violations, and truancy as well as nondelinquent juvenile matters such as neglect, abuse, and missing persons reports. Most metropolitan police departments have special police units or juvenile bureaus for handling the growing number of juvenile cases. The job of special juvenile officers include taking missing children reports; probing runaway cases; investigating juvenile crimes; contacting and interviewing juveniles, their parents, school officials, and complainants regarding the situation of an offense; maintaining juvenile records, and appearing in juvenile court.
Juveniles are less knowable than adults, and time and again exhibit less respect for the authority of officers. The infantile behavior of many children and youth means that they are more at risk to the dares of other youth, and they often engage in unusual behavior when in the company of their peers. Many youths view the police officer on guard not as a restriction to delinquent behavior, but as a challenge to avoiding detection and confrontation while loitering at night or engaging in behaviors ranging from petty mischief to property damage and sabotage, to more serious crimes of theft and assaults.
The immaturity of youth coupled with limited parental supervision and negative peer pressure presents special problems for police, who repeatedly encounter juveniles with little respect for law and authority. Juveniles also present special trouble for law regulators as they are less mindful of the consequences of their actions and of the effects of their delinquent behavior on their victims, their parents and families, their peers, and themselves[xiii].
The problematic nature of dealings between police and young people has time and again been highlighted in the research works. Interactions between police and young people are often characterized by disagreement and stress, with high levels of annoyance, fear and mistrust on both sides. From the point of view of young people, there are perceptions of mutually over-policing in public spaces and under-policing in cases of victimization. Perceptions of racism, bullying and aggression have also been well-known. Police, on the other hand, are reported to experience constant hassles and stubborn behavior from young people. In addition, a general lack of respect for police is often signaled by poor attitudes and demeanor[xiv]. In short, the typical relationship between young people and police can be characterized as one of the negative perceptions from both sides.
For the police, unfavorable interactions may arise from perceptions that youth are uncooperative and discourteous of the law and law officers, or from their own experiences of aggravation, verbal abuse and physical violence directed at them by youth. Mutually negative perceptions and interactions between police and youth may end up in adverse outcomes for each party. The negative perceptions held by youth could result in discontentedness with police as well as a lack of confidence within the police more generally. Poor relationships with police even have implications for youth.
Acting as gatekeepers to the criminal justice system, police have lots of discretion in their relations with youth. However, negative perceptions by police towards youth are likely to adversely influence how police apply this discretion. Attitudes and temperament of the police officer, as well as characteristics of the juvenile such as gender and indigenous status, and their attitudes, manner and behavior towards the police are doubtless to impact on police choices once coping with youth. Further, police discretion could have a major impact on the legislation of youth. Variety of recent studies indicates that early encounters with police could result in a larger chance of future encounters with the criminal justice system in later adolescence or adulthood. In short, negative consequences from police youth interactions are doubtless to strengthen the already unfavorable attitudes and perceptions that exist between these teams.
Understanding how perceptions and attitudes are formed between police and youth is crucial to improving these relationships and minimizing any adverse consequences. How youth understand the police will shape how they interact with law enforcement officers, and their levels of confidence in, and satisfaction with, police more generally. Similarly, how police understand youth will largely influence how they plan to answer a youth-related incident or manage a specific scenario. Chiefly, there were often discrepancies in the version of events provided by youth and that which were provided by police. As an example, youth usually claimed that police were rude, were verbally or physically aggressive or pestered and targeted them for trivial offenses. On the opposite hand, police usually claimed that it was the juvenile who was rude, aggressive and uncooperative, or that the alleged behavior failed to occur.
Police discretion has been criticized for the rationale that some believe that police abuse their intensive unrestricted powers and that they base their choices on extralegal factors apart from the offense. Extralegal factors are those that have nothing directly to do with the offense for which the juvenile suspect is being questioned, taken into custody, or in remission. Once engaged by police, however, youth are presumably to take issue with the manner or way they perceive treatment by police. Similarly, police conjointly describe things in which they asseverate it was the juvenile who was rude, uncooperative or typically showing disrespect for the police. These findings reinforce the negative attitudes and perceptions in relations between youth and police.
Relations between police and youth are often represented as problematic. Shaped considerably by negative attitudes and perceptions from either side and sometimes characterized by tension, mistrust and conflict, interactions between police and youth have resulted in adverse consequences for either side, including charges against youth and complaints against police[xv]. Such negative interactions have also served to strengthen the unfavorable attitudes and perceptions that exist between these 2 groups, thereby perpetuating a cycle of discontentedness and mistrust.
