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Transgender Rights

From Justice Definitions

‘Transgender’ (or simply ‘trans’) refers to an individual “whose gender identity differs from the sex [gender] the person was identified as having at birth.”[1] By “gender,” we refer to it as a social construct that includes “roles, behaviours, expressions and identities”[2] of an individual, as viewed through the lens of being a man, woman, or genderqueer person. Being a socially constructed norm, it is not fixed and can rather change over time in the way the individual views themself and is interacted with by others. It is an umbrella term that covers a host of gender identities and expressions. These are trans men (individuals who were assigned female at birth but whose gender identity is that of a man), trans women (individuals who were assigned male at birth but whose gender identity is that of a woman), and genderqueer/non-binary (an umbrella term for those whose gender identities fall neither within the classification of male nor female—identities that are outside the gender binary) alongside the various socio-cultural identities. Here, socio-cultural identities are a range of non-normative gender identities and expressions with long cultural roots. There are individuals who may or may not have undergone any form of gender-affirming medical procedure, but are commonly associated in India as being trans. Due to vast regional diversity, there exists a variety of trans identities in India, of which a few have been covered in the upcoming sections. Lastly, we must note that while legally intersex individuals are covered as being trans persons in India, the step has gained criticism, as there is a stark difference between the two. It is also important here to note the use of the term 'cisgender' as “an individual whose gender identity aligns with their sex assigned at birth.”[3] Thus, an individual who aligns with or feels comfortable in the gender assigned to them is, if their gender is a man, called a cis man, and similarly, a cis woman.

Trans people have a long history covering not only mythological texts but also the various empires of India, until the British control in the 19th century.[4] It is not to say that they always had a high social status, but it was only during the centralised colonial control that they faced some of the most intense, wide-scale and centralised scrutiny. In 1871, the British enacted the Criminal Tribes Act that regarded various caste and gender identities, including trans individuals, as hereditary criminals. Sections 24 to 31 of the Act covered various provisions of the Act, including maintaining a registry of trans persons, criminalising various acts, including dancing or singing in public areas, and restricting others, including adoption or making a will. Similar to this was another local law, the Telangana Eunuchs Act, 1329 Fasli (enacted in 1919), which had provisions similar to those of the Criminal Tribes Act.[5] While the Criminal Tribes Act was repealed in 1952, the latter was struck down only in 2023 by the High Court of Telangana, due to being violative of the Constitution as well as the Supreme Court’s directives in National Legal Services Authority (NALSA) v. Union of India.[6]

Recently, the Ministry of Social Justice and Empowerment, present and passed The Transgender Persons (Protection of Rights) Amendment Act, 2026, which brough major changes into the previous Transgender Persons Act, 2019, that garnered large scale oppositions against this dilution of the Act. The Amendment was further opposed and warned against by the Supreme Court-appointed Expert Committee,[7] Rajasthan High Court,[8][9] Members of the National Council of Transgender Persons,[10] among many more. As of May 2026, challenges against the same have been petitioned in the Supreme Court and hearing has begun. Although, the Court has refused to put a stay on the implementing of the bill since it has not been notified yet.[11]

At the same time, the growing discourse surrounding transgender rights is focused towards asserting that trans individuals shall be provided with the same rights, both positive and negative, that are afforded to cisgender individuals.[12] One of the most prominent concern of trans rights activism has been considered to be regarding the visibility of trans individual in the mainstream, as well as the introduction of the term “transgender” to the common parlance.[13] Further core obligations that the UN Office of High Commission of Human Rights (OHCHR) provide in order to uphold trans and larger queer/LGBTQIA+ rights include to: protecting individuals from violence (i.e. providing necessary legal safeguards), preventing torture and ill treatment (i.e. prohibiting harassment as abuse in the hands of state as well as non-state actors), repealing laws criminalising trans individuals, prohibiting and addressing discrimination and discrimination on the basis of gender identity or sex characteristics, and safeguarding “freedoms of expression, association and peaceful assembly” for trans individuals (i.e. allowing trans individuals to assert their identity publicly).[14] In additional to these, ensuring quick, accessible and transparent legal gender recognition for binary as well as non-binary trans individuals has been widely considered as necessary to upholding individual’s “right to privacy, self-determination, non-discrimination and dignity.”[15]

Official Definition of Transgender Person

Transgender Person as defined in legislation

The Transgender Persons (Protection of Rights) Act, 2019 under section 2(k), previously defined a transgender person as “a person whose gender does not match with the gender assigned to that person at birth and includes trans-man or trans-woman (whether or not such person has undergone Sex Reassignment Surgery or hormone therapy or laser therapy or such other therapy), person with intersex variations, genderqueer and person having such socio-cultural identities as kinner, hijra, aravani and jogta.”

Now, following the 2026 Amendment to the act it includes 4 categories of individuals only. These are:

  1. Trans persons belonging to socio-cultural gender identities;
  2. Intersex Persons (the definition of intersex persons has been omitted);
  3. Eunuch; and
  4. Person who "has been, by force, allurement, inducement, deceit or undue influence, either with or without consent, compelled to assume, adopt, or outwardly present a transgender identity," which may be done by "mutilation, emasculation, castration, amputation, or any surgical, chemical, or hormonal procedure or otherwise.

