Published April 2019
Regional Perspective: Pacific Islands Region - added in November 2019
This module is a resource for lecturers
Exercises and case studies
Answer the following questions:
- From your perspective and experiences, what is gender?
- How is it different from sex?
- Provide at least one example of how gender and crime are represented in your country's media, political, social and/or law enforcement discourses. What genders are represented, and how?
- Do you think that women's styles of leadership and enforcement differ from men? If so, how?
- What are women's roles in crime and organized crime in particular? Which elements shape these roles?
In-class activity: Ice-breaker
The Power Walk Exercise
To help students understand the idea of (gender) privilege, and to make them aware of their own privilege, lecturers can ask the students to do the "privilege walk" shown in this short four-minute video clip. To avoid causing discomfort and embarrassment to the students, it is recommended to use the role-play method and assign fake identities to the students (e.g. male lawyer, female police officer). Sample statements for the exercise are widely available on the Internet (see, e.g., here and here and here). The UN Women Training Centre, in its Compendium of Good Practices in Training for Gender Equality (p. 64), calls this exercise the "Patriarchy and the Power Walk", and provides the following guidance:
Statements suggested by UN Women for this exercise include:
Identities suggested by UN Women include: male lawyer with private firm, ten-year-old street boy, grandmother taking care of orphans, unemployed single mother, male storekeeper, female police officer, blind elderly man, male school teacher, female member of parliament, migrant ethnic minority, male literate factory worker, etc. These suggested identities and statements were used by UN Women in its Gender Mainstreaming Course, Bangkok, October 2017.
If it is difficult to conduct this activity due to time constraints and space limitations, lecturers can show the students the video clip. The Singapore version of the clip is available here. Note that this exercise will lead to a discussion that goes beyond gender.
Drunktown's Finest , a film from Indigenous filmmaker Sidney Freeland - a transgender Navajo woman - explores the lives of three young people trying to leave Gallup, a city in the Navajo reservation (a US government-established territory for indigenous peoples). Freeland has stated the title of the movie came from a report in American media that referred to Gallup, her hometown, as "a drunk town," and from her ensuing desire to tell a story from Indigenous people's own perspectives.
The movie follows the lives of Sick Boy, Felixia and Nozhoni, as they try to make sense of their lives in and out of Gallup. While many young Indigenous people opt to move out of the reservation into larger cities, their ability to pursue viable options may continue to be limited because of factors like discrimination, lack of occupational training or education, or their perception as uneducated, violent, alcoholic, etc. Racist perceptions of Indigenous people, combined with notions tied to gender further limit paths for youth, leading some to engage in risk-prone or illicit activities that may also be criminalized, like drug trafficking or sex work. Empirical research in gender and race has shown that in the US non-white men and women are more likely to be perceived and labelled as criminals. This stigma is furthered not just for the occupational choices they make, but also because of their ethnicity and gender. An approach that recognizes how perceptions connected to gender become compounded with race and class and create barriers that limit the acceptance and integration of specific groups of people (a concept called intersectionality), is central when talking about crime, and particularly when discussing the administration of justice. In the United States, for example, disproportional numbers of ethnic minorities are incarcerated - this means that the number of people of non-white origin in detention facilities exceeds those of white people, who are the majority of those in society. Intersectionality helps us see how different systems (race, class, gender) become interlocked, creating inequality.
Adapted from: IMDB (2014). Drunktown's Finest; Variety (2014). Sundance Film Review: 'Drunktown's Finests'. 29 January 2014; Vogue (2015). Why You Should See Drunktown's Finest This Weekend . February 19, 2015.
Who is represented in organized crime research and how?
Select a series of resources (books, articles, movies, etc.) on the topic of organized crime that you typically use/would use in class. Assign students into groups and have them discuss the following questions (this is also a useful exercise to evaluate your own materials and to enlist students in helping each other identify materials that reject/support biased or uninformed perspectives and in turn ensure gender inequality is not perpetuated).
Activity adapted from: Rutgers Center for American Women and Politics. Gender Lens. New Jersey: Rutgers University; Vicerectorado de Empleo y Acción Social de la Universidad Politécnica de Valencia (2013). Buenas Prácticas para una Comunicación no Sexista. Valencia: Universidad Politécnica de Valencia; Consejo Nacional de la Cultura y las Artes del Gobierno de Chile (2016). Guía del Lenguaje Inclusivo de Género. Santiago: Consejo Nacional de la Cultural y las Artes.
