CYBER CRIMES AGAINST WOMEN IN NATIONAL AND INTERNATIONAL PERSPECTIVE: NEED FOR EFFECTIVE LAWS
Dr. Ghulam Yazdani ((Assistant Professor, Faculty of Law, Jamia Millia Islamia, New Delhi)).
The Science of Information technology has extensively developed over the last two decades and has turned out to be the nucleus of today’s global and technological development. The worldwide network provides every user known as Netizen all the required information fastest beyond imagination. Information communication and it sharing with the help of tools making it possible in a friction of second’s easily available as being valuable source of information. With the advancement of internet, the occurrence of crime in the society by via internet has also broadened its roots in all directions. Factually commission of crime in cyber space is a constantly increasing phenomenon. This activity of human being is not only in India but all over the world. Cyber crimes is a growing field of crime targeting everyone including the Institutions , Governments, non State entities and individuals causing great damage to the social, economic, political and public and private life of the victims. The anonymous and the trans-national nature of the internet make it an easy weapon in the hands of the wrongdoer in the society. Among the sufferers Women and Children are the most vulnerable to cyber crimes and they are habitually victimized. Internet provides an important platform in today’s time to learn, discover, cultivate, advance and entertain oneself. All over the world individuals including women have been greatly emancipated by the use of internet technology by acquiring knowledge, learning new skills, opening up earning opportunities and a benevolent platform to express and entertain. While the internet has been a boon to women giving them an important means to communicate, it has also often been a bane for women who had been unfortunate victims of cyber crime.
It is true that cyber crime affects women in ways which are different from men. Cyber crimes against women which are usually sexual and implicit attack on the victim, apart from leading to a sense of insecurity and fear can severely impact the economic avenue open to the women, as it can drive women to move away from the use of internet technology, thereby snatching away all the benefits of internet which she is ideally suppose to enjoy as an individual member of the society.
In this new era of technology it is matter of great concern to all of us to make sure so that women should not be deprived of using the cyber space due to fear of such targets by the man’s world. The growing menace of cyber crimes and absence of legal mechanism ,Policy makers and Legislators all over the globe have recognized the need to regulate the use of technology by every one without any discrimination based on gender or otherwise . Laws have been enacted world over to protect the governments, institutions and individuals from being victimized. Globally the initial attempts for legislative processes to make laws started slowly and they focused more upon the e-commerce aspect of cyber space dealing with the trade and commerce rather than focusing on preventing and punishing the offenders of such cyber offences.
The internet and its increased attraction bring opportunities and challenges simultaneously particularly to younger generation. Policy makers, legislators regulators, Judicial Officers, lawyers and teachers, NGOs, and individuals all grapple with how to address the many social and legal issues involved. Although there are many interesting issues, this article will only explore ideas on how to keep women, safe from sexual predators in the cyberspace using internet.
CYBER CRIMES: Nature and Meaning
The concept of e-crime or cyber crime is not completely different from the concept of conventional crime. Both include conduct whether act or omission, which cause breach of rules of law counterbalanced by the sanction of the state. Computer crime or cyber crime refers to any crime that involves a computer and a network. The computer may have been used in the commission of a crime, or it may be the target. Cyber Crime is criminal activity done using computers and the Internet including downloading prohibited music records to thieving millions of dollars from online bank accounts. Cyber Crime also includes non-monetary offences, such as creating and distributing viruses on other computer or posting classified/confidential business or trade information on the Internet. The computer or such device may however be a target for unlawful acts in the following cases- unauthorized access to computer/ computer system/ computer networks, theft of information contained in electronic form, e-mail bombing, data diddling, salami attacks, logic bombs, Trojan attacks, internet time thefts, web jacking, theft of computer system, physically damaging the computer system.
The term Cybercrime/ e-crime means for any illegal activity that uses a computer or such device as its principal means of commission. It is an offence that is committed against individuals or groups of individuals with a criminal motive to intentionally harm the reputation of the sufferer or cause physical or mental harm to the victim directly or indirectly, using such system which is capable of transmitting the information from one place to other using modern communication networks.
Prior to this women are generally not yet get rid of different kinds of violence committed against her, new problem in the form of cyber crimes against women has posed the biggest challenge to whole world. Acknowledging the fact and looking into the domain of internet at international level the U.N. Congress on Prevention of Cyber Crime and Treatment of Offenders defined Cyber crime which comprises two categories a follows:
- Cybercrimes in a narrow sense connotes a computer crime and includes any illegal behavior directed by means of electronic operations that targets the security of the computer systems and the data processed by them.