Further, the proviso to the definition explicitly excludes "persons with different sexual orientations and self-perceived sexual identities" from the definition, even if their identity had been certified under the pre-amendment act. This retrospective removal of the right to self-identification has been questioned based upon settled legal principles as well as violation of the NALSA Judgement.[16]

Legal provisions relating to Transgender Persons

National

The Transgender Persons Act, 2019, as well as its 2020 Rules, is the main provision in India that covers the rights of trans persons. The Act is divided into 9 Chapters. The Act received major amendments in 2026, which changes the provisions around self-identification right, procedure for getting a trans Identification card, and instituting additional penalties for forcefully inducing someone to be trans. Previously, section 4 of the Act required only an application to the District Magistrate (DM), who on their own discretion shall issue the certificate. But now, the DM can take assistance from medical experts to asses the validity of the application. Furthermore, the amendment to section 7 not ensures that any individual who undergoes gender affirmative surgery at any medical institution, their information is required to be provided to the DM, and any other prescribed authority. The Ministry has claimed, that the narrowing of the definition comes in part to "not to protect each and every class of persons with various gender identities, self-perceived sex/gender identities or gender fluidities" but only specific trans socio-cultural identities, and hence the amendment was required.[17]

These amendments also altered section 18 of the Act, which provided for penalties against harms caused to a trans individuals. But, the present amendment now provides for additional offences that can be caused by forcing, alluring or hurting someone to be compelled to be a trans individual. The added offences are as provided in the table below:

Offence Provision Punishment
Compelling or Enticing transgender person to indulge in forced or bonded labour s. 18(a) Imprisonment for (minimum of six months) up to two years + fine
Kidnapping or Abducting an adult and causing grievous hurt, or permanent/ severe injury in order to compel person to present or assume a trans identity s. 18(e) Rigorous imprisonment (minimum ten years) and up to imprisonment for life + fine (minimum two lakh rupees)
Kidnapping or Abducting a child and causing grievous hurt, or permanent/ severe injury in order to compel person to present or assume a trans identity s. 18(f) Rigorous imprisonment for life + fine (minimum five lakh rupees)
Forcing, threatening, alluring, etc. an adult in order to force them to outwardly present as a trans person, or be engaged in bonded labour s. 18(g) Rigorous imprisonment (minimum five years) which may extend to ten years + fine (minimum one lakh rupees)
Forcing, threatening, alluring, etc. a child in order to force them to outwardly present as a trans person, or be engaged in bonded labour s. 18(h) Rigorous imprisonment (minimum ten years) and up to fourteen years+ fine (minimum three lakh rupees)

The amendment has received large scale criticism for its proposed changes. This includes on the grounds of: removal of right to self identification, lack of proof for claims made in the objects of the act, use of vague and colonial language to criminalize trans individuals and trans-affirming organizations.[18] Additionally, the UN Human Rights office, criticised the Bill due to its passage without adequate stakeholder consultation, as well as for its backsliding on hard-won rights of trans people.[19] At the same time, the UN Independent Expert on protection against violence and discrimination based on sexual orientation and gender identity (among other experts) has requested for information from the government in relation to the changes proposed by the amendment.[20]

Furthermore, chapter 4 covers the welfare measures that the government shall undertake. Chapters 5 and 6 outline the obligations of various persons (parents and guardians) and institutions (educational institutions and workplaces) to ensure inclusive spaces for trans individuals, including establishing grievance redressal mechanisms. It further declares that the government would need to ensure the setting up of programmes for vocational training of trans persons, alongside providing adequate medical care. Chapter 7 covers the provisions relating to the National Council for Transgender Persons. Lastly, chapter 8 now declares offences and penalties upon any persons in case they cause any harm or injury to a trans person or by forcing someone to present as a trans person. 

 The Scheme of the Act Pre-2026 Amendment: Chapter 2 of the act declares any form of discrimination against a trans person by any individual or institution as illegal. Chapter 3 covers the right to self-identification for trans people. These are further elaborated upon in the detailed procedures outlined in rules 4-9 of the Transgender Person Rules, 2020. While the NALSA judgement declares that each trans individual should have a right to self-identify, the act provides for a long procedure of gaining a transgender identity card, with different procedures for genderqueer identity, and trans men and trans women.[21]
International

The UN Declaration of Human Rights, while expressly not covering trans rights, under Article 2 prohibits discrimination of “any kind, such as race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status.” In 2011, the UN Human Rights Council, in a historic decision recognising the concerns faced by individuals being discriminated against based upon their gender identity, instructed the High Commissioner for Human Rights to undertake a study, along with calling upon a panel discussion based upon the study.[22] This study was published at the end of the same year, titled “Discriminatory laws and practices and acts of violence against individuals based on their sexual orientation and gender identity.”[23]

The International Covenant on Economic, Social and Cultural Rights’  Committee on Economic, Social and Cultural Rights has previously highlighted that there “other status” would mean to include protection for trans individuals as “gender identity is recognized as among the prohibited grounds of discrimination; for example, persons who are transgender, transsexual or intersex often face serious human rights violation…”[24] Later, the Committee added that non-discrimination and equal treatment in the context of sexual and reproductive health included a core obligation under the treaty, alongside prohibiting against coercive medical practices include those perpetuated in order to recognise one’s gender identity.[25] The Committee has also reaffirmed the fact that workplace discrimination against individuals based upon their trans identity violates the treaty and puts an obligation upon states to ensure an accessible workspace.[26]

The UN Committee on the Rights of the Child (CRC) has also interpreted the Convention on the Rights of the Child to provide safeguards to promote the rights of trans individuals. The CRC has stated that all adolescents have the right to “freedom of expression and respect for their physical and psychological integrity, gender identity and emerging autonomy.” This entails that, in focusing on minors' evolving autonomy, their views should be genuinely taken into account in determining their best interests. Additionally, in medical as well as non-medical decision making, it shall be ensured that trans individuals have access to information, psychological counselling and other services provided without any stigma and harassment so they may better make decisions relating to their gender identity.[27]

The UN Committee on the Elimination of Discrimination Against Women has highlighted the barriers faced by trans women and intersex persons in gaining access to justice and facing discrimination due to their intersecting identities. Taking these into account, it provided a wide range of recommendations to state parties to ensure an effective, accessible and gender-sensitive justice system in consonance with the Convention on the Elimination of Discrimination Against Women.[28]

At this juncture, it is also important to bring the Yogyakarta Principles into light. The Yogyakarta Principles and the Yogyakarta Principles plus-10 underscored the rights of people with diverse sexual orientations and gender identities, affirming binding international legal obligations.[29] Although these principles themselves are not obligatory upon states to follow, they highlight core principles and requirements that states must follow, and often form the essential backbone of multiple works on trans rights due to being extremely influential.

