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The global escalation of violence against women during COVID-19 lockdown

by Bhavani Kichenin and Catherine Escobedo

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Authors:

Bhavani Kichenin: Director of Women Rights Cohort at BGS – Lawyer in France practicing Commercial Litigation – UC Berkeley LL.M. with certification in Business Law – Graduate of Panthéon-Sorbonne University (France)

Catherine Escobedo: Of-counsel in BARLAW – Barrera & Asociados. UC Berkeley LL.M. with certification in Law & Technology. Lawyer degree CUM LAUDEM by Universidad de Lima (Peru)

Our gratitude goes to the attorneys, member of the Women Rights Group of Berkeley Global Society, who dedicated their time to find and share precious leading information about domestic violence in their respective country :

Ayodele Babalola: Lead Counsel – AOB Willows LP (Nigeria). UC Berkeley LL.M with specialization in Public Law and Energy & Environmental Law. Bachelor of Laws (LL.B) from University of Ado-Ekiti (Nigeria)

Luiza Sato in Brazil: Partner of the Brazilian law firm ASBZ Advogados in charge of the Data Protection, Digital Law and Intellectual Property practices. UC Berkeley LL.M. with certification in Law & Technology. Lawyer degree by Universidade de São Paulo (Brazil)

Suyash Srivastava: Co-Director of Human Rights and Arbitration Cohort at BGS – Advocate and Associate Partner, Avid Legal – UC Berkeley LL.M. with certification in Public law and Regulation – B.B.A. LL.B. – The NorthCap University (India)

Tracy Anne Ong in the Philippines: Lawyer in the Philippines in Corporate and Technology Law – UC Berkeley LL.M. with certifications in Business Law and Law and Technology. Juris Doctor (J.D.) from the University of the Philippines.

INTRODUCTION

There are sufferings which we, as human beings, can’t ignore and violence targeting women is one of them.

Hence, because all eyes have naturally been starring at how Governments handled COVID-19 pandemic these past months, this article aims at striking the attention on a distressing consequence of the pandemic: the escalation of violence against women during lockdown.

If, according to the World Health Organization, violence against women was already a public health problem which reached epidemic proportions worldwide, emergency situations – especially lockdowns – only increase it [1].

We have seen this happening during the Ebola [2] (2014-2016) and Zika (2015-2016) outbreaks, when both rich and poor countries experienced a rise in domestic violence rates. However, policy makers keep on adopting a gender-neutral approach to pandemics and miss opportunities to collect high-quality data which will be useful for the future [3].

Thus, not surprisingly, COVID-19 lockdown made no exception to this phenomenon, making United Nations chief António Guterres call countries worldwide, on April 6^th, 2020, to take measures to address a “horrifying global surge in domestic violence” towards women and girls [4].

The deplorable increase in violence against women, a drama observed around the world

While measures of lockdown have been widely taken, all countries with available figures have reported a significant augmentation of violence against women.

When discovering the striking figures bellow, one has to take into consideration that it’s more than likely that real figures are even higher, as women, being constantly with their aggressors, have less possibility to report about their ordeal.

According to the UN, comparing April 2020 to April 2019, calls to helpline have tripled in China, and doubled in Lebanon and Malaysia [5].

In South Africa, more than 12,000 victims rang the national helpline for abused women and children in the first three weeks after lockdown started, on March 27^th,2020, doubling the usual volume of calls [6].

Besides, the WHO reported that calls to European domestic violence hotlines spiked by as much as 60% in April[7].

The United Nations entity, UN Women, added there was evidence of rising violence against women in Mexico, Brazil, and Colombia, and a doubling in the number of femicides (also addressed as “feminicides”) in Argentina during quarantine [8].

Thanks to the precious work of BGS members, we have been able to collect specific information about Brazil, France, India, Peru, Nigeria and the Philippines.

In Brazil, lockdown began on March 24^th, 2020, in the State of São Paulo. The independent organization Forum de Brasileiro de Segurança Publica (FBSP) has compared violence against women in March 2019 and March 2020. It came up with alarming numbers:

Femicides in various Brazilian states highly rose:

More 400 % in Mato Grosso;
More 300 % in Rio Grande do Norte;
More 100 % in Acre; and
More 46,2 % in São Paulo.

