By Aradhana Parmeshwar and Nimisha Nagpal
Introduction
India houses approximately 5 lakh transgender people.[1] However, to most in our country they remain just a statistic, excluded from mainstream society. Their skewed portrayal by society and a refusal to accord them equal status with cis-gendered citizens as a result of their non-conformity to the traditional gender binary has caused them immense suffering.[2] With the onslaught of Covid-19, the transgender community’s suffering is increasing in every possible way—social, economic and emotional.
In 2014, the NALSA judgement recognised transgenders’ personhood, and gave them legal recognition and agency to act independently and make their own choices.[3] The Court directed, inter alia, for the central and state governments to frame social welfare schemes for their benefit and provide proper medical care to them in hospitals and other facilities.[4] However, the holding remains a mere symbol as its directives have not been followed by either the central or state governments,[5] as will be analysed in the subsequent sections. This failure to do so is particularly evident now, in the midst of a global pandemic, when the community needs it the most.
This article examines how the pandemic aggravates the struggles of the transgender community. The first section juxtaposes their conditions pre and post Covid-19, while the second section analyses their struggles with the healthcare system. The third section scrutinises relevant legal mechanisms, or the lack thereof, giving suggestions to remedy the same in the context of the pandemic, with a focus on healthcare.
Pushed To The Margins
This section deals with the various troubles experienced by the transgender community on a daily basis, exacerbated by the onset of the Covid-19 pandemic.
The Right to Residence
In India, only 2% of transgender persons in India live with their parents as the same is often extremely traumatic.[6] During their childhood, most transgenders hide their identity until it becomes impossible to do so,[7] mainly due to the acute rejection and abuse they face at home.[8] The impact of this trauma has been worsened by a lockdown affecting both geographical and occupational mobility, thus forcing trans people to live at home. Further, many transgenders undergoing transition have had their access to the required medication halted due to the pandemic.[9] However, their parents do not understand their problems and refuse to talk about such problems, which impairs their mental and physical well-being.[10]
Mental And Economic Struggles
Transgender individuals relying on hormone therapy are faced with the fear of gender dysphoria, which is the unease caused by the dissonance between an individual’s biological sex and gender identity.[11] They are also faced with other similar mental health issues such as depression and anxiety since their access to medication has been disrupted by the lockdown, further stifling limited resources.[12]
Prior to the pandemic, trans individuals sought relief in their community in order to cope with painful situations such as social/familial rejection and hormone therapy.[13] Studies indicate that community-based outreach and peer support positively affect the mental health of transgender individuals.[14] However, due to the social distancing measures imposed during the pandemic and the inability to interact with others, the psychological distress they face grows daily.
This is further burdened by their loss of income. 92% of trans people are deprived of their right to participate in economic activities,[15] with even those qualified are denied jobs due to social stigma. This results in numerous transgenders entering into beggary, sex work, or ‘badhai’[16] for sustenance.[17] The current pandemic has made their situation even worse.
However, the absence of crowds and celebrations has put a stop to their source of income due to the currently prevalent social distancing norms. As opposed to other communities, transgenders are facing extreme difficulties due to the stigma they experience, coupled with the paranoia around the virus. In April, transphobic posters were found at a Metro station in Hyderabad saying, “If you talk to transgenders, you will get corona.”[18]
The lack of income has made it hard for transgenders to pay rent, buy food supplies and fulfil their essential needs, including access to healthcare and the purchase of medicines.[19] This inability to pay rent forces them to stay in poor quality shelters where social distancing is an impossible task, potentially exposing them to the virus.[20]
A State Failure
The pandemic has exposed the limited infrastructure that exists for the transgender community. While the government is providing relief to other sections of society, this does not reach the transgender community because most schemes require identification proof via government documents like PAN card, Aadhar card, ration card, etc.[21] Since these documents are gender-specific, many trans individuals do not have access to them,[22] which deprives them of access to relief under government schemes. Thus, these schemes do not consider trans-specific needs.
In the absence of legitimate government action, community-based organisations (‘CBOs’) and non-government organisations (‘NGOs’) have attempted to uplift the transgender community. NGOs like Angel Ministries and the Sahodari Foundation have aided transgenders in issues of trafficking, rehabilitation, and education.[23] During the pandemic too, organisations are providing ration, medicines and petty cash to the transgender community,[24] with members of the community supporting each other as well.[25]
However, such organisations face various barriers when doing this. Since heteronormative culture is trans exclusive, there is rampant stereotyping of the trans community, thereby hindering the social awareness and trans-inclusive spaces they are trying to create. Further, government intervention is required in order to provide identity documents to transgenders and strengthen the capacities of such organisations.