The Committee Against Torture under the UN Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment [it should be noted that India has signed but not ratified the Convention] has stated that it is the obligation of the states to prevent torture and ill treatment against marginalised groups, including trans individuals. Irrespective of an individual’s gender identity or the reason for detention, states have to ensure that individuals are “fully prosecuting and punishing all acts of violence and abuse against these [trans and other marginalised groups] individuals and ensuring implementation of other positive measures of prevention and protection.”[30]

Transgender Person as defined in official document

The Supreme Court Handbook on Combating Gender Stereotypes,[31] released in 2023, differentiated between terms that enforce negative stereotypes and gender-affirming terms. The following table provides some of these terms that directly relate to the discourse on trans rights:

Certain Terms Provided for in the Handbook
Stereotype-Promoting/Outdated Language Affirmative Language
Biological sex / biological male / biological female Sex assigned at birth
Born a girl/boy Assigned female/male at birth
Sex change Sex reassignment or gender transition
Transsexual Transgender

It further points out the harmful stereotype held against trans persons that they cannot be raped. Trans individuals are raped and constitute one of the most vulnerable communities to sexual violence. It is incorrect to assume that all trans individuals are sex workers, due to which they consent to all forms of sex. Even trans sex workers are periodically raped when they do not consent to certain actions as part of their profession.[32]

Transgender Person as defined in official government reports

Report of the Expert Committee on the Issues relating to Transgender Persons

In 2014, the Ministry of Social Justice and Empowerment constituted an Expert Committee to report on the issues faced by the trans community in India.[33] The report was based upon a variety of consultations, ranging from civil societies to private individuals. It begins by laying out definitions related to trans individuals. It defines “trans*” (with the asterisk) as the term used within the discipline of gender studies to “refer to all persons whose own sense of gender does not match with the gender assigned to them at birth”. It further provides the normative definition of a transgender person as “all persons whose own sense of gender does not match with the gender assigned to them at birth.”

Alongside that, the report also provides certain details regarding specific socio-cultural trans identities. It defines 'Kothi' as:

A local language term used in South East Asia to refer to PAGMB [person assigned male at birth], who identify with characteristics, roles and behaviors conventionally associated with the feminine. Kothis have also been defined as effeminate PAGMBs, who like to cross dress and see themselves as women and use the female pronoun to describe themselves.

It further defines hijra as individuals who are “usually PAGMBs and rarely persons with intersex variations but identify with the characteristics, roles and behaviours conventionally associated with the feminine. They cross dress and live their life as women or may identify as belonging to the ‘third gender’.” While a hijra person typically presents themselves as feminine at all times, a Kothi person mostly presents themselves as masculine, “revealing” their feminine identity only during certain occasions.

Lastly, the report defines jogtas to be individuals assigned male at birth “who as children are dedicated to a goddess and later ritually cross dressed.”

The report further highlights issues faced by trans individuals in India, including trans children and youth, measures that may be taken to legally identify trans individuals, legal and policy interventions, inclusive and convergence practices that may be undertaken by the government, etc. While being a positive step, the committee still played a part in ensuring certain trans identities, with those from trans-feminine identities being named as members, while those from trans-masculine, intersex and intergender communities were referred to only as special invites.[34]

43rd Report of the Standing Committee on Social Justice and Empowerment (2016-17)

Before the Transgender Persons Act 2019 was passed, it was sent to a Standing Committee (Forty-Third Report presented in July 2017),  in reference to the then-presented Transgender Persons Bill 2016.[35] The earlier bill defined transgender individuals as persons who are: “A. neither wholly female nor wholly male; B. a combination of female or male; or C. neither female nor male, and whose sense of gender does not match with the gender assigned to the person at the time of birth, and includes trans-men and women, persons with inter-sex variations and genderqueers.”

The committee in the report pointed out that not only was this classification unscientific, conflating trans identities as only existing between biological sex binaries, but it also ignored legal jurisprudence and was a violation of the person's fundamental right. The report provided a definition similar to the present Transgender Persons Act, excluding persons with intersex variations. It has been further mentioned that the bill clearly does not “include, address and protect the interest of intersex persons.” In this regard, the Ministry replied incorrectly that the term 'transgender' includes intersex persons. The same was accepted by the committee.

Transgender Person as defined in case law

The Supreme Court’s verdict in NALSA v. Union of India has become the foremost judgment when discussing the rights of trans persons in India. The court in its judgement detailed the historical presence of trans persons in India, along with the violations they have faced. The court noted that an individual’s right to self-identify as well as to express their gender identity is protected by articles 19(1)(a) and 21 of the Constitution, as they form an integral part of one’s personal autonomy.

The court defined transgender as an “umbrella term for persons whose gender identity, gender expression or behaviour does not conform to their biological sex.” The court further noted that trans individuals do not conform to their gender assigned at birth and may include Hijras/Enuchs. The court’s terminology here has been criticised,[36] as the state, often in the interest of highlighting the “local” identity, ignores that conceptual baggage, where often trans masculine identities and other non-conforming identities are ignored. In other words, the court here only views the identities of individuals that are trans-feminine. Further, it continues to understand trans identities based upon reproductive anatomy, alongside confusing intersex and trans identities.[37]

Other Landmark Cases

A landmark judgement for trans rights came in 2025, when the SC noted[38] through reference to disability rights, noted that reasonable accommodation for trans persons runs at the core of the Transgender Persons Act, as well as substantive equality under Article 14 of the Constitution. It held that not only were the private establishments discriminated against by the petitioner, but that the Union and State governments had also discriminated through their inaction. Further, the States and the Union had failed to establish an equal opportunity policy and rules for the Act, as had been previously directed in Shanavi Ponnusamy v. Ministry of Civil Aviation.[39] The court also expressed disapproval of the state government’s inaction in establishing Transgender Protection Cells and grievance redressal mechanisms. Along with a hold of other directions, the court also directed the formulation of an Advisory Committee to look into the gaps of the Act, help formulate an equal opportunity policy and streamline grievance and documentation processes. While it was seen as an expansion of the court’s mandate NALSA judgement,[40] gaps still remained.[41]