Why are more Māori women and girls being jailed in New Zealand?
Dr Tracey McIntosh is an Associate Professor of Sociology at the University of Auckland. As a Maori woman, she has researched the experience of young Maori girls and women in prisons. She has done extensive research on the incarceration of both male and female prisoners (particularly of indigenous peoples), and the influence of colonialisms on social welfare and criminal justice system on Māori men and women, particularly those who have become imprisoned.
"The British annexed Aotearoa/New Zealand in 1840. Through this process, the Māori, as the Indigenous people of that country, lost their sovereignty through the imposition of and application of new policies, including law and unfamiliar legal and social codes brought by the British." McIntosh's states. "Throughout history, and abusive state policies have informed and constructed the life pathway of Māori gang members, a culturally and socially-submerged population."
In Indigenous Insider Knowledge and Prison Identity, McIntosh explains how if incarceration was simply a Maori issue "one would expect to see Maori prisoners coming from all socio-economic categories and reflecting the broader Maori population. Yet the Maori prison population overwhelmingly comes from communities that live under conditions of scarcity and deprivation (…). Attention should be concentrated on whether the proportion of Māori who are young, male, unmarried, unemployed, uneducated, in substandard housing, is reflected in the apprehension statistics. Rates of recorded offending, and hence imprisonment, are well known to depend on a range of social development factors, yet these are often ignored." Furthermore, the Maori experience of prison is gendered," and while statistics are scant on women, "to fully understand the inter-generational aspects of prison life in New Zealand it is thereby critical to likewise understand the experiences of Maori women."
See: McIntosh, Tracey and Stan Coster (2017) "Indigenous Insider Knowledge and Prison Identity." Counterfutures, 3 (68-98). Aotearoa; Radia New Zealand (RNZ) (2015). Why more NZ women, particularly Maori are being jailed. RNZ, April 2015.
Performing Masculinity: Indigenous Street Gangs
Colonization has been known to limit the participation of Indigenous peoples in many western societies, forcing some Indigenous men to search out paths to gain power, respect, and economic capital to survive. Robert Henry is a Métis indigenous man from Prince Albert, Canada and is an Assistant Professor at the University of Calgary. He argues that socio-political histories and ideologies that are shaped by colonization have led to the creation and proliferation of urban Indigenous street gangs.
Henry's work examines the histories of former male indigenous street gang-members in Canada. He has studied the men's relationships with their parents, siblings, family, peers, and social institutions to get a better understanding of their linkages to street gangs. Henry has identified how the street gang epitomize the notion of the ideal "man" - tough, independent, emotionless, and powerful. Yet an analysis of the men's narratives and the photographs they take of themselves and their contexts reveal male gang members' notions of masculinity are deeply impacted by violence and trauma. It was through violent and traumatic experiences that the men would create a kind of "mask" that would help them engage in hyper-violent behaviours, yet simultaneously protect them from further victimization.
Why should we focus on men when we talk about gender? Few political or scholarly resources are devoted to indigenous men's issues - even though they are also (although differently) impacted by the imposition offender roles and identities. More native researchers are developing work that addresses the ongoing negative effects of colonialism on women, children, and men in Indigenous communities and explores how the performance of positive and healthful masculinities can restore balance.
Adapted from: Innes, Alexander and Kim Anderson, (eds.) "Indigenous men and masculinities: legacies, identities, regeneration". University of Toronto Quarterly, 83(3) 2017. 242-244.
Teenage mafiosi in Naples
Roberto Saviano is an Italian journalist, book author and expert of organized crime, who has lived under protection for years because of the threats he received from the mafia. Best known for his internationally best-selling book Gomorrah (as well as the movie and TV series that were based on it), he recently (2016) published a book describing a new breed of gang, the Piranhas, groups of teenage boys who divide their time between social media and patrolling the streets armed with pistols and AK-47s, terrorizing the locals to let them know they mean business. A real-life phenomenon, the Piranhas are no "baby gang", but a real enterprise of young criminals who did not come up through the Camorra, Naples's dominant organized criminal group. Many of them are ruthless teenagers who look for status and recognition in a life of crime.