- Cybercrime in broader sense includes all computer related crimes and consists of any illegal behavior committed by means of, or in relation to, a computer system or network, including such crimes as illegal possession and offering or distributing information by means of a computer system or network.
In the Indian context, cyber crime may be defined as a voluntary and willful act or omission that adversely affects a person or property or a person’s computer systems and made punishable under the Information Technology Act, 2000 or liable to penal consequences under the Indian Penal Code.
CYBER VIOLENCE AGAINST WOMEN
Cyber crimes are committed against individuals as well as nations. Where in cyber crimes against individuals targets individual persons and it has been largely observed that women and children are more vulnerable to be victims of cyber crimes. They are easily targeted. In the men’s world millions of women and girls are subjected to purposeful violence because of their being feminine. Violence against women and girls knows no boundaries/limits, cutting across borders, race, culture and income groups, extremely harming victims, people around them, and society as a whole. The International Community has urged governments and industry to work harder and more effectively together to better protect the growing number of women and girls who are victims of online threats and harassment.
The State should take necessary steps towards the sudden increase in the number of cyber crimes. Because, there is a different and additional disturbing statistic that goes on to suggest that the nearly 13 per cent of the cases are targeted against outraging of modesty or blackmailing a woman. Over the years the cyber crimes reported have risen by nearly 63.7 per cent.
If we really need to do something on the matter then we should stop the culture of denial and victim-blaming. Even the National Commission for Women had organized a consultation on “Ways and means to safeguard women from cyber crime in India” on 23rd July, 2014. In a statement released after a day-long consultation on cyber crimes against women, the NCW called for sensitizing police regarding cyber crimes. The panelists called the government to provide proper guidelines for intermediaries to pull down any content offensive to women. Other suggestions called for an awareness training programs as part of curriculum in laws, and proper implementation of the Information Technology Act.
Types of Cyber Offences against Women
Though, the life of women never was smooth in every period. The occurrence and the frequency of wrongs/ crimes caused, are countless in her way Amongst the various cyber crimes committed against women main crimes can be identified which are notorious and detrimental to her dignity and freedom are listed as under:
Cyber Harassment is characteristic repetitive behaviour intended to disturb or up rest a person though use of internet. The medium of emails and social networking sites are generally used to target women for harassment by way of blackmailing, threatening, bullying , cheating, impersonation etc. Section 67-A, 67-B of the Information Technology Act provide Sexual harassment in respect of offences of publishing or transmitting of material containing sexually explicit act and child pornography in electronic form.
‘Stalking’ in general means a harassing or threatening behavior which an individual exhibits towards the other. “Stalking is a unique crime in that it is composed of a series of otherwise legal acts. Cyber stalking in particular is composed of words alone and therefore stands more distinctly as apart as a crime of accumulation. As one sociologist described it, “the separated acts that make up the intrusion cannot by themselves cause the mental abuse, but do taken together (cumulative effect).” Cyber stalking, which is simply an extension of the physical for of stalking is where the electronic mediums such as internet are used to pursue, harass or contact another in unsolicited fashion.
Cyber Stalking is a behavior wherein an individual willfully and repeatedly engages in a knowing course of harassing conduct directed at another person which reasonably and seriously alarms, torments, or terrorizes that person. Cyber stalking involves following a person’s movements across the Internet by posting messages (sometimes threatening) on the bulletin boards frequented by the victim, entering the chat-rooms frequented by the victim, constantly bombarding the victim with emails etc. Cyber Stalking usually occurs with women, who are stalked by men, or children who are stalked by adult predators or paedophiles. Cyber stalkers target and harass their victims via websites, chat rooms, discussion forums, open publishing websites and email.
The motives behind cyber stalking have been divided into four reasons, namely, for sexual harassment, for obsession for love, for revenge and hate and for ego and power trips. Cyber stalkers target and harass their victims via websites, chat rooms, discussion forums, open publishing websites (e.g. blogs and Indy media) and email. The availability of free email and website space, as well as the anonymity provided by these chat rooms and forums, has contributed to the increase of cyber stalking as a form of harassment. Why not the access of internet is being made based on identity of user?