Terms for Transgender Persons

Slight differences and nuances in the concept

'Transgender' is an umbrella term for a variety of gender identities and expressions that do not fit in the binaries of man and woman that are assigned at birth. Therefore, it would be incorrect to assume that there is a normative trans identity in India, especially in part due to the large variation in socio-cultural practices.  Apart from hijra and Kothi discussed in the previous section, other terminologies have been mentioned below:[42]

Aravanis and Thirunangai: 'Aravani' is a local term of Tamil Nadu that refers to individuals assigned male at birth, but who find themselves associated with feminine or non-binary identity. ‘Thirunangai’ literally translates to ‘respectable woman’ and is thus preferred by many over Aravani.[43]

Jogti/Jogappas: 'Jogappa' refers to trans-feminine individuals from the states of North Karnataka, parts of Andhra Pradesh, and Maharashtra who dedicate themselves to the worship of Goddess Yellamma (Renukha Devi). At certain times, the term ‘jogti hijra’ over ‘jogti’ (feminine worshipper) may be used by individuals to differentiate themselves from ‘jogtas’ who are typically cis men.

Nupa Maanba/ Nupi Maanbis: Meitei terms from Manipur to refer to trans men and trans women, respectively. Here, the maanba/maanbis translates to 'similar' or 'resembling', while the counterpart means 'woman/wife' (nupi) or 'man/husband' (nupa).

Shiv Shaktis: Individuals assigned male at birth who are considered to have closeness with the Lord Shiva and are, as such, married or possessed by the lord, having feminine gender expression during certain rituals or festivals.

Thirunangai/Thirunambi: Terms local to Tamil Nadu, 'Thirunangai' refers to a trans woman, while 'Thirunambi' refers to a trans man.[44]

Alongside these, there are many other terms that individuals use, especially when referring to trans men in India.[45]

International Experience

Argentina

Argentina in 2012 became one of the earliest nations to allow trans individuals to legally change their name and gender markers, based upon individual’s self-identification through its Gender Identity Law.[46] Further in 2021, Argentina allowed the gender marker “X” to be used in official documents and passports, alongside providing 1% reservation for trans persons and granting tax benefits to private establishments that employed trans individuals.[47]

Malta

Malta in 2015 passed the Gender Identity, Gender Expression and Sex Characteristics (GIGESC) Act[48] that has been hailed as historic law, for promoting self-identification of trans individuals. While the act does not specifically define trans individuals, it defines non-binary individuals as, “all gender identities other than male or female.” For the purposes of the act, a minor is considered to be an individual who has reached 16 years of age, as a move to highlight the growing acceptance of identities of trans minors.

Malta through the Act also became the first European state to place a ban on the harm conversion therapies.[49] It further provides for punishments for violating the provisions of the act, discriminating against any trans individuals, any offence committed against trans individual based upon their gender identity, etc. The act also recognises the concept of “lived gender” wherein an individual in detention can have their gender identity through an affidavit confirming their “gender identity and its public expression over a sustained period of time.”

Appearance of Transgender Person in Database

Crimes in India Report

The Crimes in India (CII) report is published annually by the National Crime Records Bureau (NCRB). Before 2020, the NCRB reports only covered two genders: men and women. It was following a judgment of the Delhi High Court[50] regarding The Prison Statistics India (PSI) that the NCRB started including trans individuals in its report. Although it has been claimed that present reports under-represent crimes under trans individuals due to the unavailability of gender identity cards, non-reporting/under-reporting of crimes, etc.

The present CII (2023) report notes that, from 2021-2023, a total of 19 cases were registered under the Transgender Persons Act, 2019. Of these, the highest were registered in 2023 (11), followed by 2021 (7) and 2022 (1). Of the cases in 2023, all were registered in Kerala (4) and Tamil Nadu (7).[51]

Prison Statistics India

Similar to CII, as mentioned above, PSI began highlighting data ontrans individuals from the 2021 Report onwards. Accordingly, the number of transgender inmates has ranged from 91 in 2021, to 97 in 2022, and 108 in 2023. By the end of 2023, 86 inmates were under trial. Two of them had been in prison for a period of 3-5 years, 12 for 2-3 years, 5 for 1-2 years, 7 for 6-12 months, and the rest for less than 6 months.

In 2021, trans individuals had the highest occupancy rate of all genders at 212%. This was reduced to 96% in 2023, with capacity being increased in central jails. Among the states from which inmates were admitted, Maharashtra (35) has the highest intake, followed by Telangana (33), West Bengal (31) and Madhya Pradesh (21).[52]

The image provides a graph for the occupancy capacity for the various types of prisons in India. Notably for trans individuals, the occupancy rates were at 118% for central prisons and 95% for all prisons.
Occupancy Rates in various types of prisons in India, as of 31st December 2023.

Fig. 1: Occupancy Rates in various types of prisons in India, as of 31st December 2023.

While considerable focus has been given to the lived experiences faced by trans individuals in the prison system,[53] most state laws have continued to remain unaccommodative.[54]

Research that engages with Transgender Rights

Human Rights violations against the transgender community

Published in 2003, the following report by People’s Union for Civil Liberties-Karnataka (PUCL-K) forms one of the earliest and most prominent reports on the human rights violations faced by Hijra and Kothi individuals, who mainly engage in sex work or begging. Through focusing on personal narratives, it focuses on how the legal system persecuted the already marginalised group, from accounts of police violence to rape in prisons. But the report is not limited to these; it also offers insights into legal strategies that are being utilised for the betterment of the community, along with further recommendations. The reports also become important because they provide additional resources, including an individual’s rights in criminal proceedings, copies of draft applications and letters, the procedure for obtaining gender-affirming care, etc.[55] Further, a similar report was published by PUCL-K, this time with a jury headed by (Retd.)  Justice Nagmohan Das titled ‘Police Violence Against Women and Transgender Sex Workers’.[56]

