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'HIV and Women in the Northeast' explores the feminization of the HIV/AIDS epidemic in the northeastern states of India. Shyamala Shiveshwarkar illustrates the reason behind the growing epidemic in the Northeast—that the virus has been extending its reach with high-risk sub populations like injected drug users (IDUs) as well as making inroads with the general population—and focuses on how it is impacting women detrimentally. The region has seen the HIV/AIDS epidemic primarily driven by IDUs; states are combating the double dilemma of drugs and AIDS. Transmission of the virus from IDUs to spouses, sexual partners and children has also been established, which has led to statistical increases in sero-positivity. Given that the “Northeast” is a homogenizing misnomer, the author uses tracking mechanisms to outline how differences in socio-economic and anthropological dynamics contribute to different prevalence rates and changes in infected populations over time.
Shiveshwarkar establishes and elaborates on the critical linkages between drugs, violence, and gender inequalities at the individual, family, and societal levels to establish women’s increasing vulnerability to HIV/AIDS. She asserts that regardless of whether they are affected or infected, women are being forced to take on a greater share of the socio-economic and psychological burdens of stigma and discrimination, violence, caring for the sick and providing for their families. Many women, including young girls who are forced to drop out of school, are made to work to cover the medical expenses of sick spouses or to repay debts. The author takes care to outline the intersection of these vulnerabilities with the political insurgency in these states and explores the problems with existing treatment and care of HIV/AIDS—focusing primarily on its inadequacy and male-centricism, which severely limits women’s access to prevention and care
In her conclusion, Shiveshwarkar, insists on the need to recognize that accessibility is a web of socio-economic, cultural and physical geographical factors: for women, the presence of services alone is insufficient. The author argues that what is needed is holistic reform which includes addressing the drug problem in these states, demanding state-sponsored medical interventions and gender sensitive medical environments.
This essay puts forward a series of accounts centred around the different manifestations of sexual violence in the lives of Dalit women. Unlike in the legal world, in these accounts lines between methods of assault and degrees of injury emerge blurred, and many of them remain unreported or have otherwise not been disclosed by the survivors.
Exposing the vulnerability of Dalit women to both gender-based exploitation and caste-based violence, the essay investigates the threats that follow the women into their homes, their workplace, and the streets. It also looks at the ways in which the survivors’ voice is silenced, time and again, by the authority of the ruling caste. Covering the many different structures that enable and even perpetuate such violence, the essay focuses in particular on the jogini system that legitimises prostitution even as it creates a circle of exploitation and social discrimination. This leads to an analysis not only of the incidents and functions of sexual violence, but also of the consequences that have to be borne by the survivors alone.
The authors explore different kinds of exploitative structures to identify ways in which they hamper women's claims over their bodily integrity, dignity and privacy. They show how the upper-caste discourse of a Dalit woman's sexual availability, along with the impunity for sexual crimes committed against them, is dangerous on multiple levels. It is the study of the contributing factors to this discourse, coupled with the functions and social effects of this particular kind of sexual violence, that the essay concerns itself with.
This essay looks at case studies of sexual violence against women combatants and sympathizers in Northeast India to examine the special vulnerability of this category of women to sexual violence. As Roshmi Goswami points out, at present there are over fifty armed groups in the region making a plethora of demands and situated at different stages in the continuum of conflict. The author argues that women have borne the brunt of this ongoing turmoil—whether they have been specifically targeted by security forces or rival militant groups. Sexual violence is deployed to torture, humiliate people or to punish and humiliate an enemy group or a community that is perceived to be the ‘other’.
The case studies include those of Thangjam Manorama, Snehalata Duara and Roshmi Bora. These cases bring out how issues of sexual violence often remain outside the purview of ‘peace negotiations’, and how the legal regime has provided impunity for armed forces. Goswami also dwells on how the relative or perceived agency of women combatants ends when the ‘militant’s uniform’ is given up. Ex-combatants are often deeply traumatized having experienced and seen violence at very close quarters, and are in need of long term gender-sensitive psychosocial counselling, which is hardly available in reintegration packages and schemes.
The author concludes by questioning the term ‘post-conflict reconstruction’, pointing out its problematic position: ‘reconstruction’ implies restoration to a former status quo that might not be beneficial to women. She states that for feminist peace activists, genuine conflict transformation necessarily brings the notions of justice and peace together, which would entail correcting inequalities and discrimination while ‘reconstructing’.