Thus, the transgender community faces a multitude of problems on various fronts and most of them arise from the absence of accessible structures catered towards their needs. This is particularly evident during the current pandemic, necessitating the government and policy makers to adopt urgent measures to reduce their plight.
The Barriers To Healthcare
In 2002, the South African Constitutional Court, in Minister of Health v. Treatment Action Campaign[26] underscored the state’s constitutional obligation to provide access to healthcare, among other socio-economic rights, even in the midst of the HIV/AIDS pandemic.[27] Indian jurisprudence, in addition to recognising the right to health under the fundamental right to life[28], also imposes positive obligations on the state in that regard.[29] In this context, we examine the difficulties faced by the transgender community in realising their healthcare rights during the Covid-19 pandemic and propose measures to ameliorate the same.
Highlighting The Hindrances
Transgenders fight a losing battle with the healthcare system on a daily basis. On a structural level, there is a lack of adequate medical and sensitivity training received by professionals, who are thus, unable to provide services catering to the needs of the community.[30] Secondly, access to healthcare is hindered by economic exclusion[31] and discrimination by healthcare professionals[32] and within healthcare facilities, due to the societal perception of transgenders.[33] The lack of awareness around gender identity issues such as hormone replacement therapy (‘HRT’) and sex reassignment surgery (‘SRS’) translates into cursory or derogatory reception, such as refusing treatment and making insensitive personal remarks.[34] This often has serious medical repercussions,[35] leading to treatment by unlicensed individuals or reliance on drugs and alcohol as means to cope with the trauma.[36]
The exacerbation of these issues, in addition to those mentioned previously[37], has greatly impeded the healthcare rights of transgenders during the pandemic. Firstly, the onslaught of coronavirus cases has caused hospitals to defer or cancel elective procedures, further impeding access to HRT and SRS, the latter being associated with mental health issues.[38] This is because these procedures enable transgenders to exercise their right of self-identification and a dignified life.[39] Secondly, transgender individuals may be at a higher risk of contracting the virus, given their compromised immunity due to other medications, and a high rate of chronic illness among the transgender population.[40] However, rather than taking structured steps to address this, transgenders are further stigmatised and shunned—as opposed to their cis-gendered counterparts—due to their lack of conformity to traditional gender roles.[41] This stigma discourages them from seeking medical care, which adversely affects their medical interests and that of those around them.[42] This makes it all the more important and urgent to tackle these problems.
Addressing The Loopholes
In order to provide immediate relief to the transgender community, we put forth certain suggestions. Firstly, certain treatment centres may be designated solely for transgenders, with professionals trained and informed on the medical concerns of transgenders. This serves the two-fold purpose, firstly, of catering to their specific needs and secondly, of encouraging them to seek treatment by reducing the likelihood of discrimination and alienation. State governments should direct hospitals to implement urgent steps like allocating gender-neutral wards,[43] ensuring a consistent supply of medication such as HRT, and providing online medical counselling for transgenders.[44]
A concept that must be emphasised upon in this regard is the right to information.[45] Stimulating the dissemination of complete and transparent data—while maintaining subject confidentiality—will inform transgenders on the impacts of the virus on their systems, the requisite treatment, and the facilities and professionals providing the same.[46] Moreover, accurate and reliable information will help counter speculation and baseless claims that fuel stigma and paranoia in the community.[47] Access to information in a pandemic—the specificities of which are still uncertain—is crucial in advising vulnerable communities to take necessary steps. A functioning helpline may also be fruitful in this regard.
Lastly, states should establish and strengthen quarantine shelters specifically for transgenders, to facilitate social distancing and necessary precautions.[48] Basic technology may be provided so as to access telehealth and relevant information on the virus. This will also provide access to online peer groups and therapy, which will aid mental health.[49]
Thus, it is crucial that states implement short-term measures, while initiating long-term solutions at the earliest, and thereby prioritising the needs of the transgender community.
Insufficiency of Legal Mechanisms
This section examines the role of the legal system in addressing the issues presently faced by the community, in context of the recent legislations passed in favour of transgender rights.