Shifting Subjects of State Legibility: Gender Minorities and the Law in India

The following paper by Dipika Jain, published at the onset of the NALSA judgement, aims to analyse and contextualise the reasoning and the critical fallacies of the judgement. It explores the trajectory of historical development from ancient times to the present, when transgender individuals began to be seen as a homogenous community of “eunuchs”. Further, it examines the court's rationale in the NALSA judgement by considering their interpretation of international law obligations, international developments, and constitutional obligations. There then forms the base to aid in comparison of the court’s rationale with the previous judgement in Suresh Kumar Koushal v. Naz Foundation[57] where the court had previously agreed on the validity of Section 377 of the Indian Penal Code. Lastly, the author focuses on the restrictive definition of ‘transgender’ used in the NALSA judgement that ignores the diverse experience of gender-variant individuals in South Asia.[58]

Trans Equality in India: Affirmation of the Right to Self-determination of Gender

Published in 2020, the following paper attempts towards promote and affirmation of the right to self-determination by the state through adopting a transformative equality model. The paper, through using the Transgender Persons Act, 2019 as a backdrop, provides an overview of the constitutional development of the right to self-determination and examines it as an essential part of the right to life. Ultimately, the paper criticises the medical model of gender identity recognition, where the individuals (trans men and women) have to undergo gender affirmative procedures before their identity can be affirmed.[59]

Transgender Equality: Court Decision on Transgender Rights in India

A resource book by the Centre for Law & Policy Research (CLPR), ‘Transforming Courts’, focuses on providing a variety of summaries for decisions of Supreme and High Courts. The book lists out both perceived positive and negative judgments/orders in reference to transgender rights. Some of the broad themes upon which judgements are divided are: Rights to self-determination, Public Employment, Legal Recognition, Kinship Rights, Criminal Law, Access to Education, and the Right to Social Security.[60]

Challenges

Against Transgender Persons Act

At present, one of the most prominent challenges that remains for trans individuals is the challenge of legal recognition. Previously, while the process, against NALSA’s conception of self-determination, requires non-binary individuals to forward an application to their local District Magistrate, trans men and women are required to provide details for the gender affirmative care received before their identity can be recognised. Yet, now larger challenges loom over the rights of trans individuals, alongside fear of constant criminalization over their actions. The passage of the act in a short span of time, without any public consultation, and a lack of data provided for its rationale has further created panic as to its applicability to backslide on rights of an already marginalised community.

At present, various petition has been raised before the Supreme Court as well as various High Courts challenging the amendment, and the hearings are underway.[61] Clubbed petitions were already underway at the Court to challenge their provisions of the (unamended) Transgender Persons Act, alongside others, to grant relief to trans individuals.[62] Issues have also been raised against the National Portal for Transgender Persons, which has been recognised as the online platform for obtaining Transgender Identity Cards.[63]

Policy-Level Challenges

The SMILE (Support for Marginalised Individuals for Livelihood and Enterprise) scheme by the Ministry of Social Justice and Empowerment is a central scheme that has been the flagship schemes that has been introduced to provide holistic support through the “Comprehensive Rehabilitation for Welfare of Transgender Persons.”[64] It covers skill development & employment, scholarships, composite medical health (through Ayushman Bharat – Pradhan Mantri Jan Arogya Yojana, and Ayushman Bharat TG Plus), safe shelters (or Garima Grehs), and transgender protection cells. As a comprehensive scheme, SMILE has been unable to achieve its intended outcome due to accessibility challenges, delays and financial crunch, focus on uniformity, etc.[65][66]

Other Challenges

Additionally, trans individuals are commonly made victims of violence and stigma.[67] Ranging from their own home and educational institutions to even healthcare facilities. Furthermore, these exacerbate already existent physical and mental health concerns of trans individuals, leading to high rates of depression, anxiety, and suicidal ideation alongside other comorbidities.[68]

Way Ahead

The way forward requires dealing with multiple challenges to ensure trans individuals are able to live in India with dignity. Even as the Transgender Persons Act prohibits discrimination, acts of violence and harassment in the social, educational and economic spheres, etc., have been well documented.[69] The future requires adequate protection for trans individuals in all spheres, alongside full realisation of the provided for in the NALSA judgement.

