The Legal And Ethical Implications Of Gender discrimination And Sexual Harassment In Sports, With Focus On India’s Sports Industry

INTRODUCTION

Sports have been widely acknowledged for their positive impact on the health and well-being of participants.[1] The potential harm caused to athletes’ health and well-being when their integrity is compromised through non-accidental violence or maltreatment, such as harassment and abuse[2] is often overlooked. It is crucial to understand that all forms of harassment and abuse violate human rights and may even be considered criminal offenses.

Many sports organizations fail to adequately address the harms caused by harassment and abuse, often due to concerns about damage to their reputation or a lack of awareness, silence, and collusion.[3] It is important to note that research on abuse and harassment outside of the sports context indicates that sport organizations cannot assume they are exempt from these issues, as the problems prevalent in society can also exist within sports.It is challenging to determine whether sports are more or less susceptible to such problems, and whether they offer any unique safeguards. However, it is evident that the risk of psychological, physical, and sexual violence increases as athletes progress in their talent development and performance pathway.

The cultural background of harassment and abuse originates from the presence of power imbalances tied to various social and personal factors, leading to discrimination.

It is the responsibility of the sports organisations to ensure that no sports persons who are involved in their sport are subject to any abuse, sexual misconduct, harassment or unlawful discrimination.

TYPES/FORMS OF ABUSE IN SPORTS

PSYCHOLOGICAL HARASSMENT AND ABUSE

Psychological abuse which is also known as emotional abuse is a type of mistreatment that targets person’s mental and emotional well-being. There are strong evidence that psychological, sexual and physical abuse are highly interrelated.[4]

Some examples of this abuse in sports are:

1. Continuous criticism – A sportsperson may be subjected to constant or continuous criticism and negative feedback which abrades their self- confidence as well as their self-esteem. This type of criticism can be engaged by coaches, teammates or even spectators which humiliate or ridicule the athlete.
2. Threats and intimidations – Some threats like threats of physical harm, loss of playing time or some other consequences related to them if they do not comply with the demands of coaches or any other authority, which instils fear and anxiety in the minds of athletes.
3. Psychological or emotional blackmail – This type of abuse involves using manipulation and psychological or emotional leverage which force sportspersons into certain actions or behaviours by using guilt, fear or shame to control those athletes.
4. Conning or gaslighting – When the abilities, efforts or achievements of athletes are minimised or denied by manipulating the individual’s perception of reality to make them question their own experience creates self-doubts and confusion in the mind of athletes which is known as conning of gaslighting.

SEXUAL HARASSMENT AND ABUSE

Sexual harassment and abuse have been the most recent form of interpersonal abuse that can occur in various contexts including sports. This type of abuse is by power which is fostered by an organisational culture which either disregards, denies or silently condone the issue. Across all sports and at various levels these forms of misconduct occur with higher prevalence rates observed in elite sports.According to different studies and measurement methods it ranges from 19% to 92% for sexual harassment and 2% to 49% for sexual abuse.[5]

Sexual abuse often involves the process called ‘Grooming’.

How is grooming done?

Before starting to abuse the abuser builds trust and confidence with the athlete.“The grooming process in sports involves firstly targeting a potential victim where they observe which athlete is vulnerable and finding occasions to test her out for secrecy and reliability then they Build trust and friendship like making her feel special or giving gifts and rewards then developing isolation and control, building loyalty and then lastly initiation of sexual abuse and securing secrecy.”[6]

Here are some examples of sexual harassment and abuse:

1. Unwanted sexual advances – This includes inappropriate and unwanted sexual proposition, gestures or comments directed towards athletes through which hostile environment is created where these athletes feel uncomfortable or intimidated.
2. Sexual assault – It refers to any non- consensual sexual conduct or activity. In sports it involves unwanted touching, groping, or forced sexual acts.
3. Abuse of power dynamics – Some coaches, trainers or any other person in authority abuse their powers to coerce sports persons to engage in unwanted sexual activities. This is the severe form of sexual abuse due to exploitation of powers.
4. Gender based harassment – Athletes also face harassment and discrimination based on their genders which includes derogatory remarks, slurs, that target individual’s gender and sexual identity.