The Piranhas (loosely translated from the Italian "La Paranza dei Bambini", literally "The Fishing Trawler of Children", suggesting the tiny fish who are attracted to a bright light by night-time nets meant for bigger fish) tell the story of a gang led by a clever but cold-hearted high school student, Nicolas Fiorillo. Son of middle-class parents, Nicola is obsessed by manifestations of wealth and luxury and concentrates all his adolescent attention on joining the ranks of the privileged who can drink champagne on plush sofas and dance all night on expensive restaurant's sea terraces. Steeped in the mythology of the Camorra, what Nicolas most wants is power over others. In the book's only scene where Nicola is at school, the boy impresses his teacher with a reading of Machiavelli's famous assertion that a prince should aim at inspiring fear rather than love. Very soon, he is transforming his friends into a gang of dealers and thugs. He plans an ascent to godfather status and executes his plans through intimidation, thefts, random shootings from racing scooters and cold-blooded executions. The novel was brought to the big screen in the homonymous film that won the Silver Bear Best Script Award at the 69th Berlinale (Berlin Film Festival).
Adapted from: Parks, Tim (2018). The Piranhas by Roberto Saviano review - teenage mafiosi in Naples. The Guardian, 28 September 2018; and Fisher, Ian (2018). In 'The Piranhas,' the Chronicler of Italy's Mobsters Tries His Hand at Fiction. For a Change? The New York Times, 30 August 2018.
Who are Kazakhstan's drug traffickers?
The following paragraph by Martha Olcott and Natalia Udalova describes the landscape of Kazakhastan's drug trafficking:
"The profile of a typical drug trafficker has also changed, further exacerbating the work of law enforcement groups. Most of those now involved in the operation have no prior convictions. Women are playing a more important role in the business. Since 1996 their share has increased from 3 percent to 12.2 percent in Kazakhstan; women constituted 35 percent of those convicted of drug crimes in 1998 in Tajikistan and 12.4 percent in Kyrgyzstan. Women usually accept less pay for their courier services. In case of arrest they are less likely to give up their suppliers because of a stronger desire to protect their families, and they are more likely to get shorter sentences due to the courts' general leniency toward women, particularly toward those with children."
See: Olcott, Martha and Natalia Udalova. Drug trafficking on the Great Silk Road: the security environment in Central Asia. Working paper. Carnegie Endowment, 2000.
White Slavery - the origins of the anti-trafficking movement
"The foundation of modern anti-trafficking legislation in England was created between 1885 and 1912 through a series of legal interventions. The dominant white slavery discourse at the turn of nineteenth century was largely constructed around the juxtaposition of dangerous, foreign men [against] innocent, white women. The narratives toyed with details of innocence and ruin of the victim, coupled with the demonization of foreign men. Anxieties about race, nationality, and immigration underpinned much of the debate on trafficking. Indeed, the racially neutral term 'traffic' only replaced 'white slavery' in international law in 1921 at the League of Nations International Convention to Combat the Traffic in Women and Children.
In England, the campaigns against white slavery culminated when in 1885 tens of thousands of people demanded that white slavery be outlawed and the age of consent for girls be raised. The first adopted measure was the Criminal Law Amendment Act (CLAA) which was significant for it created a specific definition of trafficked girl - the involuntary prostitute. It made it an offence to procure "any girl or woman under twenty-one years of age, not being a common prostitute, or of known immoral character, to have unlawful carnal connexion." By including the words "not being a common prostitute, or of known immoral character", the section excluded from the law not only those working in prostitution but also any women considered promiscuous or not respectable. Therefore, if a woman was already living in a brothel, she could not be classified as trafficked, reinforcing the division between 'prostitutes' and victims. In several ways, then, CLAA created a distinction between virtuous white young virginal women who embodied social purity, and the "common and immoral prostitute."
Anti-white slavery associations held campaigns that resulted in the Agreement for the Suppression of the 'White Slave Traffic' of 1904 and the International Convention for the Suppression of the White Slave Traffic in 1910. These agreements included measures to tackle procurement and traffic, but their focus was strongly on border control. They allowed charitable organisations, such as the International Bureau, to be responsible for the enforcement of border control and to establish port patrols. The International Bureau had national committees responsible for port control operations across the world which patrolled railway stations and ports, where they greeted girls suspected of being white slaves - or indeed foreign prostitutes - and then reported back on their progress. The national committees [also] provided funds and campaigned for the repatriation of foreign prostitutes. These domestic laws, together with the international white slavery agreements, created complex powers of surveillance and repatriation over foreign women suspected of prostitution."