This essay uncovers how the writings of women have emerged as forms of protest in Assam, a region torn by political violence and prolonged militancy. For Tilottoma Misra, these voices are doing more than simply responding to a need to represent the marginalised; they are attempting to depict the trauma that the women experience in their lives. In discussing the power of the narrative, Misra lays out those aspects of traumatic events that a literary discourse can grasp more expansively than a strictly historical narrative.
Through a discussion of women's writing in the last ten years, the essay explores ways in which women have been affected by violence committed by both the armed forces as well as the militants. Questions of representations do figure prominently in the essay, and the author refers to short stories and poems to illustrate the experience of living through traumatic incidents and moments of devastation. The texts also reveal a desire to create subjects who are able to rise above their immediate political locations and see suffering in a more universal light.
Written by women during times of conflict, these stories and poems help explore nuances of the ways in which one's psyche is affected by the same. With a population facing discoveries of mass graves and an increasing breakdown of basic civic amenities, Misra poses urgent questions as to the role of the writer in such difficult times.
Kalpana Sharma's essay explores the multiple roles that women came to occupy in the riots that took place in Mumbai post the Babri Masjid demolition. As the news of this destruction – carried out on 6th December 1992 – was broadcast across the country, it triggered communal violence, resulting in two phases of riots between the Muslim and the Hindu communities. The essay looks at the people who were some of the most affected by the carnage in the city, the urban poor, and highlights how their specific spatial and economic locations had a great bearing on their lives in this period. By studying the chawl dwellers, the slum inhabitants, and the people who resided on the pavements and analysing how each group had varying responses to the riots, Sharma's study explores what degree of significance their religious identity held during this time.
Sharma argues in her essay that the role of the women during these riots was not defined by their gender identity alone, or even their religious affiliation, but also by their class and their location in the metropolis. Her essay is an attempt to understand why and how these factors held the importance that they did, as her study spans areas of Mumbai which were all affected directly by the chaos. She adopts and reinforces a perspective that is broad, in that it explores women's roles during the riots not only as victims, but also as active participants, ready to fight for survival, and as peacemakers who played key roles in bringing communities together in difficult times.
Feminist movements in India have, both pre- and post-Independence, seen the family and home as the nexus of organizing women’s lives. By the early 1980s, attempts to analyse this nexus had led to examining the codification of women’s rights in marriage and property. It is in this vein that this essay considers the history of the 1985 Shah Bano case and the feminist debates on personal law that it gave rise to.
The call for a common civil code that emerged from the case was extensively critiqued by feminists, liberals and secularists, as well as Muslim religious leaders. The essay traces how the sociopolitical context led to the quick descent of the issue into communal agitation, with a demand that Muslims be exempt from Section 125 of the Criminal Procedure Code that had been cited in granting Shah Bano maintenance from her husband. It describes how Hindu communalism had been acquiring legitimacy in the eyes of the state, and the contribution of this factor to the national fervour surrounding Shah Bano’s case.
Kumar then traces the opposition by various women’s groups to the 1986 Bill, which was introduced in parliament with an aim to exclude divorced Muslim women from the purview of the hotly debated Section 125. She explores the ‘bitter lessons’ that Indian feminists learnt from the public and state responses to Shah Bano’s case, which then posed certain questions that would become increasingly important to feminists in the years to follow. She concludes with questions of secularism–its definition and its practice–and of representation, both of which are brought to the forefront by Shah Bano’s case.
With the Indo-Naga peace negotiations going into their twentieth year and no concrete resolution in sight, the area stands witness to many dying hopes. In this chapter, Dolly Kikon takes an insider's view to re-contextualise incidents of violence in the conflict-ridden terrain of Nagaland. The essay is a product of on-field research and experiences as it analyses the social and legal consequences of sexual violence that exist in the area. It is a singular analysis of Naga society, in that it tracks the different spaces that a survivor of such violence must operate in as it delves into the power relations that characterise each one. It is in this context that the story of one such survivor, called Beth, emerges. Beth's account speaks about the emergence of a culture of impunity that is embedded in the social relationships of Naga society. By locating violence inside the home, the essay investigates these relationships as well as the processes through which such impunity has become an obstacle for women's rights and justice. The area of focus is the Naga woman and her experiences of occupying a space that is fraught with conflict and sexual abuse. This figure is studied as an often-neglected survivor of cultural violence, whose voice is constantly suppressed by the masculine gaze, be it of the insurgent elements or the state armed forces. The essay is replete with real-life experiences and accounts, as it studies the forms of masculinity and suppression that have become pervasive in conflict zones where over the years violence has become naturalised beyond belief.