PHYSICAL ABUSE AND FORCED PHYSICAL EXERTION

It involves intentional acts of physical harm directed towards sports persons. It includes any form of physical assault like hitting, punching, kicking etc by coaches, trainers or any other person in position of authority. It may be inflicted both on and off the field. Numerous forms of violence in sports are implicitly accepted or normalised as a result of the ‘win/lose’ structure of sports and a culture that idolises athletes. This is especially true of contact sports because of how physically demanding they are and how the athlete’s body is treated as essential “equipment.”[7]

Now we will see these forms of abuses with the help of some examples:

• Samaira is a 16 year old girl. She’s a gifted 1000-meter runner who wants to join the Olympic team this year. She moves to the city that is close to the training facility with coach Shyam after being chosen for the qualifying squad.[8]

She received appreciation from Shyam for her performances, and he promised to fulfill her aspirations if she followed his instructions. Samira can tell that the coach likes her because he regularly compliments and encourages her.[9] She is first pleased with how her coaching relationship is developing, but as time went on, Shyam began paying closer attention to her, something that her teammates also observed.

Samira is struggling academically, so one day Shyam offers to assist or teach her in her school work in his office after practice.[10]After the tutoring session, Shyam provides conveyance and buys her food on the way home. After a few days, Shyam switches the location of the tutoring sessions from his workplace to his house.

Coach invites Samira to his hotel room for “special pre-competition talks” the evening before her 1000m qualification race. He puts his arm around her as they are seated together. He puts his arm on her thigh and she starts to feel awkward. He promised her that if she does him any favours, he will make sure she succeeds tomorrow. [11]

As she leaves the place, Samira “walks by her teammates and the team manager.  They turn around and leave while clearly upset and in tears.

• Alexa, a young female athlete who dreams of pursuing a professional career in her sport. She joins a renowned team and begins training under a trainer Mark, who wields significant power and influence within the organization. Unfortunately, the trainer abuses his position of authority, subjecting the athlete to both sexual and psychological abuse.

He begins by making unwelcome sexual advances towards the athlete, making inappropriate comments about her appearance and making explicit remarks about her body during training sessions. Gradually, Mark escalates the abuse by engaging in non-consensual physical contact, touching her inappropriately under the guise of providing coaching instructions. This sexual abuse leaves Alexa feeling violated, confused, and fearful of reprisals if she were to speak up.

Alongside the sexual abuse, the trainer also engages in psychological abuse to maintain control over Alexa.He frequently belittle and demean her in front of the team, criticizing her skills, appearance, and performance. Mark uses derogatory language, insults her abilities, and creates a hostile environment. She is constantly subjected to harsh criticism, which erodes her self-confidence, self-esteem, and passion for the sport. The trainer also isolates her from the team, creating a sense of loneliness and alienation.

[Image Sources: Shutterstock]

IMPACT ON ATHLETES AND ON SPORTS

The impact of such experiences on athletes can be long term as well as very damaging and it also extends to affect families, friends or colleagues.[12]It also has negative impact on the athlete physical, psychological and social health as well which also impacts their sport. It can also discourage talented athletes to participate in sports.[13]When potential sportspersons witness a culture that condones or ignores harassment, they may opt out of pursuing a sporting career, leading to a loss of talent and diversity in the sports industry.[14]Abuse also creates a hostile environment that can impact the performance and focus of the athletes. Sexual abuse can also disrupt team dynamics and unity and creates tension and toxic environment within the team, affecting communication.