However, not all interactions between police and youth are preceded by the delinquent or criminal behavior of youth. And it’s not solely those kinds of interactions that may result in adverse consequences or feelings of tension and mistrust. Improving relations between police and youth won’t essentially be complete through a program or intervention alone. Experiences of young people and police, influences of family and peers, and private beliefs and attitudes towards each other all facilitate to form perceptions and behaviors. Addressing those influences that contribute to negative interactions veteran by police and youth will require a combination of things to come along and be sustained over time.
Under no circumstances is a juvenile to be kept in a police lock-up or jail. This has been the sentiment of juvenile legislation since the enactment of the children Acts. Separate detection facilities were established for placement of young offenders under BCA 1948; pending enquiry they were to be detained in Approved Centers and those found to have committed an offence were to be kept in Classifying Centers. Distinct establishments for the placement of juveniles continued under JJA 1986 and Juvenile Justice Act 2000[xvi]. Reformation and rehabilitation, rather than penalizing the kid, is the essence of juvenile jurisprudence. Towards this end it is necessary to place the juvenile in a specialized setting where his development is of paramount importance. If adult wrongdoer and juvenile are kept along there is a danger of the juvenile being corrupted by hardened criminals or being abused by them. Is not treatment meted to inmates in police lock-ups and a jail isn’t commensurate with the juvenile’s age and is probably going to scar him.
The way responding to juvenile offending is a unique policy and practice challenge. While a substantial proportion of crime is perpetuated by juveniles, a good number of juveniles will grow out of offending and adopt obedient way of life as they mature. Historically, children in criminal justice proceedings were treated much the same as adults and subject to the same criminal justice processes as adults. Until the early twentieth century, children in Australia were even subjected to the same penalties as adults, including hard labor and corporal and capital punishment[xvii].
Until the mid-nineteenth century, there was no separate category of ’juvenile offender’ in Western legal systems and children as young as six years of age were incarcerated in Australian prisons. It is widely acknowledged today, however, both in Australia and internationally, that juveniles should be subject to a system of criminal justice that is separate from the adult system and that recognizes their inexperience and immaturity. As such, juveniles are typically dealt with separately from adults and treated less harshly than their adult counterparts[xviii]. Juveniles are more likely than adults to come to the attention of police, for a variety of reasons. In comparison with adults, juveniles tend to be less experienced at committing offenses; commit offenses in groups; commit offenses in public areas such as on public transport or in shopping centers; and commit offenses close to where they live.
The issue of race is a concern in the criminal and juvenile justice systems. It is an acknowledged fact that racial and tribal minorities are disproportionately represented at each stage of the system: in police arrests, in jails and detention centers, in courts, and in correctional facilities. Research studies are mixed, however, as to whether that disproportionate revelation is a result of racial bias in police arrest, prosecutors’ decisions, and judicial sentencing. African American youth are overrepresented in juvenile arrests when compared to their share of the population. Black youth, who accounted for 17% of the juvenile population in 2005, were involved in a disproportionate number of juvenile arrests for robbery (68%), murder (54%), motor vehicle theft (43%), and aggravated assault (42%)[xix]. The question is whether the overrepresentation of black juveniles in police arrest rates is due to racial bias or to the greater involvement of black youth in violent crimes. Violent crimes are more likely to be reported, detected, and result in a police arrest.
WOMEN AND CRIME
Girls having historically made up a very low percentage of the juvenile justice population, offending by the girls is on the rise today. It is not that only the overall number of juvenile delinquency cases for non-violent crimes is on the rise, but also the girls are accounting for a larger proportion of the delinquency pie than they did during the 1980s. While the crime which are violent in nature and are done by the juveniles has decreased overall since 1985, girls are prone to commit more of those offenses than they did in 1985. Knowing that there has been an increase in the involvement of the girls in the justice system, but understanding the underlying causes of it since research about female offenders is lacking hitherto[xx].
It may happen to appear that the boys and girls in the justice system are more alike in comparison of being different at the first glance. Both these genders in the justice system are the same in many aspects, such as being more aggressive, having more mental and health problems, and tend to experience more risk factors which basically include child abuse or poverty when put in comparison to the non-offending counterparts of them. Some subtle differences between both these gender offenders cannot be neglected.
Women offenders have to face various offenses and at times even brutality at the hands of the Police Officers. They are generally looked down upon by the police and hence are treated with disrespect which also outrages the modesty of the women offenders. A woman who has been brought in for an inquiry shall only be treated as a suspect and not as a proven offender. It has been observed that women have to face immense trouble and a disrespectful demeanor during the process of the inquiry at the police station and the same is continued even after they have been convicted and sentenced to jail[xxi].