The word pornȇ stands for prostitute, and graphein stands for documentary. Pornography literally means “Documenting a Prostitute” or “Depictions of acts of Prostitutes”. Pornography in the eyes of law is not necessarily obscene. Today, the largest industry of Internet is Adult Entertainment. There are millions of individually owned pornographic websites. Research shows that 50% of the web-sites containing potentially illegal contents relating to child abuse were ‘Pay-Per-View’. This indicates that abusive images of children over Internet have been highly commercialized. Currently, there is no law against viewing pornography. The Indian Penal Code and the recent IT Act both prohibit the production and transmission of “obscene material”. The IT Act stipulates three years in jail for publishing and transmitting obscene material electronically.
Cyber Pornography is pornography that is distributed via the internet, primarily via websites, peer to peer file sharing, or Usenet newsgroup. Internet has provided a medium for the facilitation of crimes like pornography. Child abuse, sexual violence against women, juvenile delinquency and other sexual crimes are the direct effect of pornographic images. Due to easy access to worldwide web through new multi-media technology, cyber pornography and other cyber crimes are increasing every moment.
The Information Technology has built up the nature of the crime of cyber pornography in such a way that it has made it much easier to create and distribute pornographic material through internet. Such material could be transmitted all over the world in matter of seconds. Moreover, the social and moral deterrence of buying a porn magazine from a bus stand/Railway stations or shop is no more there as anyone can now easily access pornographic material online with complete anonymity. Further child pornography, which is aggravated form of pornography is a much serious offence and consequently demands more stringent measures. Undisputedly, technology posed a complex challenge for the legislation and law enforcement agencies worldwide. The present Information Technology law enables the law enforcement agencies to take strict action against those seeking child pornography and its violation can lead to seven year term in jail and up to ten lac rupees fine.
Cyber tort is a willful act done by a person on internet that may cause legal injuries to virtual identity or virtual property of a person in cyberspace. Cyber tort including libel and defamation is another common crime against women in the net. This occurs when defamation takes place with the help of computers and or the Internet. E.g. someone publishes defamatory matter about someone on a website or sends e-mails containing defamatory information to all of that person’s friends.
Morphing is editing the original picture so as to make it look completely or largely different. Often criminally minded elements of the cyber world download pictures of girls from websites such as Facebook and then morph it with another picture in compromising situation so as to represent that those women were indulging in such acts. Often the next step after this is to blackmail those women through the threat of releasing the morphed images and diminishing the status of those women in society. Such acts can be penalised under I.T. Act, 2000 and attracts Sections 43 & 66 of the same. The violator of such crime can also be booked under Indian Penal Code of Sec 509. For the purposes of this section, the word ‘dishonestly’ and ‘fraudulently’ shall have the meaning assigned to it in section 24 & 25 of the Indian Penal Code,of 1860.
E-mail spoofing is a term used to describe fraudulent email activity in which the sender address and other parts of the email header are altered to appear as though the email originated from a different source; it is done by properties of the email, such as the From, Return-Path and Reply-To fields, ill-intentioned users can make the email appear to be from someone other than the actual sender. This method is often used by cyber criminals to extract personal information and private images from innocent women.
Protection to Women in International Perspective
World Community cannot be silent on the issues where half of the population of the world is in trouble. The dignity and fundamental freedom of women in the cyber world at large is on stake due to emergence of new technology and its use.
Cyber protection to women in United Kingdom
Gender sensitive cyber crime took a lead role in the late 90’s in United Kingdom when stalking of female celebrities over the internet became a major problem. In United Kingdom cyber harassment and offences against women are covered by the Protection of Harassment Act, 1997. Unlike United States of America, United Kingdom does not have women specific regulations to cover up cyber offences originating from domestic violence unauthorized access to computer resource and hacking. All these offences are regulated by the Computer Misuse Act, 1990 which is applicable to both men and women. This act penalizes three kinds of offences namely;
- Unauthorized access to computer material or to enable any such access to secure unauthorized acce,
- Intention to create further menace with such unauthorized acce,
- Unauthorized modification of computer materia
The penalties for the offences mentioned above include imprisonment for a term and 12 months and a monetary fine not exceeding statutory maximum or both.