Transgender Legislation: A Tokenistic Effort
The Transgender Persons (Protection of Rights) Act, 2019 [50] was passed on July 2019 and the Draft Transgender Persons (Protection of Rights) Rules[51] (‘the Rules’) were released by the government in April 2020. The release of the Rules as well as the deadline to send comments regarding the same (18 May, 2020), fell during the peak of the pandemic and the lockdown period.[52] This effectively barred a large proportion of the transgender population from voicing their concerns due to language barriers, internet accessibility and employment difficulties.[53]
Both, the Act and the Rules suffer from various infirmities, particularly in aiding transgenders during the pandemic. Firstly, several members of the community do not possess basic documentation or identification, excluding them from the ambit of government’s social security schemes.[54] This is a chief concern during the pandemic, which the Rules do not consider. Secondly, in order to apply for a transgender certificate, one must procure a psychologist’s certificate, followed by an application to the District Magistrate, which may be accepted or rejected within 60 days.[55] Not only is this procedure in contravention to the principle of self-identification,[56] it may also hinder speedy relief under transgender-specific schemes. Thirdly, the Act simply empowers state governments to enact welfare schemes in various spheres, including healthcare, without providing specific guidelines or timelines for the same.[57] This leaves undue discretion to state governments, leading to a lack of uniformity and accountability.
The Rules should also define the term “medical institution” as under §7(1) of the Act[58] in order to ensure a reasonable standard for qualifications of medical professionals.[59] The Rules as well as the Act should also mandate consultation with members of the transgender community in formulating legislation for their benefit, to achieve accurate representation of their interests.[60] For the duration of the pandemic at least, it would be prudent for state governments to pass orders specifically dealing with access and discrimination in the healthcare sphere for transgenders. The penalty for discrimination, for instance, should be increased beyond “imprisonment which may vary between six months to two years, with a fine”, which is provided in the Act.[61] Such rules may also include prescribing standards for quarantine centres, and providing funds to strengthen CBOs working with transgenders.[62]
The Role Of The Judiciary
During the pandemic, neither the central nor state governments have passed transgender-specific orders or schemes.[63] Orders encompassing all marginalised communities under a common umbrella do not address the difficulties exclusive to the trans community. This has led to multiple public interest litigations (‘PILs’) being filed by transgender activists and organisations in High Courts across the country. In June, transactivist Vikram Shinde moved the Bombay High Court with a PIL regarding the distressing situation faced by the Indian transgender community.[64] He asserted that given their substantial loss of income and their increased vulnerability to the virus, they must be provided with relief under various government welfare schemes. The High Court directed the petitioner to file a representation, on the basis of which the social justice department was to take a decision, within 2 weeks.[65] However, there has been no communication by the latter on the same. The judiciary must take a more proactive stance by stressing upon the urgency of the situation and formulating basic guidelines for the legislature to act upon, without encroaching on the latter’s legislative power. The Telangana High Court, for instance, has directed the State Government to ensure the provision of medical aid and earmarking of special wards for transgenders, while requesting a detailed report from the petitioner’s (a transgender activist) lawyer regarding the conditions of the community, based on which further directions may be framed.[66] It also directed the State Government to provide free medicines, food grains, and essentials to transgenders despite their lack of ration cards.[67] The Karnataka High Court has also directed the State Government to undertake several relief measures, through interim orders.[68] It specifically recognised the needs of the transgender community, by extending the benefits available to them under the Mythri pension scheme during the pandemic.[69] The scheme—designed to provide pension to transgenders falling within a certain income bracket—has been extended to pay two months’ worth of pension immediately.[70]
Thus, the legislature and judiciary need to take active, speedy, and targeted steps in addressing these gaps, for which adequate representation of the transgender community is required.
Conclusion
As indicated since the NALSA judgment, identification of rights and needs does not necessarily lead to implementation of the same. While there are several measures, both long and short term, that may be implemented for the benefit of the transgender community, Covid-19 necessitates prioritisation of the immediate and most pressing issues. In order to delineate the same, giving the community a voice in the decision making process is essential, as has been attempted by the Telangana and Bombay High Courts. This can be achieved by extending the deadline for comments on the Draft Rules and consulting known transactivists and organisations in framing transgender legislation. As the unusual circumstances imposed by the pandemic are likely to extend indefinitely, it would be prudent to begin addressing structural problems and framing long term solutions at the earliest. This situation is thus, a true test of the efficiency and reliability of our country’s legal framework. Lastly, we acknowledge that being external to the transgender community, we cannot adequately understand their hardships and can only lend our voice in support of their cause, as this article attempts to do.