However, FBSP announced a reduction of official filings of intentional physical injuries, a process which requires women to physically appear before the authorities to file their complaint:

Minus 21,9 % in Mato Grosso;
Minus 9,4% in Rio Grande do Sul;
Minus 28,6 % in Acre; and
Minus 8,9% in São Paolo.

These contradictory numbers reveal the great difficulties for women to report about their aggressors due to the absence of privacy during lockdown.

This contradiction was also noticed in France, where lockdown began on March 17^th, 2020. The French Region of Val-d’Oise noticed that calls to the police increased by 25 %, however 20 % less complaints were filed.

On a national level, police interventions concerning domestic violence have increased by 44% compared to the same period in 2019 and calls to hotlines have doubled[9].

In India, where lockdown began on March 24^th, 2020, a 60 % increase of complaints to hotlines was reported by the women’s rights organization, Swayam [10].

Besides, complaints received by the National Commission for Women (NCW) doubled since lockdown, and in April 2020, 89 % of total cases registered were of domestic violence[11].

Indian women living in rural areas are even more vulnerable. Indeed, not only are they facing domestic violence, but they have twice as much risk to be sexually assaulted from non-partners encountered on the multiple miles road they have to walk to get firewood for cooking and open defecation [12].

In Peru, the situation was already alarming since, according to statistics from the Ministry of Women and Vulnerable Populations (MIMP), 84 cases of femicides, 204 of attempted femicides, 7,332 of sexual violence and 29,761 of physical violence were reported from January to June 2019 [13].

During quarantine, starting on March 15^th and until April 25^th,2020, 16,000 calls and queries via hotline or chats have been registered, 6 femicides and 150 cases of rape were reported[14].

In Nigeria and the Philippines, there is no official data on domestic violence calls to the Police, nor centralized data on the number of complaints filed during lockdown.

Hence, visibility on the current situation is only possible considering the data before lockdown.

On this basis, in Nigeria, it has been reported that 28% of women aged 25 to 29 have experienced some form of physical violence since aged 15[15].

The same study reveals that 44% of divorced, separated or widowed women reported experiencing violence since age 15, while 25% of married women or those living with their spouses have experienced violence[16].

Violence against women in Nigeria takes the form of sexual harassment, physical violence, harmful traditional practices, emotional and psychological violence and socio-economic violence [17].

In the Philippines, the Center for Women’s Resources (CWR) reported in March 2020, that one woman or child is abused every 10 minutes. CWR executive director, Jojo Guan, stressed that this data, while already alarming, “does not paint the complete picture of VAW (violence against women) in the country” since only 6 percent of women victims seek help from authorities according to the 2017 National Health and Demographic Survey [18].It is further reported that one in four women aged 15 to 49, have experienced sexual, physical or emotional abuse from their husband or partner.[19]

If reporting about what is happening behind closed doors appeared impossible, Philippine news outlets have reported about more visible types of violence, taking various forms.

First is the online violence, being particularly aggressive in a time where social interactions are almost exclusively via internet. The Commission on Human Rights (CHR) reported an intensification of peer-to-peer online cyber-violence against women and girls. These include posting on social media explicit videos and photos depicting sexual activity or promiscuity without the consent of the woman. The perpetrator is usually her ex-partner [20].

Harassment by police and military officers at checkpoints where they are stationed to patrol borders have also been reported. Government rules require only the presentation of a company ID, certificate of employment, or other relevant documents upon passing through [21]. However, a Twitter user has reported that a ride-hailing company’s rider was forced to give up his woman passenger’s number at the pain of being issued a ticket and his license being confiscated [22]. Other similar incidents have also been reported online.

Considering these striking figures, the increase of violence targeting women during lockdown has indisputably been a worldwide issue, requiring scrutinizing its causes.

Understanding the reasons behind the increase of violence during quarantine: key to build an effective system

Though there is no legitimate reason to justify why gender-based violence increases during lockdowns, understanding what is behind this phenomenon is critical to develop the necessary policies to prevent it.

According to UN Women, being stuck in close quarters with a perpetrator of abuse and having no way of seeking recourse increases the chances of incidents taking place [23]. In addition, most of the other documentation mentions isolation, stress, alcohol/drugs consumption and financial difficulties as triggers for violence at home.