Cyber protection to women in United States of America
Studies have shown that United States of America has the highest number of cyber specific legislations. The U.S Communication and Decency Act, 1996 differentiates child pornography and have both federal and state laws to regulate cyber crimes. Similarly Computer Fraud and Abuse Act, 1860 regulates the offence of hacking which is again covered by Title 18, USC 1030 which defines it as an “unauthorized access”.
Section 223(a) Title 47, USC makes it an offence to use a telecommunication device in interstate or foreign communications to:
- Make, create solicit and initiate the transmission of “any comment, request, suggestion, proposal, image, or other communication which is obscene, lewd, lascivious, filthy or indecent, with the intent to annoy, abuse, threaten or harass another person.,
- Make, create solicit and initiate the transmission of “any comment, request, suggestion, proposal, image, or other communication which is obscene knowing that the recipient of such communication is under 18yearsof age.,
- Make a telephone call or utilize a telecommunication device without disclosing the identity to annoy , abuse, threaten or harass any person at the called number or who receives the communicati,
- Make or cause the telephone of another repeatedly or continuously to ring with intent to harass any person at the called number.,&
- Knowingly permit any telecommunication facility under his or her control to be used to commit any of the previously listed ac
The penalties for these offences include fines, imprisonment or up to 2 years or both
The Information Technology Act, 2000
In 1999, Indian Government, formed the Ministry of Information Technology. India was on the path to making India IT superpower. The impact of Glabalisation in the country was so imminent that in less than a year, India has made the enactment of its first statute relating to Information Technology on the pattern of Model Law on Electronic Commerce, 1996, adopted by the United Nation Commission on International Trade law (UNCITRAL). The Electronic Transaction Act of 1998 of Singapore also significantly guided the framing of the Indian Act. The Information Technology Act, 2000 was passed by the Parliament on May 15, 2000, approved by the President on June 9, 2000 and notified to come into force on October 17, 2000.The Act, seeks to protect this advancement in technology by defining crimes, prescribing punishments, laying down procedures for investigation and forming regulatory authorities.
The Information Technology Act, 2000 initially consisted of XIII Chapters & 4 Schedules and 94 Sections. Two schedules have been deleted by the Information Technology (Amendment) Act, 2008. At present it has 2 Schedules. Chapters IX & XI covers up offences and penalties. The Information Technology Act, 2000 nor defines ‘cyber crimes’ neither uses this expression, but only provides the definition of and punishment for certain offences. Thus two kinds of definition of cyber crimes can be given. In narrow terms cyber crime consists of only those offences which are mentioned under the Information Technology Act, 2000, whereas broadly speaking cyber crime can be said to be an act of omission, commission or committed on or through or with the help of internet, whether committed directly or indirectly and which is prohibited by any law for which punishment corporal or monetary is provided. In this context it can be concluded that Information Technology Act, 2000 provides punishment for only certain offences and is not exhaustive of all cyber crimes.
The Information Technology (Amendment) Act, 2008 also added section 66A which prohibited the sending of offensive messages though a communication device (i.e. through an online medium). The types of information covered were offensive messages of a menacing character, or a message that the sender knows to be false but is sent for the purpose of ‘causing annoyance, inconvenience, danger, obstruction, insult, injury, criminal intimidation, enmity, hatred, or ill will’. However, the provision was challenged on the ground of vagueness, arbitrariness and misuse and was ultimately struck down by the Supreme Court in the case of Shreya Singhal. In light of the sexual harassment, abuse and intimidation faced by women on the internet, the section could have provided for a proper remedy.
As regards cyber victimization of women, the Information Technology law has remained a half baked law. Unfortunately even though Chapter XI of the IT Act deals with the offences such as Tampering with computer source documents (s.65), Hacking with computer system (s66), publishing of information which is obscene in electronic form (s.67) Access to protected system(s70), Breach of confidentiality and privacy(s. 72), Publication for fraudulent purpose(s.74) IT Act 2000 still needs to be modified. It does not mention any crime specifically as against women and children.
The basic problems, which are confronted with Cyber-Crimes, are Jurisdictional issues, Loss of evidence, Lack of Cyber Cops ,Army and Cyber savvy judges who are the need of the day. Judiciary plays a vital role in shaping the enactment according to the order of the day. The IT Act 2000 does not mention the typical cyber crimes like cyber stalking, morphing and email spoofing as offences. The Indian law is still unequipped to deal with various cyber offences against women such as revenge porn.
