Domestic Violence: A Comparative Analysis in the UK, USA, and Russia
Written by Keyur Tripathi
Table of Contents
Introduction
Domestic violence is a global issue that affects millions of people worldwide, regardless of their ethnicity, race, religion, or socio-economic status. Although there are various forms of domestic violence, the most common ones are physical, emotional, and sexual abuse. Domestic violence is a serious concern in India, the United States, the United Kingdom, and Russia, among other countries. In this article, we will compare the prevalence, causes, and laws related to domestic violence in these four countries.
Comparison
India: In India, domestic violence is a common issue that affects women of all ages, classes, and castes. According to the National Crime Records Bureau (NCRB), domestic violence is the most common form of violence against women, with 30% of all crimes against women being domestic violence.[1] The main causes of domestic violence in India are patriarchal attitudes, lack of education, poverty, and social stigma.
The Indian government has enacted several laws to protect women from domestic violence, including the Protection of Women from Domestic Violence Act, of 2005.[2] This act provides for a range of reliefs, including protection orders, residence orders, and monetary relief to victims of domestic violence. However, there is still a long way to go in terms of implementing these laws effectively and changing societal attitudes towards domestic violence.
United States: Domestic violence is a significant problem in the United States, with one in four women and one in nine men experiencing severe physical violence by an intimate partner in their lifetime. The causes of domestic violence in the US include poverty, substance abuse, and mental health issues.
The US government has enacted several laws to protect victims of domestic violence, including the Violence Against Women Act (VAWA). VAWA provides funding for programs that assist victims of domestic violence, including shelters and hotlines. It also provides for the issuance of protection orders and the prosecution of abusers. However, the effectiveness of these laws is limited by the lack of resources and funding allocated to them.[3]
United Kingdom: Domestic violence is a significant issue in the UK, with an estimated two million adults experiencing domestic abuse each year. The causes of domestic violence in the UK are similar to those in the US and include poverty, substance abuse, and mental health issues.
The UK government has enacted several laws to protect victims of domestic violence, including the Domestic Abuse Act 2021.[4] This act provides for a range of measures, including a new statutory definition of domestic abuse, new orders to protect victims, and the criminalization of coercive and controlling behavior. However, the effectiveness of these laws is limited by the lack of resources and funding allocated to them.
Russia: Domestic violence is a widespread issue in Russia, with an estimated 16,000 women being killed each year by their partners or family members. The causes of domestic violence in Russia include poverty, substance abuse, and societal attitudes towards gender roles.[5]
The Russian government has enacted several laws to protect victims of domestic violence, including the Law on Prevention of Domestic Violence, 2017. This law provides for the issuance of restraining orders, fines, and imprisonment for perpetrators of domestic violence. However, the effectiveness of these laws is limited by the lack of resources and funding allocated to them, as well as the societal acceptance of domestic violence.
Challenges
- Reporting rates: While all four countries have laws in place to protect victims of domestic violence, the reporting rates can vary significantly. In India, there is still a significant stigma attached to reporting domestic violence, and many victims do not come forward due to fear of social stigma or retribution from their abusers. In contrast, reporting rates in the US and UK are relatively high, but there are still challenges in ensuring that all victims are identified and protected. In Russia, domestic violence was decriminalized in 2017, which has made it even more challenging for victims to seek help and justice[6].
- Law enforcement response: In all four countries, there have been instances where law enforcement officials have been accused of not taking domestic violence seriously enough. However, the severity of the issue varies. In India, there have been reports of police officers refusing to register complaints of domestic violence, or advising women to “adjust” to the situation. In the US and UK, there have been instances of police officers failing to properly investigate or prosecute domestic violence cases. In Russia, the decriminalization of domestic violence has had a significant impact on the ability of law enforcement officials to respond to cases of abuse.
- Support services: All four countries have support services available for victims of domestic violence, but the availability and quality of these services can vary significantly. In India, there is a lack of government-funded support services, and many NGOs and shelters are underfunded and overstretched. In the US and UK, there are a variety of support services available, including hotlines, shelters, and counseling services, but funding can still be a challenge. In Russia, the availability of support services has decreased since the decriminalization of domestic violence, and there are concerns that victims are not able to access the help they need.
- Cultural and social factors: Domestic violence is often shaped by cultural and social factors, which can vary significantly between countries. For example, in India, there is still a prevalent patriarchal mindset that can lead to violence against women being normalized or justified. In the US, there is a culture of gun ownership that can lead to an increased risk of homicide in cases of domestic violence. In Russia, there is a cultural expectation that women should be subservient to their husbands, which can contribute to a culture of abuse.
- Government response: The response of governments to domestic violence can also vary significantly. In India, there have been efforts in recent years to strengthen laws and increase awareness about domestic violence, but progress has been slow. In the US and UK, there have been efforts to provide more funding for support services and to strengthen laws around domestic violence. In Russia, the decriminalization of domestic violence has been widely criticized, and there are ongoing calls for the government to take action to protect victims.