Adapted from: Laura Lammasniemi (2017). White slavery: the origins of the anti-trafficking movement. Beyond Trafficking and Slavery, 16 November 2017.
Latina Gang-Affiliated Mothers in the United States
Public interest on violence against women has increased worldwide. The United States is one of many countries that have spent vast financial resources addressing this critical social issue, which feminist criminologists have called a "war on girls." Yet studies on the violence experienced by Latinas (that is, women in the United States who can trace their origin to countries across Latin America), and most specifically, by gang-involved Latina mothers, are scant.
Gangs (possibly a type of an organized criminal group) and violence are the subject of contentious debates in the United States. Yet, these are based on largely speculative data, even though sociologists and criminologists have been researching these groups for almost a century. There is work on the labelling and marginalization of gang members, on how to reduce international gang violence, and how to craft comprehensive gang control. Together, this research has influenced the development of interventions, laws and policies seeking to end gangs and their activities - including violence. However, most US research on gangs has focused on men, even though national data shows women comprise about one third of known gang members. Furthermore, research on female gang members heavily focuses on physical and sexual violence perpetrated by their male partners or other gang members.
The research of Katherine Maldonado, a Latina doctoral Student from South-Central Los Angeles (a community historically identified as having one of the largest number of gangs in the United States) argues that the focus on interpersonal violence in the study of gangs limits our understanding of their activities. Furthermore, Maldonado shows violence is not bound by the period of gang-involvement. Instead, it follows gang-involved women throughout their lives: "structural and institutional violence creates a context of violence that cannot be reduced to violent individuals [but is instead] embedded in the broader social order, gender inequality, the perpetuation of violence, impunity, and women's diminished rights" (Menjivar and Walsh, 2017).
Violence against Latina women in South Central Los Angeles also involves direct and indirect interactions with the criminal justice and child welfare systems, which create forms of structural violence that shape women's lives and those of their families. Maldonado's work, relying on life history interviews conducted among gang-affiliated Latina mothers, explores the substantive significance of gang membership in the grand scheme of women's lives vis-à-vis the interplay of gang involvement, violence, motherhood and legal and social relations, along with women's responses to structural violence through strategic forms of resistance.
Adapted from: Menjívar, Cecilia, and Shannon Drysdale Walsh (2017). "The architecture of femicide: the state, inequalities, and everyday gender violence in Honduras." Latin American research review 52, no. 2; Maldonado, Katherine (forthcoming). Gang-affiliated Latina mothers resisting violence. Crime and Delinquency.
"Tricked and Trapped: Human Trafficking in the Middle East"
The report "Tricked and Trapped: Human Trafficking in the Middle East" by the International Labour Organization (ILO), was based on more than 650 interviews conducted over a two-year period in Jordan, Lebanon, Kuwait and the United Arab Emirates (UAE) about how the workers are 'tricked and trapped' into forced labour and sexual exploitation, and the constraints that prevent them from leaving those countries. The report points to deficits in labour law coverage that "reinforce underlying vulnerabilities of migrant workers" as well as significant gaps in national legislation that "restrict the ability of migrant workers to organize, to terminate their employment contracts and to change employers." The authors noted that the lack of inspection procedures maintains the "isolation of domestic workers in private homes" and heightens their vulnerability to exploitation, while in male-dominated sectors, such as construction, manufacturing, seafaring and agricultural sectors, workers are routinely deceived with respect to living and working conditions, the type of work to be performed, or even the existence of a job at all.
The Middle East hosts millions of migrant workers, who in some cases exceed the number of national workers substantially. In Qatar, for example, 94 per cent of workers are migrants, while in Saudi Arabia that figure is over 50 per cent, according to the ILO. Meanwhile, in Jordan and Lebanon migrants also make up a significant part of the workforce, particularly in the construction and domestic work sectors. Those industries are particularly susceptible to abuse due to the kafala or sponsorship system: most migrant workers need to be sponsored by their in-country employers for visa and legal status, a system the ILO calls "inherently problematic" because it connects a worker to a single employer who virtually controls his ability to become employed, creating an unequal power dynamic between the employer and the worker (all employees in construction in this specific case were men).
"Labour migration in this part of the world is unique in terms of its sheer scale and its exponential growth in recent years," Beate Andrees, Head of ILO's Special Action Programme to Combat Forced Labour, said at the start of a two-day conference on the topic in Amman, Jordan. "The challenge is how to put in place safeguards in both origin and destination countries to prevent the exploitation and abuse of these workers," Ms. Andrees told the more than 100 participants from a dozen Arab countries.