In this essay, Geetanjali Singh Chanda explores the idea of the nation, and its representation as a house or home in postcolonial Indian English literature. The author identifies that this literature has a dual parentage that manifests in its narratives, where characters with fragmented identities negotiate to make India their home.
Chanda explores this depiction of ‘Indianness’ through three prominent literary works: Nayantara Sahgal’s Rich Like Us (1983), Meena Alexander’s Nampally Road (1991), and Arundhati Roy’s The God of Small Things (1997). She focuses on the treatment of history within these narratives, and the struggle of characters to reconcile their personal or national history with the post-colonial present. This is done by connecting the events in the text to a significant historical event—like the Indian Independence in 1947, or the Emergency of 1975, which becomes the setting of both Rich Like Us and Nampally Road.
While an exhaustive study of the novels’ characters and storyline shows differences in their narratives and the authors’ perspectives, Chanda identifies common themes of disillusionment, belonging, and a complicated relationship with a house, which in each narrative becomes symbolic of the characters’ relationship with the nation. Women in particular seem to have tenuous relationships with the house, often being marginalized in the idea of the nation. But their relationships with each other seem to transcend national and ethnic identities, and help them navigate through the nation. Chanda focuses on these relationships in particular, associating the motherland with the biological mother.
After the success of These Hills Called Home and Once Upon a Life, Temsula Ao returns to her beloved Nagaland to bring readers the beautifully crafted story of Aosenla, a woman who is coming to terms with herself. The novel opens on a typical summer afternoon that soon turns into another oppressive evening. Aosenla sits listening to her children playing nearby and is seized by a great lethargy. As she casts a watchful gaze over the house she has called home for so many years, Aosenla wonders how an inanimate structure like a house can exercise such power over a human being.
Looking down at a wedding invitation in her hands, Aosenla begins to recall her own wedding many years ago, initiating a deep and moving reflection on the life that others made for her and the life that she eventually created for herself.
This essay is a historical overview of Dalit literature, focusing on the contribution of women writers. The authors Urmila Pawar and Meenakshi Moon show how the Dalit movement gained momentum with the rise of Dalit centric newspapers and literary societies, which gave a voice to the Dalit people. Led by Babasaheb Ambedkar, this literary movement was strengthened through talks, discussions, analysis of folk songs, and by spreading literacy and encouraging research. By the 1960s, Dalit writers had created a huge collection of short stories, poems, novels, autobiographies and analytical pieces. The authors focus on the gradual increase of female voices and perspectives in Dalit writing – on topics ranging from religious customs like funerary rites, birth control, to mixed marriages. Some women included larger criticisms of patriarchal societal norms in their writing, advocating for equality. They were especially emphatic about the need for education, urging other Dalit women to take initiative by educating their daughters. The essay also looks at writings on Ambedkar himself, and on Buddhism, the religion that Ambedkar heavily propounded, and later embraced. By providing excerpts of their writings, the essay shows how the women often had differing points of view, leading to healthy discussions and critiques. Appreciating these works for their literary merits as well as social significance, the authors suggest that they helped people understand and appreciate their own history, and facilitated the spread of radical ideas of identity and self-worth.
Gazala Peer’s essay, written against the backdrop of militarization and the existing Armed Forces Special Powers Act in Jammu & Kashmir, explores obstacles faced by survivors of sexual violence in seeking redress when the perpetrators of this violence are members of the armed forces. Through cross-cultural comparisons, Peer describes the extent to which gendered sexual violence is used by nation states in war and conflict situations, and the culture of impunity that accompanies this violence – conditions that have existed, too, in Kashmir since the onset of armed struggle against the Indian state in the early 1990s. The essay establishes the role of Indian authorities in signaling impunity to their armed forces in Kashmir, and goes on to investigate the procedure and function of court martials as justice delivery systems for survivors of sexual violence.