Related terms

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Page created 2026-08-21  ·  Last updated 2026-08-23
  1. ↑ 'Transgender' (Merriam-Webster Dictionary) <https://www.merriam-webster.com/dictionary/transgender>
  2. ↑ Canadian Institute of Health Research, 'What is gender? What is sex?' (2023) <https://cihr-irsc.gc.ca/e/48642.html>
  3. ↑ APA Dictionary of Psychology, 'Cisgender' (American Psychological Association) <https://dictionary.apa.org/cisgender>
  4. ↑ M Michelraj, 'Historical Evolution of Transgender Community in India' (2015) 4 Asian Rev of Social Sci 1 <https://www.trp.org.in/wp-content/uploads/2015/10/ARSS-Vol.4-No.1-Jan-June-2015-pp.17-19.pdf>; 'Hinduism Case Study – Gender' (Harvard Divinity School, 2018) <https://rpl.hds.harvard.edu/sites/g/files/omnuum8216/files/rpl/files/gender_hinduism.pdf>; Rima Ghosh Patranabish, 'Trans masculinity in Indian Mythology: Misinterpreted, forgotten?' (Heinrich Böll Stiftung, 2023) <https://in.boell.org/en/2022/02/28/trans-masculinity-indian-mythology>
  5. ↑ See: V. Vasanta Mogli v. State of Telangana, Writ Petition (PIL) Nos. 44, 355 of 2018.
  6. ↑ 2014 INSC 275.
  7. ↑ Bhalla, V. (2026). SC-appointed panel urges Govt to withdraw Transgender Persons Amendment Bill. The Indian Express. https://indianexpress.com/article/india/sc-appointed-panel-urges-govt-to-withdraw-transgender-persons-amendment-bill-10602609/
  8. ↑ Sofi Ahsan. (2026). Transgender Bill may turn right to gender identity into State-dependent entitlement: Rajasthan High Court. Bar And Bench - Indian Legal News. https://www.barandbench.com/news/rights-of-transgender-persons-must-not-become-illusory-selfhood-is-a-right-rajasthan-hc-on-transgender-bill-2026
  9. ↑ Even as the court later expunged the remarks made, due to them being "added by mistake". See: Scroll Staff (2026). ‘Added by mistake’: Rajasthan HC deletes remarks  critical of transgender bill. Scroll.in. https://scroll.in/latest/1091873/added-by-mistake-rajasthan-hc-deletes-remarks-critical-of-transgender-bill adresinden erişildi.
  10. ↑ Henry, N. (2026). ‘Kept in dark about Bill, minister skipped meeting’: Why India’s top transgender advisors resigned in protest. The Indian Express. https://indianexpress.com/article/india/transgender-advisors-who-quit-council-were-kept-in-dark-about-bill-minister-skipped-meet-10605457/; Kar, S. (2026). “Only we define ourselves”: rights activists, backed by opposition MPs, demand rollback of “Regressive” Transgender Amendment bill - The Wire. The Wire. https://thewire.in/lgbtqia/only-we-define-ourselves-rights-activists-backed-by-opposition-mps-demand-rollback-of-regressive-transgender-amendment-bill; TNM Staff. (2026). Kalki Subramaniam resigns from NCTP over regressive transgender bill. The News Minute. https://www.thenewsminute.com/news/kalki-subramaniam-resigns-from-nctp-over-regressive-transgender-bill adresinden erişildi.
  11. ↑ LiveLaw (2026). Plea in Supreme Court Challenges Transgender Persons Amendment Act 2026, says omitting... Live Law. https://www.livelaw.in/top-stories/plea-in-supreme-court-challenges-transgender-persons-amendment-act-2026-says-omitting-self-identification-violates-art-21-528986
  12. ↑ See: Tia Powell and others, ‘Transgender Rights as Human Rights’ (2016) 18(11) AMA J Ethics <https://doi.org/10.1001/journalofethics.2016.18.11.pfor3-1611>
  13. ↑ George Diepenbrock, ‘Book Traces Improbable Rise of Transgender Rights Movement’ (KU News, 2018) <https://news.ku.edu/news/article/2018/11/06/book-traces-improbable-rise-transgender-rights-movement>
  14. ↑ OHCHR, ‘About LGBTI People and Human Rights’ (OHCHR) <https://www.ohchr.org/en/sexual-orientation-and-gender-identity/about-lgbti-people-and-human-rights>
  15. ↑ Council of Europe, ‘Protecting Human Rights of Transgender Persons A short guide to legal gender recognition’ (November 2015) <https://rm.coe.int/1680492119>
  16. ↑ Yachu, S. (2026). The Transgender Persons Amendment Bill, 2026, and its Discontents. Vidhi Centre for Legal Policy. https://vidhilegalpolicy.in/blog/the-transgender-persons-amendment-bill-2026-and-its-discontents/
  17. ↑ PTI, ‘“Undermine Hard-Won Rights”: UN Human Rights Expresses Concern over Amended Transgender Bill’ (Telegraph India, 2 April 2026) <https://www.telegraphindia.com/india/un-human-rights-expressed-concern-over-transgender-bill-sets-back-their-hard-won-rights/cid/2154349> accessed 8 May 2026
  18. ↑ Aashi Samith, "Fears grow over new trans law amendment’s impact on queer care networks" The News Minute (2026) <https://www.thenewsminute.com/news/fears-grow-over-new-trans-law-amendments-impact-on-queer-care-networks>; Aashna Mansata and other, “Submissions on the Transgender Persons (Protection of Rights) Amendment Bill, 2026” (Vidhi Centre for Legal Policy, March 26, 2026) <https://vidhilegalpolicy.in/research/submissions-on-the-transgender-persons-protection-of-rights-amendment-bill-2026/>; Ajitesh Singh, “Architecture of Erasure: How the Transgender Amendment Bill 2026 Erases Those It Claims to Protect” The Leaflet (March 26, 2026) <https://theleaflet.in/leaflet-reports/architecture-of-erasure-how-the-trans-amendment-bill-2026-erases-those-it-claims-to-protect>; Amnesty International, “India: Presidential Approval of Regressive Transgender Bill a Major Step Backward for Human Rights” (Amnesty International, March 31, 2026) <https://www.amnesty.org/en/latest/news/2026/03/india-presidential-approval-of-regressive-transgender-bill-a-major-step-backward-for-human-rights/>; IDR, “The Trans Amendment Bill: Everything You Need to Know | IDR” (India Development Review, May 5, 2026) <https://idronline.org/article/rights/the-trans-amendment-bill-everything-you-need-to-know/>; Jayshree Bajoria, “India’s Transgender Rights Bill a Huge Setback” Human Rights Watch (March 26, 2026) <https://www.hrw.org/news/2026/03/26/indias-transgender-rights-bill-a-huge-setback>; Mridula Chari, “The Transgender Bill Doesn’t Amend Rights, It Erases Us” (Article 14, 2026) <https://article-14.com/post/the-transgender-bill-doesn-t-amend-rights-it-erases-us--69c21fafafeaa>; Quint, “Lok Sabha Passes Transgender Persons Amendment Bill amidst Sharp Division” TheQuint (March 24, 2026) <https://www.thequint.com/news/breaking-news/lok-sabha-passes-transgender-bill-amid-division>