LEGAL IMPLICATIONS

“The right to be protected from sexual harassment and sexual assault is, therefore, guaranteed by the Constitution, and is one of the pillars on which the very construct of gender justice stands”

Justice Verma Committee

Gender based discrimination in sports can take the form of sheer male superiority within patriarchal family or societal structures where sports is considered as exclusively male domain. It can also arise from myths surrounding the adverse effects of sports on women’s reproductive health and/or beauty to undermining their sporting career ambitions, leading to limited support and opportunities for their careers.[15] Also, women’s sports did not get adequate media coverage and lack sufficient spectator ship, contributing to further inequality.[16] Furthermore, female athletes are vulnerable to sexual harassment within the sporting realm.

Inequality in facility access is a problem for female athletes as well. Former Indian cricketer Snehal Pradhan narrates:

“For two years, I practised at a ground in Bandra where I was the only girl. After training the boys would change from their muddied whites into T-shirts and shorts for their journey home. They would do so in the open. There was no changing room there, so I just pulled a jumper over my sweat-soaked T-shirt, so that I wouldn’t get sweat and grime on my co-travellers in the bus or train. The jumper made me sweat even more. Later, the ground staff gave me access to a locked bathroom to change. It was small, unlit dingy and sometimes stank. But it had a lock, and allowed me to change out of my whites into a clean T-shirt. It was better than the jumper.”[17]

The Constitution of India guarantees the Right to Equality under Article 14 to 18 and Article 15 expressly prohibits gender discrimination in any situation including access to “places of public entertainment” which can be interpreted to imply gender equality in sporting facilities as well. Under Articles 226 and 32 citizens are free to approach High Court or even Supreme Court. [18]

The cognizance of gender equality and sexual harassment in sports has taken by The Ministry of Youth Affairs and Sports.

Rule 9.3 condition xi of National Sports Development Code, 2011(which is not a statute but a delegated legislation of The Ministry of Youth Affairs and Sports, but its binding nature is judiciary upheld)[19] mandates that national sporting organisations including BCCI to regularly hold tournaments for both men and women for continuance of status as recognised organisations and to receive financial assistance from the government.

Rule 10.8 states that if funding is provided to national sports federations by the government then an equal amount of money should be allotted for the tournaments for both the genders.

Rule 1.6 mentions that the government has issued the guidelines to address sexual harassment of women in sports.

The landmark case of Vishakha v. State of Rajasthan[20] which deals with sexual harassment at workplace is also indeed pertinent in this context. Now, the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 has come into being which codifies the guidelines given by the Supreme Court in the said case.

The primary objective of this act in the protection of women, prevention and redressal of the complaints of sexual harassment and to protect women at different types of workplaces. Under Articles 14 and 15(3) sexual harassment has been termed as violation of basic fundamental rights of women.

Clause iv and v of this act states that sporting spaces are also workplace as the term “Workplace” is defined broadly and includes “any sports institute, stadium, sports complex or competition or games venue, whether residential or not used for training, sports or other activities relating thereto”, and “any place visited by the employee arising out of or during the course of employment including transportation provided by the employer for undertaking such a journey”.[21]

The draft of the National Sports Development Bill of 10 July 2013, deserves our attention. In its preamble the elimination of “sexual harassment of women in sports” is mentioned.

Section 15 of this draft exclusively deals with sexual harassment which is quoted verbatim hereunder:

“(1) It shall be the duty of every National Sports Federation, the National Olympic Committee, the Sports Authority of India and other sports bodies to prevent sexual harassment in sports.

(2) For the purpose of sub-section (1), all National Sports Federations, the National Olympic Committee, the Sports Authority of India and other sports bodies shall adopt measures, namely:

1. a) notify, publish and circulate, guidelines for the safety and well-being of all involved in Sports;
2. b) establish appropriate systems to ensure healthy relationship between coach and athletes;
3. c) provide for sufficient number of women members in the coaching and support staff for every woman athlete or team of women athletes;
4. d) provide appropriate conditions for women in respect of work, leisure, health and hygiene;
5. e) provide reasonable assistance to the adversely affected athlete, where sexual harassment occurs as a result of an act or omission by any third party and initiate appropriate legal action against such third party;
6. f) to set up a complaints committee for redressal of the complaints in a time bound manner so as to comply with the guidelines laid down by the Supreme Court or the mandate of any other enactment: Provided that, to prevent the possibility of any undue pressure or influence from within the organisation, the complaints committee shall have an independent member either from a nongovernmental organisation or other body/person, as the case may be, who is familiar with the issues of sexual harassment.