Since AFSPA was imposed on Kashmir, the Indian government has not granted sanction for the prosecution of any armed personnel in any court of law. Although in principle the provision of prosecuting army personnel under court martial trials does exist, Peer questions whether these trials, taking place within the structure of the army itself, can ever be a substitute for trial in civil courts. To this end, Peer closely examines the context and process of the court martial, arguing that this system, in cases of sexual assault and violence perpetrated by its forces (which the army views as “breaches of discipline”), is disposed to be lenient toward the perpetrators, maintaining martial impunity.
Finally, to highlight the hostile and alienating nature of the court martial trial to survivors of sexual violence, and questioning the system’s ability to deliver any kind of justice at all, Peer walks the reader through the experience of four such survivors. Their testimonies and interviews raise serious questions on the basic norms of justice and fair trial vis-à-vis cases of sexual violence tried under AFSPA.
Sheba Chhachhi's piece offers an alternative to the visual landscape of Kashmir which, in the popular imagination of people today, is occupied by the ravages of war and countless martyred men. By placing itself as an invitation into a private space that is rarely, if ever, breached by dominant media discourses, this photo-essay highlights the absences in the pictures of carnage that are used to fuel propaganda on both sides of the conflict.
The piece – comprising of a critical essay and a series of personal testimonies which are interspersed with photographs – seeks to bring human figures back into the landscape and give voice to those whose lives have been obscured in the din of a prolonged war. It makes space for the individual in a history of representation that is populated with recurring tropes and warring stereotypes which, Chhachhi argues, depersonalise the Valley and its conflicts. In her work, women are no longer silent victims, they emerge as textured human beings, not only with voices with which to speak, but also with eyes that are wide open. The testimonies have been taken over a period of six years and reflect varying positions, and the interviewees are students and professionals, Muslims and Pandits, teenagers and the aged.
The photographs are extracted from a larger work which was initially presented as a photo-installation by Sheba Chhachhi and Sonia Jabbar. The photo-essay as a whole captures the life and times of women during conflict, including during the attempted implementation of the burqa diktat in the Valley. These individuated women stand out in the frames as they look back at the viewer in more ways than one.
Please note that the photographs contained in this essay have been directly scanned from the printed book due to the non-availability of the originals.
Avinuo Kire is a fresh, young voice from Nagaland, in India's northeast.
In "The Power to forgive", the title story of this strong collection. Avinuo Kire tells the moving story of a rape survivor who, at the threshold of a new life, looks back on the incident that has shaped nearly two decades of her life and wonders if she made the right choice.
Called from folk and tribal traditions of Naga life, Kire's stories take us into a world where spirits converse with humans, unsuspecting people are drawn into the movement for Naga independence, a man dies quietly of cancer, a mother wonders if she did the right thing in giving her child a name different from the one she intended...
With insight and compassion, Avinuo Kire draws fine portraits of ordinary people in Naga society.
This essay discusses caste, gender and the state, and the relationship between the three in the context of militarization under Peshwa rule in eighteenth century Maharashtra. Analysing materials available in the Peshwa daftar, Uma Chakravarti illustrates the different ways in which the state played a decisive role in upholding the caste system and in installing social codes to legitimize women’s sexuality.
Chakravarti points out how the Peshwa state upheld Brahmanical social order by prohibiting ‘untouchables’ from approaching the temple of Vithoba (which also housed a shrine for Chokhamela, a saint belonging to the Mahar community who were historically considered ‘untouchable’, was associated with the regional Varkari movement), threatening punishment if they failed to conform. Chakravarti casts doubt on whether this traditional practice helped bridge the gap between the upper and lower castes by looking at the effects of the development of other religious practices with the consolidation of the Peshwai.
The institution of marriage and other codes that legitimized women’s sexuality, additionally, were major elements at play in the Peshwai’s organising of gender relations. Chakravarti explores ideological structures of enforced widowhood, the difference in punishment that women and men who committed adultery faced, and the role of the state in arranging marriage for girls between ages seven and ten. Connecting caste with women’s sexuality, the essay gestures towards Brahmanya’s investment in the undiluted purity of its women.
This essay examines women’s writing in the 19th century on the oppression of widows, focusing on voices that writer Uma Chakravarti believes have been invisibilized over the years. Stating that the history of social reforms and widowhood has been predominantly understood from a knowledge-based male perspective, Chakravarti proposes balancing the discourse with several female perspectives based on experiencing widowhood first-hand.