Strict privacy and safety measures should concern the law-makers in order to deal with the cyber crimes against women. Every now and then we believe that we are making some development but every single time the visible progress is speedily followed by a return to the status quo. As the Internet is a not having boundaries known as borderless medium which allows instantaneous and anonymous distribution of one’s message, and the follower/ stalker has the protection of the “veil of anonymity. Creating awareness about the possible harms of the online world along with education to curb the interaction/access of illegal and immoral elements in the society by way of privacy features can go a long way in protecting women. Having said that it is equally important to have a strong and effective legal machinery in place to combat any kind of cyber violence which may be committed against a woman. Laws play an important role in combating crimes in any society. Undoubtedly, over the years, India has witnessed huge developments as far as policy making for the protection of women and children are concerned. The recent Criminal Law Amendment Act, 2013 provides some respite with section 354 (B) that takes cognizance of online stalking, voyeurism and releasing of private moments in compromising situations online. However, our laws are inadequate to handle cases of cyber violence.
In order to keep away from the cyber-crime we should desist from making conversation with people we don’t know. People on the other end of the computer may not be who they claim to be. We must keep our passwords protected and do not keep sensitive material on the computer as that can be accessed by the hacker. If anything seems out of place or wrong, contact law enforcement immediately without any delay to nearest cyber Police Stations.
Violence online and offline is supplementary and complimentary to each other. Abuse may be confined to networked technologies or may be supplemented with offline harassment including vandalism, phone calls and physical assault. It is pertinent that measures such as skill training and sensitizing the police, conducting awareness programmes at the grassroots level, proper implementation of the IT Act, and guidelines to pull down offensive material should be taken. To effectively combat cyber violence against women both the restructuring of laws and creating awareness to avoid victimization and to take proper steps for redressal are important. At the end to achieve a place of joy in the digital era while searching safe and secure root for the Internet citizens will have to be articulate and choose a coherent set of values to live by online and feel happy.
 Danielle Keats Citron , Law’s Expressive Value in Combating Cyber Gender Harassment , available at http://digitalcommons.law.umaryland.edu/cgi/viewcontent.cgi?article=1687&context=fac_pubs
 Moore, R,. Cyber crime: Investigating High-Technology Computer Crime, (Anderson Publishing, Cleveland, Mississippi, 2005)
 Warren G. Kruse and Jay G. Heiser, Computer forensics:Incident Response Essentials 392 (Addison-Wesley Longman Publishing Co., Inc. Boston, MA, USA ©2002.
 Dr. Atul Bamrara, “The Challenge of Cyber Crime in India: The Role of Government” Pakistan Journal of Criminology, Volume 3, Jan, 2012, pp. 127 – 134
 Tenth UN Congress on Prevention of Crime & Treatment of Offenders was held in Vienna on April 10-17, 2000.
 Dr. Vishwanath Paranjape, Legal Dimentions of Cyber Crimes and Preventive Laws ,Central Law Agency, Allahabad, 2010.
 http://ncw.nic.in/Pressrelease23072014.pdf (last visited on October 10, 2014)
 http://www.business-standard.com/article/news-ians/ncw-seeks-guidelines-on-online-content-offensive-to-women-114072401659_1.html (last visited on October 15, 2014)
 S. 67A. Punishment for publishing or transmitting of material containing sexually explicit act, etc., in electronic form.—Whoever publishes or transmits or causes to be published or transmitted in the electronic form any material which contains sexually explicit act or conduct shall be punished on first conviction with imprisonment of either description for a term which may extend to five years and with fine which may extend to ten lakh rupees and in the event of second or subsequent conviction with imprisonment of either description for a term which may extend to seven years and also with fine which may extend to ten lakh rupees.