(3) Without prejudice to the foregoing provisions, the Central Government may specify certain other acts which may constitute sexual harassment in sports.

(4) The Central Government may make rules prohibiting sexual harassment in sports and provide for appropriate penalties.”[22]

The National Sports Development Bill 2013 has asked for better measures of security towards the woman athletes of the country.

This can be done by

“(i) prescribe necessary rules

(ii) provide sufficient members of women coaching staff

(iii) appropriate sporting conditions for women and girls

(iv) setup complaint mechanism

(v) be woman centric and also someone from NGO so that there is no pressure from Association.

(vi) Provide appropriate penalties.”[23]

According to Section 26, there shall be equal representation of male and female athletes on the National Olympic Committee, and at least 10% of the members of the National Olympic Committee and National Sports Federations shall be women. [24]

Since gender-related issues that might otherwise not be classified as “sexual harassment” have been covered by Section 15(2)(d), Section 25 creates an Appellate Sports Tribunal that has the authority to settle disputes between athletes and sports federations or the National Olympic Committee. These disputes can also involve issues pertaining to gender.[25]

But here the only problem is this draft is still under consideration. Much could be done for the benefit of women in sports if it could be given legal recognition. Therefore, our law makers should adopt this bill and implement it for the future prospects of women athletes.

POSITION IN INTERNATIONAL LAW

The importance of gender equality in all spheres of life, including sports, has been recognized by international law.

Some general provisions of the International Covenant on Economic, Social, and Cultural Rights (ICESCR),the International Covenant on Civil and Political Rights (ICCPR), the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), and the Universal Declaration of Human Rights (UDHR) can be applied in the context of sports, while there are other provisions in international law which deal specifically with the problem of gender inequality in sports.[26]

The CEDAW is without a doubt the most significant convention in the realm of women’s rights. The States are required to provide “the same opportunities to participate actively in sports and physical education” to “men and women” according to Article 10(g) of this treaty, which deals with the topic at hand.

Article 1 of CEDAW defines “discrimination against women” as “any distinction, exclusion or restriction made on the basis of sex which has the effect or purpose of impairing or nullifying the recognition, enjoyment or exercise by women, irrespective of their marital status, on a basis of equality of men and women, of human rights and fundamental freedoms in the political, economic, social, cultural, civil or any other field”[27], which would definitely include the realm of sports.

Since India is a signatory to the ICCPR, ICESCR, and CEDAW but not to the Optional Protocol to the CEDAW, complaints cannot be submitted to the CEDAW Committee for examination after all domestic legal remedies, including appeals to the Supreme Court, have been exhausted. However, Articles 51 and 253 of the Indian Constitution, in particular, substantially mandate obedience to international law.

ETHICAL IMPLICATIONS

There are significant ethical issues related to gender discrimination and sexual harassment in the Indian sports industry that need to be addressed. Here we will look for some ethical implications related to sexual harassment and gender discrimination against women in sports:

• Human Dignity and Respect: Every individual regardless of gender should be treated with respect and dignity. This principle is violated by sexual harassment as it subjects individual to unwelcome, unpleasant and offensive behaviour. In order to uphold human dignity there is a necessity to create an environment by sports authorities where all athletes may flourish without fear of harassment and discrimination.
• Fairness and Equal Opportunity: Sexual harassment and gender-based discrimination jeopardise the principles of fairness and equal opportunity in sports. Because of harassment, female athletes may have obstacles, unfair treatment, and limited chances, which makes it difficult for them to compete on an even playing field. To ensure that all athletes have an equal opportunity to succeed, it is crucial to promote a fair and inclusive sports culture.
• Safety and well-being: Victims of sexual harassment in sports may suffer serious emotional, psychological, and physical consequences. A safe and encouraging atmosphere should be provided to the sports persons, with a focus on their well-being. This includes protection against any kind of abuse, exploitation, or harassment so that players can concentrate entirely on their sports goals and personal growth.
• Trust and Integrity: Sexual harassment degrades the integrity of the sporting community and erodes trust within sports organisations. Athletes, coaches, and other participants should have faith that they are a part of a culture that values decency, justice, and moral behaviour. Rebuilding and maintaining confidence within the sports sector depends on addressing and preventing sexual harassment.
• Organizational Responsibility: It is the moral responsibility of sports organizations to safeguard athletes and prevent sexual harassment. The responsibility includes putting in place defined rules, moral standards, and reporting procedures. Organizations should promote a culture that values open communication, resolves issues of power disparities, and holds people accountable for their deeds.
• Gender Equality and Social Justice: A key ethical principle is the promotion of gender equality and social justice. Sexual harassment and gender discrimination aggravate societal injustices and hinder efforts to create a more just society. The sports industry could endorse the broader goal of promoting gender equality and social justice by actively combatting harassment.

In order to prevent sexual harassment in India’s sports industry, everyone must work together to uphold ethical principles and foster a welcoming environment. This involves putting laws into place and upholding them, providing education and awareness campaigns, helping victims, and holding perpetrators accountable. The sports industry may promote a culture of respect, equality, and dignity for all participants by placing a high priority on ethics and values.

CHALLENGES IN INDIA’S SPORTS INDUSTRY

• Cultural Norms and Stereotypes: Gender discrimination in sports is perpetuated by deep-seated cultural norms and stereotypes. The perception that sports are primarily for men may limit the opportunities available to the female athletes. To overcome these challenges there requires challenging societal norms and promoting cultural change.
• Reporting Barriers: There are number of barriers that victims of gender discrimination and sexual harassment face while reporting the incidents. These includes lack of awareness about their legal rights and support systems, fear of stigma or reprisal. It is crucial to create safe and confidential reporting mechanisms that can provide support to survivors, and raise awareness about available rights and resources.
• Implementation and Enforcement: Effective implementation and enforcement are essential for the laws and policies that exists.Sports organizations need to take preventive actions by holding offenders accountable, conducting regular training programs, and setting up grievance redressal systems. To protect athletes rights, it is essential to ensure that policies are actively enforces and not just mere formality.

EFFORTS AND SOLUTION

A comprehensive approach combining legal measures, cultural change, education, and institutional assistance is needed to address gender discrimination and sexual harassment in India’s sports industry. The sports industry can act as a driver for societal advancement and female emancipation by supporting gender equality, protecting athletes’ safety, and fostering inclusive environments.

Athletes can do various thing to protect themselves from these abuses like;

“-Understand your rights and responsibilities

– Follow your organisation’s procedures if there are any

– Know what to do to prevent and report concerns

– Look out for each other

– Challenge inappropriate behaviour by others

– Share your concerns with someone else”[28]

Also,

• Sensitization and training programmes: Holding required sensitization programmes for athletes, coaches, and sports administrators can help promote gender equality, sexual harassment, and respectful conduct. Such programmes might encourage the development of a welcoming and courteous sports culture.
• Establishing safe reporting channels, such as helplines, websites, or specialized officers, makes it easier for victims to come forward without worrying about fear of reprisal. To foster trust and guarantee justice, complaints must be properly investigated, and appropriate action should be taken against the offenders.
• Initiatives for gender equality: Promoting equal female participation and representation in sports is crucial. By promoting women’s leadership positions within sports organisations, supporting women’s sports at all levels, and providing adequate resources and facilities, gender disparities can be closed and an inclusive environment can be developed.
• Advocacy and Awareness Campaigns:Aware the public of sexual harassment and gender discrimination, challenge cultural preconceptions, and inspire action are all possible outcomes of advocacy and awareness campaigns. Promoting a healthy sports culture may be mostly accomplished through the media, athletes, and influencers.