The police officers tend to use physical force on these women and this is done by both the male and female police officers. Physical violence here refers to the intentional use of the physical force which has the potential for causing a grievous injury, harm, disability, or even death of the person on whom it has been inflicted upon, it also comprises, hitting, shoving, biting, restraint, kicking, or even the use of a weapon.
Police officers in most of the cases treat women offenders as a sexual object. Sexual abuse comprises any kind of a situation where force is used for obtaining participation in any of the unwanted, unsafe, or a degrading sexual activity. Forced sex is an act of aggression and violence and even a spouse or an intimate partner with whom consensual sex has occurred cannot be relieved under this (with an exception in India where rape by the husband, i.e. marital rape is not an offense). This has also been mentioned in the Justice Verma Report[xxii].
Women offenders face a situation wherein sexual favors have been asked from them by the police. They face sexual abuse at the hands of even the male prisoners (when they come in contact). Male and female police officers are considered to be insensitive towards them and treat them with ungracious words and demeanor by looking down upon them. The police shall deal with the women who have been into human trafficking with immense patience and not with undue disrespect so that they may get out of the ambit of their trauma and narrate their part of the story.
Most of the assessment tools and treatment models have not been tested adequately with the females but were designed and used with the youth in the justice system keeping in mind only the male offenders. Only with adequate research, the effectiveness of these assessments and interventions with offending girls can be known. It is imperative that services shall be offered in the case of female offenders knowing about the high rates of mental health disorders in them. Girls with conduct disorders are far less likely than their male counterparts to find, receive, or complete treatment.
Girls are said to experience a multitude of risk factors or often even at higher rates in the justice system as compared to their male counterparts. Offending girls exhibit higher rates of mental health problems, exhibit more aggression toward family members and romantic partners, and suffer more negative consequences from their justice system involvement than offending boys. Girls who are antisocial are less likely to receive treatment and are accessed to fewer options of community-based treatment as compared to boys, even if they have an increased need for such services. Finally, girls who are formally charged are more likely to be placed in secure confinement than boys in the same situation and to act out violently once there.[xxiii]
Victimization, in any form, i.e., physical or sexual, and also the emotional aspect is the first step along a female’s pathway into this system of juvenile and criminal justice as has been consistently identified by the research. It has also been considered as a primary source for determining the types and patterns of typical offenses committed by girls and women. The act of committing such offenses by the women and girls at an early age can be the negative repercussion as a result of the abuse which they might have suffered in their lives. The proportion of the girls first entering the juvenile justice system as runaways, for the reason of escaping abuse at home was high. Ninety-two percent of the juvenile female offenders interviewed in 1998 reported that they had been subjected to some form of emotional, physical, and/or sexual abuse[xxiv]. It has been observed that the attention paid to female experiences with crime and delinquency has been reasonably low as it has been generally associated only with boys.
The ideal interaction of a police officer with a women offender includes the following:
- Police personnel shall respect a woman’s dignity (even though she is an offender) in the interviews conducted by them and they shall also remain patient during the same.
- They shall be attentive to the offender’s sense of personal dignity ensure appropriate covering of their bodies so that it is not immodestly displayed. For example, during your interview of victims, do not lose sight of the possibility that they may be preoccupied with their dirty face, disheveled hair, torn clothing, or otherwise “undignified” appearance. Provide victims with covering while being careful not to compromise the collection of any forensic evidence.
- The interaction with the victims shall be in a calm and a professional manner. The police officer shall not exhibit his outrage or disgust at the crime as the offender has not been convicted and without her conviction, she cannot be held guilty of the crime, therefore shall not be treated ruthlessly like a convicted person.
- The women offender shall be put under the charge of a women police officer, who will be performing the duties of arresting the offender, interviewing and setting up an inquiry, etc. The arrest of the women offender can only be made by a female officer before sunset, though a male officer may be present there.
- The police shall conduct the interview with the offender with extreme sensitivity.