For Shailey Hingorani, Head of Advocacy and Research at AWARE (Singapore), these reasons are closely associated with family violence’s roots in power and control[24]. As during pandemics people’s lives seem out of control, and unemployment and economic hardship at the household level increase, abusers try to regain some semblance of control by hurting their victims. Besides, stay at home orders increase social isolation on the victims, as continuously living under the same roof with their aggressor makes it almost impossible to have an opportunity to seek help from local authorities or to file any legal actions or complaints without being caught.

Furthermore, victims fear to seek shelter with friends and family because they could expose themselves to the virus. Not to mention that, even if the victims intend to leave an abusive relationship, being able to be financially independent (and sometimes support their children) could become more difficult with the upcoming world economy recession and the consequent risk of losing their jobs or income.

This question was also raised by the Sao Paulo Public Prosecutor’s Office when writing their Technical Note entitled “X-RAY of domestic violence during isolation. A portrait of São Paulo”[25]. To them, along with isolation of the victims and unemployment, consumption of alcohol or illicit drugs is also considered a reason explaining this raise. Indeed, their use affects the individuals both physically and mentally.

The WHO also addressed this problem when analyzing how COVID-19 can exacerbate risks of violence for women, mentioning – besides the reasons and examples listed above – the following examples:[26]

Perpetrators may restrict access to necessary items such as soap and hand sanitizer, exert control by spreading misinformation about the disease and stigmatize partners;
Access to vital sexual and reproductive health services, including for women subjected to violence, will likely become more limited;
Other services, such as hotlines, crisis centers, shelters, legal aid, and protection services may also be scaled back, further reducing access to the few sources of help that women in abusive relationships might have.

Anita Bhatia, the Deputy Executive Director of UN Women, in an interview for the TIME, reflected on how “the very technique we are using to protect people from the virus can perversely impact victims of domestic violence.” She added that “while we absolutely support the need to follow these measures of social distancing and isolation, we also recognize that it provides an opportunity for abusers to unleash more violence.”[27]

In this complex context, Governments around the world have adopted different responses.

III. Tailor-made measures adopted in response to the surge of violence against women

In most countries, addressing the escalation of domestic violence during lockdown was of secondary concern behind the combat against the spread of COVID-19, involving for developing countries, struggles to provide primary resources such as food [28].

Though, endeavors were made to try and tackle this issue.

Along with measures shared by a great majority of countries, certain specific actions have been implemented depending on the country.

Among initiatives taken by a great number of countries are those strengthening their existing system of hotlines and chat number to seek help by:

Appointing more people to receive calls and messages asking for police or medical help;
Creating more means to reach them with the creation of additional hotlines, chat numbers, online applications, links on social medias;
Adding assisting services including psychological assistance

In addition to those means, each country our BGS members have reported about, has framed specific means to combat the surge.

Nigeria has joined private and public forces to fight the escalation of violence.

In Nigeria, where reporting aggressions against women is also an issue, stakeholders have joined the battle, pairing with Civil Society Organizations (CSOs) and family support units. They joined their forces to track domestic violenceduring the COVID-19 crisis to eventually present this issue to the authorities and ask them for an effective response [29].

Police surveillance of strategic areas has also been established. They are patrolling neighborhoods, streets, major roads, and surveilling communities, places of worship, markets, shops and other areas of coverage.

The Philippineshave specifically addressed online violence and harassment at checkpoints by reiterating their Safe Spaces Act.

The Safe Spaces Act punishes acts using information and communications technology in terrorizing and intimidating victims through physical, psychological, emotional threats. It also sanctions sexual misogynistic and sexist remarks and comments online, whether made publicly or through direct, private message. The Act also prohibits relentless requests for a woman’s personal details such as name, contact and social media details or destination.

Furthermore, the Philippine Commission on Women has ordered agencies to adjust their 2020 Gender and Development Plan and Budget to respond specifically to the COVID-19 situation. Adapted measures may relate to providing dedicated hotlines to report gender-based violence cases, online counseling, and repurposing spaces to expand shelters for gender-based violence survivors.[30]

Brazilhas worked on strengthening its repressive judicial system.

Indeed, bills were drafted, aggravating sanctions in case of domestic violence during quarantine.

As an example, PL 1319/20 provides that penalties applicable to crimes of domestic violence during quarantine are doubled.

France has made open shops be relay for hotline centers.