The essay is divided into three parts – the first section focuses on women’s works on widowhood, examining the writing of Sushila Devi, Tarabai Shinde and Rakhmabai. The second section looks at widows from Poona Widows' Home writing about their own experiences, and the third at writers like Pandita Ramabai and Parvati Athavale who were actively involved in providing support to other widows. From scathing criticism to personal experiences, the works criticize the then existing male-dominant Reformist movement, which focused only on widow remarriage, and outline the problems faced by widows, such as deprivation of basic needs like food, clothing and shelter, and the enforcement of unpaid and unacknowledged labour.
Chakravarti thus claims that these works were responsible for expanding the boundaries of the discourse around widowhood, making widows the subject of the issue than mere lifeless objects. She critiques these works, analysing the ideologies and influences of each writer. Through the topic of widowhood, Chakravarti demonstrates how women writers went on to discuss issues of female agency and autonomy, and critique larger patriarchal structures such as religion and family, which reinforced oppressive practices against women.
This chapter from The History of Doing focuses on the late nineteenth century and early twentieth century, when social reform movements in India were beginning to show results and women were becoming more visibly present in the public sphere. Kumar provides a thematic history of the women’s movement before independence, beginning with focusing on the 1889 session of the Indian National Congress in Bombay where ten women delegates attended the assembly for the first time.
Using photographs and a wide variety of print sources from books to newspapers, Kumar looks at how women’s issues were raised and how women were involved in addressing these. Prostitution was one of the first such issues, referred to by the Indian National Congress at their 1888 session. The essay discusses at length the steps taken to regulate prostitution by the British in India and the level of support this received from reformers and moderate nationalists. The turn of the century saw a proliferation of homes for widows, with schemes to train widows as teachers. The Swadeshi movement in Bengal during this time period marked the beginning of women’s participation in national activities on a larger scale.
Kumar offers detailed portraits on the lives of some of the women involved in the above movements and reforms like Swarnakumari Debi, her daughter Sarala Debi Ghosal and Bhikaiji Cama. Kumar also observes that for some of these women, the bid for personal independence grew to be subsumed in a quest for national independence, but that they also returned to their homes without regret when the moment of crisis passed. A large number of the women written about in the essay were writers, both reformists and revolutionaries.
Chakravarti’s essay counters the claim that in the pre-colonial period, a ‘fixed’ Hindu law didn’t exist because of multiple caste laws, by arguing instead that even those separate caste laws were bound by a broader rational framework, enforced as such by the Peshwai.
Chakravarti analyses the three legal issues of widow remarriage, conjugality and the age of consent to explore how the colonial laws affected women; the relationship between the caste panchayat and the larger legal culture of the second half of the nineteenth century, and whether the textual law was more or less repressive than customary law.
Women came under the purview of the colonial law because of a weakening of the caste panchayats, and the new British administration gave men a choice of forum through which to enforce patriarchy.
They were also brought under the colonial state through criminal cases against them, such as those for prostitution and abortion. The colonial state was able to do this effectively because the patriarchal Indian community also had the same goals. Despite the inherently patriarchal nature of colonial laws, women also sought the system out for cases of adoption and rights over their parents’ property.
The essay also points to how cultural nationalism unified ‘Hindus’, placing a Brahmanical patriarchal notion of womanhood instead of caste and regional differences, raising important questions about the relationship among the colonial state, law, family, caste panchayats and gender in the nineteenth century.
The 73rd Amendment (1992) to India’s constitution has not only given rural local governments (Panchayati Raj institutions) constitutional status, but has also ensured that marginalized sections of society such as backward classes and women have reservations in these bodies. The amendment has helped facilitate the entry of rural women in the public sphere. However, the visibility and presence of women in rural politics has been met with a lot of backlash. In this essay, Mayaram uses qualitative data from her fieldwork in Rajasthan to highlight the ‘new modes of violence’ that elected women representatives face.
The essay details the different forms of violence that elected women are subjected too, like physical violence, forced stripping, and verbal abuse. Dalit women face dual stigmatization on grounds of caste and gender. Mayaram’s essay demonstrates how caste politics, the police, and patriarchy form a nexus to protect the perpetrators.