State governments shall ensure and consider juvenile justice system as an integral part of the training curriculum of the police. It shall be ensured that the treatment of the juveniles by the law shall be differentiated with the treatment of an adult criminal, and every police personnel shall also be explained the reason of such a distinct treatment. This can be one of the steps which may assure a juvenile his rights in the justice system, hence curtailing the ongoing practice of the police to treat juveniles as adults. This shall be helpful in obtaining the results of training as to how it changes the perspective of a police officer who religiously believes that people committing crimes shall to be treated stringently, and punished. Police officers have to encounter with various delinquent behavior among the youth, which ranges from minor to serious crimes. Minor offenses involving the order and maintenance function of enforcement of law is basically for what the police personnel encounters with the juveniles. The encounter of the police with the juvenile can make a significant difference on the relationship between the police and the juvenile and also the police with the women regardless of even the seriousness of the behavior.
The “bad manners” used by the police often creates a risk factor for a crime for themselves. In the situation where the police show disrespect towards the suspects and citizens, they receive the same kind of behaviour from them towards the police and even the law. Juveniles criticize various practices of the police such as the police stopping to question them, asking them not loiter on street corners, and various other places, etc. Various other students have ambivalent feelings about police. One of the essential reasons for juveniles’ negative approach towards the police is the inevitable result of police personnel’s just but unpopular restrictions on young peoples’ behaviors which are contradicting to law.
For the women, it shall be ensured that women police officers shall be recruited in large numbers and only they shall be authorized to deal with such offenders. It is strongly believed that the interaction between police and a juvenile are a two-way street. How police officers treat the young people is how they will respond to them and in the same way even the officers often respond in the same manner to juveniles’ disrespectful behavior. Working with juveniles and women is a challenge for the police departments and to do well in this the police personnel shall be imparted with the cultural awareness training to enhance their skills in working and interacting with juveniles as well as the women offenders.
Formatted on 13th March 2019
[i] Section 2(k), Juvenile Justice (Care and Protection) Act, 2000
[ii]National Crime Record Beareau, Statistic 2012, (New Delhi: Ministry of Home Affairs, Govt. of India) pp. 131-136
[iv] Section 2(h), Juvenile Justice Act, 1986
[v]Proviso to Section 9, Juvenile Justice (Care and Protection), Act 2000
[vi]Juvenile offenders and Victims: 2006 National Report, available at, http://ojjdp.ncjrs.gov/ojstatbb/ nr2006/downloads/NR2006.pdf. (Last Accessed on 1st July, 2014)
[vii] Statement of Objects and Reasons, Juvenile Justice (Care and Protection), Act 2000
[viii] Section 63(2), Juvenile Justice (Care and Protection), Act 2000
[ix] Section 12(2), Juvenile Justice (Care and Protection), Act 2000
[x]Law Commission of India report, http://lawcommissionofindia.nic.in/101-169/Report156Vol2.pdf August 1997
[xi] Section 63(2), Juvenile Justice (Care and Protection), Act 2000
[xii] Christine B. Siegfried, Susan J. Ko, and Ann Kelley, Victimization and Juvenile Offending, National Child Traumatic Stress Network Juvenile Justice Working Group 2004.
[xiii] infra Note 15
[xiv] Christine B. Siegfried, Susan J. Ko, and Ann Kelley, Victimization and Juvenile Offending, 2004 in National Child Traumatic Stress Network Juvenile Justice Working Group.
[xv] Stephanie M. Myers, Police Encounters With Juvenile Suspects: Explaining The Use Of Authority And Provision Of Support. (Albany: School of Criminal Justice, 2002)
[xvi]Section 8-9, Juvenile Justice (Care and Protection), Act 2000
[xvii] Kelly Richards, What makes juvenile offenders different from adult offenders? In Trends and Issues, ,(Australia: Australian Institute of Criminology, 2011)
[xviii] Lee, Myoung-Jin Cho, Joo-yeon Choi, Moonkyoung, Child Abuse and Juvenile Delinquency, Vol.7 No.2 Korean Journal of Social IssuesOctober 2007
[xix] Gohike, Karl H, Police and Juveniles in Juvenile Justice. 1995.
[xx] Daly, Kathleen, Feminism, Criminology, and Criminal Justice: An Information Packet, 1991, pg 58.
[xxi] Raffel, Sokoloff, Natalie J. McGraw-Hill, The Criminal Justice System and Women: Offenders, Victims, and Workers. (2nd edition) Price, Barbara 1995.
[xxii] Justice Verma Committee Report Summary, available at http://www.prsindia.org/parliamenttrack/report-summaries/justice-verma-committee-report-summary-2628/, (Last Accessed on 30th June, 2014)
[xxiii]supra note 15
[xxiv] Raffel, Sokoloff, Natalie J. McGraw-Hill, The Criminal Justice System and Women: Offenders, Victims, and Workers. (2nd edition) Price, Barbara 1995.