  19. ↑ PTI, ‘“Undermine Hard-Won Rights”: UN Human Rights Expresses Concern over Amended Transgender Bill’ (Telegraph India, 2 April 2026) <https://www.telegraphindia.com/india/un-human-rights-expressed-concern-over-transgender-bill-sets-back-their-hard-won-rights/cid/2154349> accessed 8 May 2026; Livemint, ‘UNHR Slams India’s New Transgender Law, Says It Will Erode “Hard-Won Rights”: Here’s What the Rights Body Said: Today News’ (Mint, 2 April 2026) <https://www.livemint.com/news/india/unhr-slams-indias-new-transgender-law-says-it-will-erode-hard-won-rights-heres-what-the-rights-body-said-11775135201207.html> accessed 8 May 2026;
  20. ↑ OHCHR, ‘Communication (Ref.: OL IND 7/2026) by the Mandates of the Independent Expert on Protection against Violence and Discrimination Based on Sexual Orientation and Gender Identity; the Special Rapporteur on the Rights to Freedom of Peaceful Assembly and of Association; the Special Rapporteur on the Right of Everyone to the Enjoyment of the Highest Attainable Standard of Physical and Mental Health; the Special Rapporteur on the Situation of Human Rights Defenders; the Special Rapporteur on the Independence of Judges and Lawyers; the Special Rapporteur on Contemporary Forms of Racism, Racial Discrimination, Xenophobia and Related Intolerance; the Special Rapporteur on Contemporary Forms of Slavery, Including Its Causes and Consequences and the Special Rapporteur on Trafficking in Persons, Especially Women and Children’, OHCHR (23 April, 2026) <https://spcommreports.ohchr.org/TMResultsBase/DownLoadPublicCommunicationFile?gId=30942>
  21. ↑ 'India: Transgender Bill Raises Rights Concerns' Human Rights Watch (October 28, 2020) <https://www.hrw.org/news/2019/07/23/india-transgender-bill-raises-rights-concerns>
  22. ↑ UN Human Rights Council, 'Follow-up and implementation of the Vienna Declaration and Programme of Action, Human rights, sexual orientation and gender identity' (15 June 2011 A/HRC/17/L.9/Rev.1) <https://documents.un.org/doc/undoc/ltd/g11/141/94/pdf/g1114194.pdf>
  23. ↑ UN Human Rights Council, 'Annual report of the United Nations High Commissioner for Human Rights and reports of the Office of the High Commissioner and the Secretary-General Follow-up and implementation of the Vienna Declaration and Programme of Action, Discriminatory laws and practices and acts of violence against individuals based on their sexual orientation and gender identity: Report of the United Nations High Commissioner for Human Rights' (17 November 2011) A/HRC/19/41 <https://www.ohchr.org/en/documents/thematic-reports/ahrc1941-discriminatory-laws-and-practices-and-acts-violence-against>
  24. ↑ UN Committee on Economic, Social and Cultural Rights, 'General comment No. 20: Non-discrimination in economic, social and cultural rights (art. 2, para. 2, of the International Covenant on Economic, Social and Cultural Rights)' (2 July 2009, E/C.12/GC/20) <https://www.ohchr.org/en/documents/general-comments-and-recommendations/general-comment-no-20-2009-non-discrimination>
  25. ↑ UN Committee on Economic, Social and Cultural Rights, 'General comment No. 22' (2016 E/C.12/GC/22)
  26. ↑ UN Committee on Economic, Social and Cultural Rights (CESCR), 'General comment No. 23' (2016 E/C.12/GC/23)
  27. ↑ UN Committee on the Rights of the Child, 'General comment No. 20 (2016) on the implementation of the rights of the child during adolescence'(2016 CRC/C/GC/20)
  28. ↑ UN Committee on the Elimination of Discrimination Against Women, 'General Comment 33 on access to justice' (2015 CEDAW/C/GC/33)
  29. ↑ Both the principles can be accessed here: Yogyakarna Principles, <https://yogyakartaprinciples.org/principles-en/>
  30. ↑ UN Committee against Torture, 'General Comment No. 2' (2008 CAT/C/GC/2) para. 21; See also: UN Committee against Torture, 'General Comment No.3' (2012 CAT/C/GC/3)
  31. ↑ Supreme Court of India, 'Handbook on Combating Gender Stereotypes' (2023) page 2-4 <https://cdnbbsr.s3waas.gov.in/s3ec0490f1f4972d133619a60c30f3559e/uploads/2024/01/2024012544.pdf>
  32. ↑ Ganju D and Saggurti N, 'Stigma, Violence and HIV Vulnerability among Transgender Persons in Sex Work in Maharashtra, India' (2017) 19 Culture Health & Sexuality 903 <https://pmc.ncbi.nlm.nih.gov/articles/PMC6176758/>
  33. ↑ Ministry of Social Justice and Empowerment, Report of the Expert Committee on the Issues relating to Transgender Persons (2014) <https://prsindia.org/files/bills_acts/bills_parliament/2016/Expert_Committee_Report_(2014)_1.pdf>
  34. ↑ Satya, 'LOUNGE OPINION: Why the Transgender Verdict Is an Incomplete One' Mint (April 18, 2014) <https://www.livemint.com/Leisure/Nv9Azw4bFA30CGbyCWSXUJ/LOUNGE-OPINION-Why-the-transgender-verdict-is-an-incomplete.html>
  35. ↑ Ministry of Social Justice  and Empowerment, The Transgender Persons (Protection of Rights) Bill, 2016 Forty-Third Report (2017) <https://www.scobserver.in/wp-content/uploads/2021/09/21._Standing_Committee_Report_2017.pdf>
  36. ↑ Aniruddha Dutta and Raina Roy, 'Decolonizing Transgender in India: Some Reflections' (2014) 3 Transgender Studies Q 3 <https://www.ohchr.org/sites/default/files/documents/cfi-subm/2308/subm-colonialism-sexual-orientation-oth-sarkar-input-3.pdf>