CONCLUSION

Sexual harassment and gender discrimination in India’s sports industry have serious legal and ethical implications that call for prompt attention. The findings brought to light the pervasive gender bias and power imbalances in the sports sector that prevent the inclusion and growth of female athletes. There is still considerable work to be done to guarantee that athletes may pursue their aspirations without encountering harassment or discrimination, despite attempts to promote gender equality and provide safe conditions.

Among the laws in India that forbid sexual harassment and gender discrimination are the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act and the Protection of Children from Sexual Offences Act. These laws offer a framework for dealing with these issues and pursuing justice for the victims. However, implementation and enforcement still present significant challenges. Stronger implementation strategies are required, including awareness campaigns, training programmes, and effective grievance redressal procedures, to ensure that athletes feel safe and supported when reporting events.

After examining the problems and the legal positions related to sexual harassment and gender discrimination it is believed that The National Sports Development Bill, 2013,[29] has incorporated provisions with respect to this issue and it is high time that legal sanctity should be given to this draft bill.

Also, Sexual harassment and gender discrimination in sports violate the ethical ideals of justice, equality, and respect. Regardless of gender, athletes should be judged and treated according to their ability, skills, and commitment rather than their gender.

Women’s sports have come a long way historically, but there is still more work to be done. In addition to being one of the fields where gender equality is necessary, sport is frequently considered as a means of empowering women.  To achieve this, we believe that numerous legislative and other efforts of the kind stated must be enacted in the Indian context.

In conclusion, eliminating sexual harassment and gender discrimination in India’s sports business requires a determined effort from all parties concerned. By creating a culture of equality, respect, and inclusivity and allowing female athletes to reach their full potential, the sports industry may aid in the promotion of societal change.

Author: Arya Bhatt, A Student at Dharmashastra National Law University (DNLU), Jabalpur, School of Law, in case of any queries please contact/write back to us at support@ipandlegalfilings.com or IP & Legal Filing

REFERENCES

1. Bhandary S S (Review and need for change of draft National Sports Development bill 2013) https://www.jetir.org/papers/JETIR1809568.pdfaccessed 20 June 2023
2. Blog TE-C, ‘Dangers Lurking for Sportspersons in India: Beyond #METOO and Posh’ (Extra, 21 August2021) https://www.extra-cover.org/post/dangers-lurking-for-sportspersons-in-india-beyond-metoo-and-posh accessed 20 June 2023
3. jan I and Ghazi O, ‘GENDER BIAS IN ACCESS TO SPORTS FACILITIES: PLUGGING THE LEGISLATIVE AND EXECUTIVE LOOPHOLES IN INDIA by Ifra Jan and Omer Ghazi’
4. John A, ‘The Legal Challenges of Reporting and Investigating Sexual Harassment in Indian Sport’ (Scroll.in, 12 October 2018)https://scroll.in/field/897898/the-legal-challenges-of-reporting-and-investigating-sexual-harassment-in-indian-sportaccessed 20 June 2023
5. Krishnan M, ‘India’s Female Athletes Contend with Sexual Harassment – DW – 06/13/2022’ (dw.com, 13 June 2022) https://www.dw.com/en/indias-female-athletes-contend-with-sexual-harassment-in-sports/a-62110783accessed 20 June 2023
6. Mountjoy M and others, ‘International Olympic Committee Consensus Statement: Harassment and Abuse (Non-Accidental Violence) in Sport’ (2016) 50 British Journal of Sports Medicine 1019
7. ——, ‘India: Wrestlers’ Protest Spotlights Sexual Abuse in Sports – DW – 05/04/2023’ (dw.com, 5 May 2023) https://www.dw.com/en/india-wrestlers-protest-puts-spotlight-on-sexual-abuse-in-sports/a-65518424 accessed 20 June 2023
8. ‘Convention on the Elimination of All Forms of Discrimination against Women New York, 18 December 1979’ (OHCHR)https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-elimination-all-forms-discrimination-against-womenaccessed 20 June 2023
9. ‘Gender Discrimination in Sports: Depleting Respect of Women Players in India’ (2017) 6 International Journal of Science and Research (IJSR) 1493
10. ‘Sexual Harassment and Abuse in Sport’ (International Olympic Committee, 20 December 2021)https://olympics.com/ioc/safe-sport/sexual-harrassment-and-abuseaccessed 20 June 2023
11. ‘Sexuality and Gender Perspectives on Sports Ethics’ (Australian Sports Commission) https://www.clearinghouseforsport.gov.au/kb/sexuality-and-gender-perspectives-on-sports-ethics#sexual_harassment_and_abuse accessed 20 June 2023