In France, reproducing the Spanish system, Government has designated pharmacies as cooperators, remaining one of the only shops still open during lockdown.
Prospects on how to handle a victim seeking help were made to be distributed to pharmacists. It instructed them that if a woman needs help, they have to take the victim to the back office and call the police or, explain to the victim the procedure to get help [31].

France also created a special police intervention procedure aiming at taking the violent partner away from the house and place him in special shelters during lockdown [32].

Peru has focused on educating the population, targeting both women and men.

Series of booklets have been elaborated by the Ministry of Women and Vulnerable Populations, Associations and Organizations, and were distributed to the population. They raise awareness on the fact that special lockdown time is not an open door to violence, that help is available and on how to reach it [33]. They also procured practical advice to couples about sharing tasks at home, building equality between partners as a fundamental premise to avoid violence [34].

Moreover, trash collectors, as rare ones who can be in direct contact with victims at their home, have been trained to receive victims denounces and give them information about available tools to seek help.

Peru has also addressed its specific problem of women in rural areas, whom isolation is emphasized, through its Urgent Itinerant Care. With telephone coordination with the community authorities and indigenous leaders, they can identify and intervene on cases of violence in rural communities. This led to 58 interventions so far [35].

In addition, booklets which are not accessible to the most remoted, and messages containing information and advice “notes” on a healthy coexistence, have been slipped into food baskets to reach them.

Indiahasstrengthened its endemic “protection officer” system.

Delhi High Court has directed the Government to deliberate on measures to curb domestic violence. It responded strengthening its specific system of protection officers. They have initially been created in 2005 through the Protection of Women from Domestic Violence Act.

A protection officer is a qualified social worker and is identified as key person in the implementation of the law. Her role is to assist a woman from the stage of registering her case, taking her case to Court and ensuring that court orders are implemented [36].

They can be found on lists available online.

This system was strengthened during lockdown, by appointing a greater number of protection officers.

As observed, various weapons were thought to address the increase of violence against women during quarantine. But have those means indeed helped?

Can it be said that Governments managed to build an effective system addressing this surge? It seems there is long road ahead

As mentioned above, thanks to the BGS members, we have been able to obtain very valuable information on how different countries in the world are facing this problem. We also asked them to share their opinion on whether the current measures taken by their respective Government were really making a difference, and we hereby share their answers.

In Brazil, France and Peru, although not yet perfect, measures seem to be promising. The common problem is that even when in theory good measures are being implemented, in reality very few people is aware of them.

To Luiza Sato, measures are probably not effective in Brazil, since domestic violence complaints are declining however feminicide cases are increasing. “With the aggressor inside the house, it seems hard for the victim to seek for help with the current tools in place or with the low dissemination of such tools” which existence she only learned on the occasion of her research for this article. However, she believes that “the tools created to help victims of domestic violence with the aggrieved situation of the pandemic are adequate and it will be incredible if the bills aiming to contain the increase in cases of domestic violence during quarantine are approved.”

In France, Bhavani Kichenin strikes Associations alerts reporting that the procedure aiming at taking the violent partner away, is not always implemented. Not only weakening the process itself, it discourages victims to call the police, fearing revenge from their aggressor.

She also regrets that making pharmacists be recipient of victims’ complaints has not quite been a success. Indeed, police stations, lawyers and prosecutors in some cities have declared not having received a single case through pharmacists help. A Women rights federation, FNCDIFF (National Federation of Information Centers about Women and Family Rights), blames the slowness in giving pharmacists tools to help. For proof, some pharmacies still don’t have the explanatory booklets on how to deal with women seeking help. Bhavani adds that “it’s a good thing that such measures have been taken, but as long as people know about it.”

She, as Luiza, regrets that the only reason she learned about most of them is because of her research for the purpose of this project. “There is an obvious lack of communication, tremendously weakening the effectiveness of the system”.

The case of Peru is not different for Catherine Escobedo. She cited an article published by the United Nation Development Program (UNDP) in Peru which mentions that even when Peru lead important efforts to stop domestic violence during the health crisis early on, “the action of local government was also indispensable and by far necessary[37]”.

In Catherine’s opinion “while it is praiseworthy that the Government has invested time and money to elaborate certain measures, the fact that – for example – the informative booklets are available just online makes it difficult for the rural population and the one in situation of extreme poorness which don’t have the means to access the internet or don’t have a cellphone, to access such information. Thus, only “half” the problem is resolved.