See: UN News. Migrant workers in the Middle East often exploited, UN reports at human trafficking conference. 9 April 2013. ; and Nasri, Alix and Helene Harroff-Tavel. Tricked and Trapped: Human Trafficking in the Middle East. International Labour Organization, 9 April 2013.
Nigerian Women and Juju
Sine Plambech, a Danish researcher who has worked extensively with Nigerian women working in the European sex trade, has written extensively about Juju. Plambech's work has shown that while indeed juju is 'a popular term for various forms of "traditional" medicine and black magic' (197) too much emphasis has been placed on its coercive and enslaving role (EASO 2015). This is problematic, because it often relies on sensationalistic stories and a victimizing approach, in which women (most specifically, Nigerian women) appear deprived from any agency or free will. Such an approach may overlook situations in which women choose to engage in sex work, or fails to identify the reasons why women may ultimately opt to leave Nigeria (family demands, intimate partner violence, their own desire to travel, study, work, etc.). In most of Europe, the narratives concerning "[terms like] 'voodoo,' 'slave trade' and 'organized crime' are appealing to the public, as these [often] recreate Western clichés concerning African women as primitive or prone to believe in witchcraft, rather than presenting a nuanced understanding of women's decisions to migrate and/or the levels of understanding they have about their journeys.
One of Plambech's interviewees, Becky, knew before she left Nigeria that she would have to work in the sex trade to pay back her journey to Europe. At a point she helped the woman who recruited her recruit other women. Every time, Becky told the women she recruited what their job would be once they reached Europe; there were no threats or coercion. A report on sex trafficking from EASO states: " Juju may not always be experienced by victims (…) as a tool of intimidation and control. Rather it is a 'secondary' form of coercion, experienced by those who have already entered situations of trafficking. It only becomes a threat once the woman is in a situation of exploitation" (2015: 200). Furthermore, Plambech reminds us that not all women use the term when describing their experiences in the sex trade, nor consider themselves under spells or curses. Often family expectations, financial demands to pay smuggling or travel fees for other friends and relatives, and the personal wish to improve one's live outcomes may drive migrants to pursue sex work to reach another country. In other words, claims that organized crime relies on juju to bring down or break the spirits of women fail to identify the wider dynamics of women's migration, and may ultimately reinforce stereotypes of Nigerian women, rather than providing detailed understandings of their experiences.
Adapted from: Finish Immigration Service (2015). EASO Country of Origin Information Report. Nigeria Sex Trafficking on Women. Brussels: EASO.
The Place that Female Coca Growers Deserve
Multiple researchers have argued that the nation's drug policy responses to the increase of coca cultivation in Colombia have involved problematic approaches and consequences. The work of the DeJusticia has identified how Colombians of peasant origin tend to be in prison disproportionally, amid the growth in forced crop eradication efforts.
Literature has highlighted the close relationship between drug policy and inequity, poverty and violence (see e.g. the Equality Trust, 2007; O'Gorman, 2016); but the gendered impacts of these issues have yet to be researched in depth. DeJusticia has worked for many years examining the ways drug policy has affected women. In particular, it has focused on documenting the experiences of the women who grow coca in the region of Putumayo.
Using intersectionality-informed perspectives, DeJusticia's work explores the implications of rural life, gender, armed conflict and illegality on the lives of coca-growing women in the Putumayo region. Here, the ways in which late colonization, non-state armed actors, violence, poverty and a precarious state presence converge have been studied for decades. However, the roles of women who grow coca plants, known locally as "Cocaleras", have not been part of research initiatives. Ignoring women's perspectives hides experiences that are key to understand how social inequality and poverty operate through policies like the "war on drugs" and impact women
Peasant women are involved in the coca economy working as crop workers, caring for and feeding the plants, harvesting, processing and trading coca leaf and its derivatives. Throughout their lives, women perform these roles at different times and circumstances, depending on the economic need. DeJusticia's researchers relied on a participatory research method known as social cartography. Through this, the cocaleras worked in groups drawing maps of their region. They mapped their daily routines, their community meeting spaces, their relationship with the coca plants, their family dynamics, their definition of State, and their relationship with armed actors, both legal and illegal. The maps along with the group conversations that arose from the drawings exposed the contexts of violence, poverty, inequality, and State abandonment that the women and their families face. Similarly, there was vast recognition of how coca harvesting has brought opportunities for social mobility for women and promoted collective solidarity for communities to build their own territories.