The authors, Aradhana Parmeshwar and Nimisha Nagpal, are currently law students at the National University of Juridical Sciences (NUJS), Kolkata.
[1] Government of India, ‘Overview of Census 2011’ 22 <https://censusindia.gov.in/2011-prov-results/data_files/mp/02Introduction.pdf> accessed September 9, 2020.
[2] Deepika Ganju* and Niranjan Saggurti, ‘Stigma, violence and HIV vulnerability among transgender persons in sex work in Maharashtra, India’ (2017) 19(8) Culture, Health and Sex 903.
[3] NALSA vs. Union of India (2014) 5 SCC 438; BBC News, ‘ India court recognises transgender people as third gender’(April 15, 2014) < https://www.bbc.com/news/world-asia-india-27031180> accessed July 29, 2020.
[4] NALSA v Union of India (2014) 5 SCC 438 ¶129.
[5] Ramya Kudekallu, ‘Why transgender community is struggling in spite of NALSA judgment,’(DailyO, February 3, 2017) <https://www.dailyo.in/politics/transgender-nalsa-judgment-aadhar-card-gender-rights-self-identification/story/1/15462.html> accessed July 29, 2020; Rintu Mariam Biju, ‘Transgender (Protection of Rights) Act, 2019: In violation of the NALSA judgment?’ (Bar and Bench December 14, 2019) <https://www.barandbench.com/columns/transgender-persons-protection-rights-act-2019-violation-nalsa-judgment> accessed July 29, 2020
[6] National Human Rights Commission, ‘Study on Human Rights of transgender as a third gender’, 34 (Kerala Development Society 2018) <https://nhrc.nic.in/sites/default/files/Study_HR_transgender_03082018.pdf> accessed August 29, 2020.
[7] Ibid.
[8] Kennith Rosario, ‘COVID-19 lockdown: transgender community pushed further to the margin’ (The Hindu, April 6, 2020 <https://www.thehindu.com/news/cities/mumbai/covid-19-lockdown-transgender-community-pushed-further-to-the-margin/article31265535.ece> accessed July 29, 2020.
[9] Megha Mohan, ‘Coronavirus: Transgender people ‘extremely vulnerable’ during lockdown’ (BBC News, April 29, 2020) <https://www.bbc.com/news/world-52457681> accessed July 22, 2020.
[10] Neeraj Chauahan, ‘Left alone: Just 2% of trans people stay with parents’ (The Times of India, August 13, 2018 ) <https://timesofindia.indiatimes.com/india/left-alone-just-2-of-trans-people-stay-with-parents/articleshow/65380226.cms> accessed July 29, 2020.
[11] National Health Service, ‘Gender Dysphoria’<https://www.nhs.uk/conditions/gender-dysphoria/> accessed August 29, 2020.
[12] Mohan (n 9).
[13] Rosario (n 8).
[14] Simran Shaikh et al., ‘Empowering communities and strengthening systems to improve transgender health: outcomes from the Pehchan programme in India’ (2016) 19(3) Journal of Int. AIDS Society 2.
[15] National Human Rights Commission (n 6).
[16] Badhai, which means ‘congratulations’ is the Indian tradition of inviting transgender individuals to weddings to sing, dance and bless the couple. This is acts as a source of income for the transgender community. See Prachi Pinglay-Plumber, ‘Chucking Badhai For Growth’ (Outlook, August 22, 2016) <https://magazine.outlookindia.com/story/chucking-badhai-for-growth/297698> accessed August 29, 2020.
[17] Rosario (n 8).
[18] Donita Jose, ‘Transgenders shocked by hate posters in Hyderabad amid coronavirus fear’ The New Indian Express (March 30, 2020) <https://www.newindianexpress.com/cities/hyderabad/2020/mar/30/transgenders-shocked-by-hate-posters-in-hyderabad-amid-coronavirus-fear-2123284.html> accessed July 22, 2020.
[19] Rosario (n 8).
[20] Thomas Reuters Foundation News ,‘India’s “invisible” trans community struggles as coronavirus shuts life down’ (March 25, 2020) <https://www.reuters.com/article/us-health-coronavirus-lgbt-india/indias-invisible-trans-community-struggles-as-coronavirus-shuts-life-down-idUSKBN21C098> accessed July 29, 2020.
[21] Transgender Persons (Protection of Rights) Act, 2019, §12(1).
[22] Chauhan (n 10).