Besides, it is very important to train the police and local authorities for the prompt and due attention and response to the reports of assault or rape filed by women. The measures contained in the recently issued Legislative Decree No. 1470 [38] are a huge advance, but if the authorities which are in charge of its fulfillment don’t execute it (as they haven’t executed previous laws in favor of women which are fully in force) it will just be a nice text full of good intentions.“

In the case of the Philippines, as of mid-April, the Government has worked almost exclusively with existing pre-pandemic measures, considering that more tailored measures (e.g. readjustment of government budget) will take more time to be implemented.

To Tracy Ong, existing measures are not particularly sensitive to the plight of the woman on lockdown, and are thus not sufficient.

She added that “as reported by the Commission on Human Rights, it is hard for the women to report by call within their homes for fear of being overheard. If that is the case, then special attention should be given to more silent reporting, maybe through social media or other means. Even social media measures may not be fully effective because women who are closely monitored are often not allowed to use their phones. Even if they were allowed, the lack of money during this period would not allow them to have the needed call and internet services. If so, we might want to look at measures that capitalize on the traditional roles that women play in the household (still pervasive today)- like buying food and groceries. If women are allowed to go out to the public markets to buy food, then the alarm systems must be installed there. It is often in these situations only that women are allowed to use the quarantine pass, which is given one per household only. If the woman is not allowed to hold this pass at all times; in the moments that she could, we should ensure that she has access to the help she needs.”

Finally, in Nigeria and India, the biggest challenge has been to try to plan effective policies with the very limited available data.

To Ayodele Babalola, from Nigeria, to reduce the number of unreported cases, thus, obtaining useful data, a duty should be placed on Doctors and other Medical Personnel to report to the Police for further investigation against suspected cases of gender violence, and the Police should invest more resources on creating a database for those complaints.

He also reflects on how “countries should strive towards achieving resilient rather than response-based approaches. This will ensure that systems are already in place instead of just setting them up when an event happens.”

Finally, regarding India, Suyash Srivastava shared his concerns that it will be a while before they really know if the measures taken by the Government were indeed effective and helpful because “many organizations working in this area believe that the country has seen a sharp increase in cases of domestic violence and the cases are underreported”.

As it can be observed, these 6 different countries, representing South American, European and Asian regions of the world, face different challenges while fighting the increase of violence against women during lockdown. However, we believe that there are three main common lessons to be learnt.

Firstly, the importance of the collection of data. Governments need to rely on data collected in similar past situations before building and implementing public policies. This will highly contribute to their success;
Secondly, the importance of the sustainability of the measures taken. Governments should keep building long term assistance and educational systems and keep improving them to be prepared to face extraordinary times like the current ones;
Thirdly, the importance of the dissemination of information. Governments generally needs to communicate efficiently about the tools created to protect women from gender-based violence. Furthermore, they have to ensure that the population, no matter how far they live or what language they speak, learn about the existence of those tools.

CONCLUSION

It’s said that crisis worsen existing abuses, and gender-based violence against women made no exception to this dismaying statement. It’s regrettable as it should never be a matter of having to choose between confinement for the purpose of general health and preserving women’s physical and psychological safety.

However, a crisis can always be an opportunity for improvement. After all, hasn’t this lockdown led a great number of Governments to work on providing a better protection to women?

Hoping Governments retain the lessons learnt from this crisis, maintain the measures taken those past days and continue building on them, this appalling situation can lead to better days and eventually contribute to bring an effective response to a gangrene which has lasted for too long.

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[1] https://www.who.int/reproductivehealth/publications/emergencies/COVID-19-VAW-full-text.pdf?ua=1

[2] https://www.reuters.com/article/us-health-ebola-women-idUSKBN0ME30520150318

[3] https://www.theatlantic.com/international/archive/2020/03/feminism-womens-rights-coronavirus-covid19/608302/

[4] https://news.un.org/en/story/2020/04/1061052

[5] Ibid.