The cocaleras life's trajectories have developed in family units in which the burden of home care falls onto them. At the same time, they actively participate in the productive work of the farm. Educated to be caregivers, they quickly become also providers for their families. Likewise, cocaleras participate actively in social organizations in the region, either as leaders or as activists.
Adapted from: Cruz, Luis and Margarita Martinez Osorio. The Place that female coca growers deserve. DeJusticia, 2018.
On the relationship between drug policy and inequity, see also: The Equality Trust (2007). Drug Abuse; and O'Gorman, A. (2016). Outcomes: Drug Harms, Policy Harms, Poverty and Inequality. Clondalkin, Drug and Alcohol Task Force Final Report. The University of the West of Scotland, 2016.
One woman's career fighting wildlife crime
Read this article posted on the website of the African Wildlife Foundation. Explain the roles of women in the fight against wildlife trafficking. How are women's roles described? What are the characteristics and language that is used to define women's roles in this specific form of trafficking, and why are women relevant to the way the practice is described and/or depicted? What assumptions about women are reproduced? What would be a practical solution for the language and the practices concerning gender in fighting wildlife crime?
Source: Hannah Wilber (2017). One Woman's Career Fighting Wildlife Crime. African Wildlife Foundation. 21 March 2017.
Regional Perspective: Pacific Islands Region
Several cases analysed and discussed under the section "Regional Perspective: Pacific Islands Region" in various modules of the E4J University Module Series on Organized Crime have dealt with women offenders.
Police v Marsters and others 
In this case, a Senior Sergeant of the Cook Islands Police force, who was also the wife of a drug dealer, was sentenced to 2 years and 6 months in prison. The sentencing judge stated:
" It seems to me that in the circumstances you were always in a compromised position. Part of what I have read from your partner, Marsters is that the two of you are a very close unit, you do not have any secrets from each other. If that was the case, you would have known what he was doing and what he was dealing with. You knew cannabis was in the house, there were cannabis instruments although there have not been any charges survive in relation to those and you knew, I am sure, of the growing. So, that is a compromising position and again shows unfortunately your lack of judgment."
State v Anand Kumar Prasad and others  - Fiji
Ms. Shirley Chand, a high-ranked bank employee was convicted on several charges for her involvement in a fraud and money laundering scheme run by her brother. A second woman was convicted too, together with her husband, with her prison term of two years suspended on virtue of her minor role in the conspiracy.
Regarding Ms. Chand, the sentencing judge stated:
" Mr. I. Khan [attorney, note of editor] has filed extensive and helpful written submissions on behalf of the 5th accused. He tells me that she is 32 and married with two children. She has a Diploma in Banking and worked in the bank for nine years. She is caring for the child of a deceased sibling and she engages in charity work for the religious body she belongs to. In fact, the Bank Management have given evidence that before these irregularities came to light she was highly regarded and destined for promotion to the high Echelons of the banking world. She has no previous convictions. I bear all of this mitigatory material in mind. I accept that there is no evidence that this accused received any of the forged cheques into her account. Mr. Khan asks that a non-custodial sentence be imposed.
 The fifth accused cannot escape the fact that her actions in facilitating these fraudulent activities were an absolute breach of trust placed in her both by her employer and by Mr. Evanson who was one of her "prime" customers. For that reason alone, a non-custodial sentence cannot be contemplated despite the fact that she is a first offender. Playing a leading role in a $900,000 fraud, whilst breaching the trust placed in her by her banking employer must attract a prison term of some degree."
Regarding Ms. Singh, the sentencing judge stated:
" Mr. Shah [attorney, note of editor] submits on her behalf that she is 26 years old with two young children. Apart from managing the 4th accused's grocery/liquor and repair business, she is a housewife. She has a clear record and there is no evidence that she personally benefited during the period of the conspiracy. She is educated to Form 6 level and the offence is totally out of character. She is never likely to reoffend. Mr. Shah submits that she was an "innocent victim" and played no active role in perpetuating the conspiracy. He urges leniency for the sake of the children who are about to be deprived of both parents."
Source: State vs. Anand Kumar Prasad and others  HCF. Crim case 24/2010:
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