 67B. Punishment for publishing or transmitting of material depicting children in sexually explicit act, etc. in electronic form.- Whoever,-
(a) publishes or transmits or causes to be published or transmitted material in any electronic form which depicts children engaged in sexually explicit act or conduct or
(b) creates text or digital images, collects, seeks, browses, downloads, advertises, promotes, exchanges or distributes material in any electronic form depicting children in obscene or indecent or sexually explicit manner or
(c) cultivates, entices or induces children to online relationship with one or more children for and on sexually explicit act or in a manner that may offend a reasonable adult on the computer resource or
(d) facilitates abusing children online or
(e) records in any electronic form own abuse or that of others pertaining to sexually explicit act with children, shall be punished on first conviction with imprisonment of either description for a term which may extend to five years and with a fine which may extend to ten lakh rupees and in the event of second or subsequent conviction with imprisonment of either description for a term which may extend to seven years and also with fine which may extend to ten lakh rupees:
Provided that the provisions of section 67, section 67A and this section does not extend to any book, pamphlet, paper, writing, drawing, painting, representation or figure in electronic form-
(i) The publication of which is proved to be justified as being for the public good on the ground that such book, pamphlet, paper writing, drawing, painting, representation or figure is in the interest of science, literature, art or learning or other objects of general concern; or
(ii) which is kept or used for bonafide heritage or religious purposes
Explanation: For the purposes of this section, “children” means a person who has not completed the age of 18 years.
 Lambèr Royakkers, Cyberstalking: menaced on the internet, cited in West’s Encyclopedia of American Law, available at http://www.sociosite.org/cyberstalking_en.php as cited by Merritt Baer, Cyberstalking and the Internet Landscape We Have Constructed in Virginia Journal of Law & Technology Fall 2010 ,University of Virginia VOL. 15, NO. 154.
 Wayne Pethererick “Cyber-Stalking: Obsessional Pursuit and the Digital Criminal”. CrimeLibrary.com. as quoted in Chapter 5.
 Supra note 6
 http://www.livemint.com/Politics/3MpSaU1JOWj0I23Tm521NL/PIL-in-Supreme-Court-seeks-ban-on-Internet-pornography.html/ (last visited on April 16, 2013)
 Mohit Mittal, “Issue of Jurisdiction in Combating Cyber Crimes: Issues and Challenges Pornography and Indian Jurisdiction” Available at http://www.legalservicesindia.com/article/print.php?art_id=1386
 Charandeep Singh Samrao, Cyber Crimes (Random Publications, Delhi, 2013)
 http://dictionary.reverso.net/english-definition/Cybertort (last visited on September 17, 2014)
 Section 43 of the Information Technology Act, 2000: Penalty and compensation for damage to computer, computer system, etc.
If any person without permission of the owner or any other person who is in charge of a computer, computer system or computer network, or computer resource —
- accesses or secures access to such computer, computer system or computer network;
- downloads, copies or extracts any data, computer data base or information from such computer, computer system or computer network including information or data held or stored in any removable storage medium;
- introduces or causes to be introduced any computer contaminant or computer virus into any computer, computer system or computer network;
- damages or causes to be damaged any computer, computer system or computer network, data, computer data base or any other programmes residing in such computer, computer system or computer network;
- disrupts or causes disruption of any computer, computer system or computer network;
- denies or causes the denial of access to any person authorised to access any computer, computer system or computer network by any means; (g) provides any assistance to any person to facilitate access to a computer, computer system or computer network in contravention of the provisions of this Act, rules or regulations made thereunder;
- charges the services availed of by a person to the account of another person by tampering with or manipulating any computer, computer system, or computer network, he shall be liable to pay damages by way of compensation to the person so affected.
- destroys, deletes or alters any information residing in a computer resource or diminishes its value or utility or affects it injuriously by any means;
- steel, conceals, destroys or alters or causes any person to steal, conceal, destroy or alter any computer source code used for a computer resource with an intention to cause damage;
 Section 66 Computer related offences. -If any person, dishonestly or fraudulently, does any act referred to in section 43, he shall be punishable with imprisonment for a term which may extend to three years or with fine which may extend to five lakh rupees or with both.
 ‟Cyber Space Regulation for Protecting Women in UK‟,(2013) available at http://www.igi- global.com/chaptr/cyber-space-regulation-protecting-women/55535 (last visited on September 17, 2014)
 Shobna Jeet, “Cyber Crimes against Women in India: Information Technology Act,2000” Elixir Criminal Law 47 (2012) 8891-8895.
 K.P. Malik, Computer and Information Technology Law (Allahabad Law Agency, 2010.)
 Shreya Singhal v. Union of India, (2013) 12 SCC 73
 Debarati Halder and K. Jaishankar, Cyber crimes against women in india(TMC Academy Journal, Singapore. Vol 3, Issue 1, June 2008. pp. 48-62, 2008)
 Supra note 6.