[6] https://news.yahoo.com/just-got-worse-domestic-violence-surges-under-africa-093359671.html

[7] https://www.euronews.com/2020/05/07/who-deeply-troubled-by-spike-in-domestic-violence-in-locked-down-europe

[8] https://www.nbcnews.com/news/latino/another-pandemic-domestic-abuse-calls-spike-latin-america-during-coronavirus-n1193281

[9] https://www.francetvinfo.fr/sante/maladie/coronavirus/enquete-franceinfo-quelles-reponses-ont-ete-donnees-aux-signalements-des-violences-faites-aux-femmes-pendant-le-confinement_3964513.html

[10] https://timesofindia.indiatimes.com/city/kolkata/domestic-violence-on-the-rise-as-women-fail-to-reach-out-for-help/articleshow/75652359.cms

[11] https://www.epw.in/engage/article/covid-19-domestic-abuse-and-violence-where-do

[12] https://thewire.in/women/covid-19-lockdown-domestic-violence

[13] https://peoplesdispatch.org/2019/08/20/peruvian-feminists-demand-an-end-to-gender-based-violence/

[14] https://www.gob.pe/institucion/mimp/noticias/131657-aecid-pnud-banco-mundial-y-mimp-trabajando-en-conjunto-para-prevenir-la-violencia-contra-las-mujeres-en-tiempos-de-emergencia

[15] https://www.un.org/africarenewal/news/nigerian-women-say-%E2%80%98no%E2%80%99-gender-based-violence

[16] Ibid.

[17] Ibid.

[18] https://news.mb.com.ph/2020/03/05/cwr-one-woman-or-child-abused-every-10-minutes/

[19] https://www.cnnphilippines.com/life/culture/politics/2020/4/6/womens-needs-COVID-19.html

[20] https://www.gmanetwork.com/news/news/nation/734922/condemns-rising-online-sexual-harassment-vs-women-amid-covid-19-pandemic/story/

[21] https://www.rappler.com/nation/254498-workers-guidelines-metro-manila-lockdown-coronavirus

[22] https://www.interaksyon.com/celebrities/2020/03/26/165098/reports-harassment-women-muslim-checkpoints-pnp-afp-bela-padilla/

[23] http://www.effective-states.org/covid-19-and-domestic-violence-caring-states/

[24] https://www.channelnewsasia.com/news/commentary/coronavirus-covid-19-family-violence-abuse-women-self-isolation-12575026

[25] http://www.mpsp.mp.br/portal/pls/portal/!PORTAL.wwpob_page.show?_docname=2659985.PDF

[26] https://www.who.int/reproductivehealth/publications/emergencies/COVID-19-VAW-full-text.pdf

[27] https://time.com/5803887/coronavirus-domestic-violence-victims/

[28] http://www.effective-states.org/covid-19-and-domestic-violence-caring-states/

[29] Teresa Chigozirim Okoro, COVID-19 Lockdown: Rising Cases of Sexual and Gender-Based Violence against Women and Girls, Sahara Reporters, 17 April, 2020

[30] https://www.pcw.gov.ph/law/adjustment-andor-implementation-fy-2020-gad-plan-and-budget-view-coronavirus-disease-2019-situation?fbclid=IwAR1PMdSj8vCAC4pHQA0iPaYCw7AC0JZpv1eOukpzBL8-hETxtZzFSLPjO1Q

[31] http://www.leparisien.fr/faits-divers/confinement-un-dispositif-d-alerte-dans-les-pharmacies-pour-les-femmes-violentees-26-03-2020-8288838.php

[32] https://www.francetvinfo.fr/sante/maladie/coronavirus/violences-intrafamiliales-comment-donner-l-alerte-et-agir-durant-le-confinement_3907175.html

[33] https://www.mimp.gob.pe/files/Cartilla-Vivamos-sin-violencia.pdf , http://www.mimp.gob.pe/files/cartilla-pnud-victimas-covid-19.pdf

[34] https://www.mimp.gob.pe/files/cartilla-vivamos-aislamiento-con-igualdad.pdf

[35] https://www.gob.pe/institucion/mimp/noticias/126699-mujeres-ninas-ninos-y-adolescentes-victimas-de-violencia-de-zonas-rurales-cuentan-con-atencion-especializada-del-mimp

[36] “Women and Domestic Violence Law I India: A quest for Justice “ by Shalu Nigam

[37] https://www.pe.undp.org/content/peru/es/home/presscenter/articles/2020/la-otra-pandemia–violencia-en-el-hogar-en-tiempos-de-cuarentena.html

[38] https://busquedas.elperuano.pe/normaslegales/decreto-legislativo-que-establece-medidas-para-garantizar-la-decreto-legislativo-n-1470-1865791-1/