According to Mayaram, there is an urgent need to recognize this backlash and the hindering impact it can have on women’s development. She believes that institutional reform is needed so that implementing agencies like the bureaucracy are sufficiently sensitized to women’s issues, and that structures of support should be created for elected women. Her essay is thus a testament to the fact that having ‘good’ legislation isn’t enough—ground realities have to be taken into account as well to ensure that policies can function effectively.
This piece was written after the abduction of the author's husband by ULFA terrorists in Majuli, Assam where they worked as social development workers in 1996–97. In this chapter, Ghose explores her experience of learning to cope with the aftermath. Moving from personal reflections to discussing universal aspects of such suffering, she throws light on the far-ranging impact of violence that often goes unacknowledged. She then captures the different stages that an individual undergoes in the period of suffering, and consequently looks at strategies of coping which are effective and can transcend harmful responses. By shifting the focus onto the individual's own reaction to violent events, Ghose is able to break down the mistakes that one is susceptible to making almost reflexively – mistakes that perpetuate a cycle of violence.
Written in the form of a prefaced monograph, the title of this piece is drawn from a short course that the author attended in Delhi, which gave her the fresh perspective and strength needed to make this reflective essay a reality. Ghose's insights on responding to events of violence or conflict are embedded in a critique of certain forms of protest as well as what she calls the commonly held 'victim attitude'.
For Ghose, strategies of coping become methods of achieving much more. In a world full of violence and rage where a vicious cycle of the two is kept alive, it becomes imperative to rise above feelings of aggression and victimisation that inevitably cause more harm than good.
Samita Sen’s essay traces the history of the Indian Women’s Movement from the 1920s to the present day. The chronological as well as thematic logic of the essay follows three primary heads: a historical background, the Uniform Civil Code (UCC) controversy, and the political implications of the reservation for women in legislatures.
The historical background highlights four critical issues: the tensions and fractures within the women’s movement, how these fractures were related to the mediated relationship between women and the conception of their ownership by the nation-state, how the differences amongst women could be managed or transcended to create a political community to which women will want to belong, as opposed to being shunted into it, and finally, the issue of women’s agency in politics.
The discussion on the UCC becomes an example of how the community and communal politics are deeply implicated in the politicization of personal laws, and how the rise of nationalism and the politicization of the ‘private’ familial domain placed personal laws at the centre of the colonial-nationalist conflict. The initial consensus amongst the women’s movement for reforming the gender discrimination in personal laws broke down by the time the Women’s Reservation Bill was introduced. This also marked a shift in focus from demanding legislation from the state to a greater participation of women in state affairs.
For Sen, a new feminist politics has to address struggles of class, caste, community, religion et al, without displacing gender as the central concern, making this essay one of crucial importance for understanding the origins of the issues facing feminist politics today.
In this essay, Pratiksha Baxi explores the modes by which the law addresses stripping and parading as a political ritual of atrocity in India at three registers: the naming of the spectacular violence by law; the naming of sites of such corporeal performances in legally plural settings; and identifying the circuits of power that are activated to immunize communities and institutions from naming these acts of injustice.
She illustrates the history of protests against sexual harassment, drawing on watershed legal cases and amendments, starting from the protests by women’s group against the rape of underage tribal girl Mathura in 1979, to nation-wide protests against the Nirbhaya rape case in 2012. Baxi draws extensively on the legal proceedings of Maya Tyagi’s sexual assault case (Sheo Kumar Gupta v State of Uttar Pradesh) and on the case of a young Hindu widow, S, who was sexually assaulted and paraded in her local community after she married a Muslim man (Miss M.S. Annaporani v State of UP). She examines the remnants of colonial law, particularly the laws of “divine displeasure” and “outraging a woman’s modesty” to see how mythic temporalities—like that of Draupadi from Mahabharta, in Mrs. Tyagi’s case—are evoked.
Baxi argues, using this framework, that the stripping and parading of women is constitutive of a public spectacle in which the victim is put on display as a degraded object, having been stripped literally and symbolically of all that is social. The justificatory discourse of such violence constitutes its victims as transgressive subjects who deserve the violence by evoking the language of law or custom. Elaborating on various legal amendments and introductions to judgments, Baxi concludes with analyzing the failings of these in practice. The processes of according dignity remain fraught, she says, when courts insist on hypertechnicalities hollowing the law of its constitutional content
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