[23] Saniya Raza, ‘Preaching gender equality, this NGO saves transgenders from human trafficking’ (YourStory, July 11, 2017) <https://yourstory.com/2017/07/transgenders-human-trafficking-angel-ministries-bengaluru> accessed July 29, 2020.
[24] Amnesty International India, ‘Support India’s Most Vulnerable Fight COVID-19: A List Of Fundraisers You Can Donate To’ ( April 3, 2020) <https://amnesty.org.in/support-indias-most-vulnerable-fight-covid-19-a-list-of-fundraisers-you-can-donate-to/> accessed July 29, 2020.
[25] Suryasarathi Bhattacharya, ‘Coronavirus Outbreak: Trans community’s lives come to standstill, but hope presents itself through welfare initiatives’ (Firstpost, April 19, 2020) <https://www.firstpost.com/india/coronavirus-outbreak-trans-communitys-lives-come-to-standstill-but-hope-presents-itself-through-welfare-initiatives-8234171.html> accessed July 29, 2020.
[26] Minister of Health v. Treatment Action Campaign (2002) 5 SA 721
[27] Ibid, ¶94.
[28] Paschim Bengal Khet Mazdoor Samity v State of West Bengal & Anr (1996) 4 SCC 37.
[29] Soobramoney v Minister of Health (Kwazulu-Natal), 1998 (1) SA 765 (CC), ¶15.
[30] Muller A, Teaching lesbian, gay, bisexual and transgender health in a South African health sciences faculty: addressing the gap [2013] BMC Medical Education, 4, 5.
[31] Simran Shaikh et al., ‘Empowering communities and strengthening systems to improve transgender health: outcomes from the Pehchan programme in India’ (2016) 19(3) Journal of Int. AIDS Society 2.
[32] Kosenko K, Rintamaki L, Raney S, Maness K, Transgender Patient Perceptions of Stigma in Health Care Contexts (2013) 51(9) Medical Care.
[33] Chakrapani V, Newman PA, Shunmugam M, Dubrow R, Barriers to free antiretroviral treatment access among kothi‐identified men who have sex with men and aravanis (transgender women) in Chennai, India (2011) 23(12) AIDS Care.
[34] Elizabeth Soumya, ‘Indian transgender healthcare challenges’ (Aljazeera, 18 June, 2014) <https://www.aljazeera.com/indepth/features/2014/06/healthcare-distant-india-transgenders-201461882414495902.html> accessed July 29, 2020; Ankur Paliwal, ‘How could you have been raped?’: New study on how India’s transgender people face bias from doctors’ (Scroll.in November 2, 2017) <https://scroll.in/pulse/856285/transphobia-among-indian-doctors-study-aims-to-uncover-reasons-for-bias-against-transgender-people> accessed July 29, 2020.
[35] Ibid.
[36] Paliwal (n 34); Center for American Progress , ‘An Effective Response to the Coronavirus Requires Targeted Assistance for LGBTQ People’ (April 9, 2020) <https://www.americanprogress.org/issues/lgbtq-rights/news/2020/04/09/482895/effective-response-coronavirus-requires-targeted-assistance-lgbtq-people/> accessed July 26, 2020.
[37] Rosario (n 8); Thomas Reuters Foundation News (n 20).
[38] The Lancet, ‘Correspondence’ (July 8., 2020) <https://www.thelancet.com/pdfs/journals/landia/PIIS2213-8587(20)30182-0.pdf> accessed July 31, 2020.
[39] NALSA vs. Union of India (2014) 5 SCC 438, para 82-106.
[40] Centre for Disease Control and Prevention, ‘People at Increased Risk of Severe Illness’ ( 25 June, 2020) <https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-at-increased-risk.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.gov%2Fcoronavirus%2F2019-ncov%2Fneed-extra-precautions%2Fpeople-at-higher-risk.html> accessed July 29, 2020.
[41] Aljazeera, Elizabeth Soumya, ‘Indian transgender healthcare challenges’ (18 June, 2014) <https://www.aljazeera.com/indepth/features/2014/06/healthcare-distant-india-transgenders-201461882414495902.html> accessed July 29, 2020.
[42] Amnesty International India , ‘As the World Comes Together, India’s Transgender Community Fights Covid-19 Alone’ ( 1 April, 2020) <https://amnesty.org.in/as-the-world-comes-together-indias-transgender-community-fights-covid-19-alone/> accessed July 29, 2020.