[1] Mountjoy M and others, ‘International Olympic Committee Consensus Statement: Harassment and Abuse (Non-Accidental Violence) in Sport’ (2016) 50 British Journal of Sports Medicine 1019

[2]Ibid

[3] ‘Victoria Lozano Esparza’ (King’s College London) https://kclpure.kcl.ac.uk/portal/en/persons/victoria-lozano-esparza&gtaccessed 22 June 2023

[4] ‘International Olympic Committee Consensus Statement: Harassment and Abuse (Non-Accidental Violence) in Sport’ (n1)

[5] Ibid

[6]‘Sexual Harassment and Abuse in Sport’ (International Olympic Committee, 20 December 2021) https://olympics.com/ioc/safe-sport/sexual-harrassment-and-abuseaccessed 20 June 2023

[7]‘International Olympic Committee Consensus Statement: Harassment and Abuse (Non-Accidental Violence) in Sport’ (n1)

[8] ‘Harassment and Abuse in Sport’ (Olympics | Olympic Games, Medals, Results, News | IOC)https://webarchive.archive.unhcr.org/20160930162835/https://www.olympic.org/shaaccessed 22 June 2023

[9]Ibid

[10]‘Sexual Harassment and Abuse in Sport’ (n6)

[11] Ibid

[12] ‘International Olympic Committee Consensus Statement: Harassment and Abuse (Non-Accidental Violence) in Sport’ (n1)

[13] Ibid

[14]‘Sexual Harassment and Abuse in Sport’ (n6)

[15]jan I and Ghazi O, ‘GENDER BIAS IN ACCESS TO SPORTS FACILITIES: PLUGGING THE LEGISLATIVE AND EXECUTIVE LOOPHOLES IN INDIA by Ifra Jan and Omer Ghazi’

[16] Ibid

[17]Pradhan S, Keshav K and Patnaik S, ‘An Equal Hue – the Way Forward for the Women in Blue PDF’ (Scribd) https://www.scribd.com/document/469458615/An-Equal-Hue-The-Way-Forward-for-the-Women-in-Blue-pdf  accessed 26 June 2023

[18]jan I and Ghazi O (n15)

[19] ‘Complying with the National Sports Development Code of India, 2011: Ikigai Law’ (TRA, 4 June 2020) https://www.ikigailaw.com/complying-with-the-national-sports-development-code-of-india-2011/accessed 26 June 2023

[20]Vishakha v. State of Rajasthan (1997) 6 SCC 241: 1997 AIR SC 3011

[21] Ibid

[22]jan I and Ghazi O (n15)

[23] Bhandary S S (Review and need for change of draft National Sports Development bill 2013) https://www.jetir.org/papers/JETIR1809568.pdfaccessed 20 June 2023

[24]jan I and Ghazi O (n15)

[25] Ibid

[26] Ibid

[27] ‘Convention on the Elimination of All Forms of Discrimination against Women New York, 18 December 1979’ (OHCHR) https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-elimination-all-forms-discrimination-against-women accessed 20 June 2023

[28] ‘Sexual Harassment and Abuse in Sport’ (n6)

[29]jan I and Ghazi O (n15)