Legal Differences
According to the National Crime Records Bureau, domestic violence cases have been on the rise in India in recent years, with over 4 lakh cases reported in 2019 alone.[7] The Indian Constitution recognizes the right to life and personal liberty as a fundamental right, and this includes the right to live with dignity and without fear of violence.
The Constitution of India provides various provisions to protect the victims of domestic violence. Article 14 of the Constitution[8] provides for equality before the law and equal protection of the law to all citizens. Article 15 prohibits discrimination on the grounds of religion, race, caste, sex, or place of birth. Article 21 guarantees the right to life and personal liberty, which includes the right to live with dignity and free from violence.
The Protection of Women from Domestic Violence Act (PWDVA) was enacted in India in 2005 to protect women from domestic violence. The PWDVA recognizes domestic violence as a human rights violation and provides for a wide range of protective measures. Under the Act, women who have experienced domestic violence can seek a protection order, a residence order, and a monetary order.
In comparison to India, the United States, the United Kingdom, and Russia also have laws and provisions to protect victims of domestic violence. In the United States, the Violence Against Women Act (VAWA) was enacted in 1994, which provides federal resources to combat domestic violence and sexual assault. The Act also provides for a range of protective measures, including restraining orders, emergency shelter, and legal assistance.
In the United Kingdom, the Domestic Abuse Bill was passed in 2021, which defines domestic abuse as a pattern of behavior that is controlling, coercive, or threatening, and that causes harm or distress to the victim.[9] The Bill provides for protective measures, such as restraining orders, and criminalizes coercive and controlling behavior in intimate relationships.
In Russia, the Law on Prevention of Domestic Violence was passed in 2017, which provides for protective measures for victims of domestic violence, such as restraining orders, and imposes criminal liability on perpetrators of domestic violence.[10] However, the law has been criticized for not providing enough protection to victims and for being too lenient on perpetrators.
Conclusion
Domestic violence is a serious concern in India, the United States, the United Kingdom, and Russia. While each country has enacted laws to protect victims of domestic violence, there is still a long way to go in terms of implementing these laws effectively and changing societal attitudes towards domestic violence. It is crucial to address the root causes of domestic violence, including poverty, substance abuse, and mental health issues, in order to prevent and reduce the incidence of domestic violence worldwide.
Keywords: Domestic Violence: A Comparative IN UK & USA; Domestic Violence: A Comparative UK & RUSSIA; Domestic Violence: A Comparative in USA & RUSSIA; Domestic Violence: A Comparative in India & USA, Domestic Violence: A Comparative in India and UK; Domestic Violence: A Comparative in India & Russia
[1] Harbishettar, V. And Math, S. (2014) “Violence Against Women In India: Comprehensive Care For Survivors”, The Indian Journal Of Medical Research, 140(2), P. 157. Available At: Https://Www.Ncbi.Nlm.Nih.Gov/Pmc/Articles/PMC4216486/ (Accessed: 6 April 2022).
[2] ACT NO. 43 OF 2005
[3] Modi, M., Palmer, S. And Armstrong, A. (2014) “The Role Of Violence Against Women Act In Addressing Intimate Partner Violence: A Public Health Issue”, Journal Of Women’s Health, 23(3), Pp. 253-259. Doi: 10.1089/Jwh.2013.4387.
[4] The Domestic Abuse Act 2021 | Equation (2022). Available At: Https://Equation.Org.Uk/Domestic-Abuse/Da-Act-Updates/ (Accessed: 6 April 2022).
[5]Killings Of Women And Girls By Their Intimate Partner Or Other Family Members (2023) Unodc.Org. Available At: Https://Www.Unodc.Org/Documents/Data-And-Analysis/Statistics/Crime/UN_Brieffem_251121.Pdf (Accessed: 6 April 2022).
[6] Russia: Bill To Decriminalize Domestic Violence (2017). Available At: Https://Www.Hrw.Org/News/2017/01/23/Russia-Bill-Decriminalize-Domestic-Violence (Accessed: 6 April 2022).
[7] Crime In India National Crime Records Bureau, (Ministry Of Home Affairs), Government Of India (2019) Ncrb.Gov.In. Available At: Https://Ncrb.Gov.In/Sites/Default/Files/CII%202019%20Volume%201.Pdf (Accessed: 6 April 2022).
[8] The State Shall Not Deny To Any Person Equality Before The Law Or The Equal Protection Of The Laws Within The Territory Of India.
[9] Domestic Abuse (2021). Available At: Https://Pandorsetscb.Proceduresonline.Com/P_Dom_Viol_Abuse.Html (Accessed: 7 April 2022).
[10] Practical Implications Of Current Domestic Violence Research: For Law Enforcement, Prosecutors And Judges (2021) Ojp.Gov. Available At: Https://Www.Ojp.Gov/Pdffiles1/Nij/225722.Pdf (Accessed: 7 April 2022).