[43] Bangalore Mirror, ‘Ward for transgenders at all govt hospitals’(8 Nov 2013) <https://bangaloremirror.indiatimes.com/bangalore/others/ids-passports-driving-licences-ration-cards-castration-certificate-karnataka-sexual-minorities-federation-tuberculosis-hiv/articleshow/25392919.cms> accessed July 29, 2020.
[44] Miesen A, Raaijmakers D, Grift T, ‘You Have to Wait a Little Longer’: Transgender (Mental) Health at Risk as a Consequence of Deferring Gender‐Affirming Treatments During COVID‐19 [2020] 49 Archives of Sexual Behaviour.
[45] Avafia T, Konstantinov B, Esom K, Sanjuan J & Schleifer R, A Rights-Based Response to COVID-19: Lessons Learned from HIV and TB Epidemics [2020] Health and Human Rights Journal.
[46]Apurvakumar Pandya & Alex Redcay, Impact of COVID-19 on Transgender Women & Hijra: Insights from Gujarat, India (2020), PREPRINT (Version 1), 3 <https://www.researchsquare.com/article/rs-44619/v1> accessed July 29, 2020.
[47] Avafi et al(n 45).
[48] Simran Shaikh et al., ‘Empowering communities and strengthening systems to improve transgender health: outcomes from the Pehchan programme in India’ (2016) 19(3) Journal of Int. AIDS Society 2.
[49] Thankachan A, Rathore A, Kumar S, Shweta, Krishnapriya V, Haokip N, Bhatnagar S & Bhopale S, ‘Challenging concerns of transgender community amidst COVID-19’ (2020) 26(5) Indian Journal of Palliative Care.
[50] The Transgender Persons (Protection of Rights) Act, 2019.
[51] Draft Transgender Persons (Protection of Rights) Rules, 2020.
[52] The Print ,‘Modi govt releasing draft rules on Transgender Persons Act in lockdown a blow to community’ (May 5, 2020) <https://theprint.in/opinion/modi-govt-releasing-draft-rules-transgender-persons-act-lockdown-a-blow/414331/> accessed 22 July, 2020.
[53] Ibid.
[54] Frontline, Covid-19 and the plight of the transgender community’ (April 29, 2020) <https://frontline.thehindu.com/dispatches/article31463945.ece> accessed 22 July, 2020.
[55] Draft Transgender Persons (Protection of Rights) Rules, 2020, Cl 5(2).
[56] National Legal Services Authority v Union of India (2014) 5 SCC 438.
[57] The Transgender Persons (Protection of Rights) Act, 2019,§8.
[58] The Transgender Persons (Protection of Rights) Act, 2019, §7(1).
[59] The term “medical institutions” to be read as “clinical establishments” with the same meaning as under the Clinical Establishments (Registration and Regulation) Act, 2010; Comments and Suggestions on the Draft Transgender Persons (Protection of Rights) Rules, 2020, NUJS Law Review, 5.
[60] ‘Comments on the Draft Transgender Persons (Protection of Rights) Rules, 2020’ (Vidhi Centre for Legal Policy, 14 May 2020) <https://vidhilegalpolicy.in/research/comments-on-the-transgender-persons-protection-of-rights-rules-2020/> accessed 29 July, 2020 Lack of pin citation.
[61] The Transgender Persons (Protection of Rights) Act, 2019, §18(d).
[62] Sheikh (n 14).
[63] Jurist, ‘Covid-19 and the Transgender Community in India’ (5 June, 2020) <https://www.jurist.org/commentary/2020/06/sonal-rawat-trans-rights-covid19/> accessed 22 July, 2020
[64] Chauhan (n 10).
[65] Ibid.
[66] Vyjayani Vasanti Mogli v State of Telangana, WP(PIL) No 74 of 2020.
[67] Ibid.
[68] Centre for Law & Policy Research, CLPR files Applications before Karnataka High Court for protecting transgender persons during the Covid-19 lockdown’ (April 7, 2020) <https://clpr.org.in/litigation/mohammed-areef-jameel-anr-v-union-of-india-ors/> accessed 22 July, 2020.
[69] Ibid.
[70] The Indian Express, ‘Karnataka transgender community suffers govt apathy, high court intervenes’ (15 April, 2020) <https://indianexpress.com/article/cities/bangalore/karnataka-transgender-community-coronavirus-lockdown-6363247/ >accessed 29 July, 2020.
The Journal of Indian Law and Society 