  37. ↑ Gee Imaan Semmalar, 'Gender Outlawed: The Supreme Court judgment on third gender and its implications' (Round Table India, 2016) <https://www.roundtableindia.co.in/because-we-have-a-voice-too-the-supreme-court-judgment-on-third-gender-and-its-implications/>
  38. ↑ Jane Kaushik vs Union Of India, W.P. (Civ) N.. 1405 of 2023.
  39. ↑ WP (Civ) No. 1033 of 2017.
  40. ↑ V. Venkatesan, “Beyond the Binary: Supreme Court Reclaims the Promise of Transgender Equality - Supreme Court Observer” (Supreme Court Observer, October 24, 2025) <https://www.scobserver.in/journal/beyond-the-binary-supreme-court-reclaims-the-promise-of-transgender-equality/>
  41. ↑ Verma R, “Transgender Rights in Employment after Jane Kaushik v. Union of India: A Socio-Legal Analysis of the Supreme Court’s Ruling” (OHRH, 8 January 2026) <https://ohrh.law.ox.ac.uk/transgender-rights-in-employment-after-jane-kaushik-v-union-of-india-a-socio-legal-analysis-of-the-supreme-courts-ruling/>
  42. ↑ NALSA v. Union of India, 2014 INSC 275; Law and Marginalisation Clinic, 'Handbook on the Rights of Transgender and Gender-Diverse Persons in India' Centre for Justice, Law and Society (April 2024) <https://www.dropbox.com/scl/fi/5hxiy7798ir59safmo2yf/Final-Handbook-24.04.24.pdf?rlkey=fkscxd4jv4ej6kjv3g8jzbqra&st=qh4c0d63&dl=0>
  43. ↑ Shakthi Nataraj, ‘The Thirunangai Promise: Gender as a contingent outcome of migration and economic exchange’ (2022) 19 Anti-Trafficking Rev pp. 47-65, <https://doi.org/10.14197/atr.201222194>
  44. ↑ Azeefa Fathima, 'In a first, glossary of Tamil LGBTQIA+ terms published by TN govt' The News Minute (23 August 2022( <https://www.thenewsminute.com/tamil-nadu/first-glossary-tamil-lgbtqia-terms-published-tn-govt-167129>
  45. ↑ Satya n (); Gee Ameena Suleiman, 'Non-'hijra' transgenders struggle for identity' DNA India (15 April 2015) <https://www.dnaindia.com/lifestyle/report-non-hijra-transgenders-struggle-for-identity-1588421>; Tanwi Nandini Islam, 'On Writing Transnational Trans Characters' (Literary Hub, March 20, 2019) <https://lithub.com/on-writing-transnational-trans-characters/>
  46. ↑ Alejandra Sardá–Chandiramani and Radhika Chandiramani Translingua, ‘English Translation of Argentina’s Gender Identity Law as approved by the Senate of Argentina on May 8, 2012’ (Global Action for Trans*Equality) <https://globalhealth.usc.edu/wp-content/uploads/2017/03/english-translation-of-argentina_s-gender-identity-law-as-approved-by-the-senate-of-argentina-on-may-8-2012.pdf>
  47. ↑ Cristian González Cabrera, ‘Argentina Recognizes Non-Binary Identities’ Human Rights Watch (July 22, 2021) <https://www.hrw.org/news/2021/07/22/argentina-recognizes-non-binary-identities>; Marcela Valente ‘New Law in Argentina Could Change Lives in the Transgender Community’ (World Economic Forum, June 3, 2025) <https://www.weforum.org/stories/2021/06/new-law-in-argentina-could-change-lives-in-the-transgender-community/>;  Francisco Fernández Romero, ‘Beyond Identity: Redistributive Transgender Rights in Argentina’ (ReVista, 2023) <https://revista.drclas.harvard.edu/beyond-identity-redistributive-transgender-rights-in-argentina/>
  48. ↑ Chapter 540 of the Laws of Malta, Gender Identity, Gender Expression and Sex Characteristics Act 2015 <https://legislation.mt/eli/cap/540/eng/pdf>
  49. ↑ The Data Team, ‘Malta Leads the Way for Gay and Transgender Rights in Europe’ The Economist (June 5, 2018) <https://www.economist.com/graphic-detail/2018/06/05/malta-leads-the-way-for-gay-and-transgender-rights-in-europe>
  50. ↑ Karan Tripathi v. NCRB WP(Crim) No. 9596/2020.
  51. ↑ 'Crime in India' National Crime Records Bureau <https://www.ncrb.gov.in/crime-in-india.html>
  52. ↑ 'Prison Statistics India' National Crime Records Bureau <https://www.ncrb.gov.in/prison-statistics-india.html>
  53. ↑ Commonwealth Human Rights Initiative, Lost Identity: Transgender Persons Inside Indian Prisons (2020) 35 <https://ruralindiaonline.org/en/library/resource/lost-identity-transgender-persons-inside-indian-prisons/>; Deekshitha Ganesan & Saumya Dadoo, ‘Confinememnt at the Margins: Preliminary Notes on Transgender Prisoners in India’ (2020) 13 NUJS L. Rev. 3 <https://nujslawreview.org/wp-content/uploads/2020/09/13-3-Ganesan-Dadoo-Confinement-at-the-Margins.pdf>
  54. ↑ T Chauhan and Sweety Mohanta, Gender, Law, Incarceration: Transgender Inmates' Unique Challenges in Sex-Segregated Prisons in India. In M. K. Sinha & Ashit Srivastava (Eds.), Transcending the Binary (pp. 150-170). Bloomsbury <https://www.researchgate.net/publication/390299501_Gender_Law_Incarceration_Transgender_Inmates'_Unique_Challenges_in_Sex-Segregated_Prisons_of_India>
  55. ↑ People’s Union for Civil Liberties-Karnataka (PUCL-K), 'Human Rights violations against the transgender community: A study of kothi and hijra sex workers in Bangalore, India' (September 2003) <https://www.ohchr.org/sites/default/files/lib-docs/HRBodies/UPR/Documents/Session1/IN/PLD_IND_UPR_S1_2008anx_PUCLreport.pdf>
  56. ↑ PUCL-K, 'Police Violence Against Women and Transgender Sex Workers' (2019) <https://puclkarnataka.org/wp-content/uploads/2023/04/nagmohandasreportsexwork.pdf>
  57. ↑ 1 S.C.C. 1 (2014).
  58. ↑ Dipika Jain, 'Shifting Subjects of State Legibility: Gender Minorities and the Law in India' (2017) 32(1) Berkeley J Gender, L & Just <https://doi.org/10.15779/Z388K74W73>
  59. ↑ Jayna Kothari, 'Trans Equality in India: Affirmation of the Right to Self-determination of Gender' (2020) 13 NUJS L Rev <https://nujslawreview.org/wp-content/uploads/2020/09/13-3-Kothari-Trans-Equality-in-India.pdf>
  60. ↑ Centre for Law & Policy Research, Transgender Equality: Court Decision on Transgender Rights in India (2024) <https://clpr.org.in/wp-content/uploads/2024/12/Accessible_Transgender-Rights-Resource-Book-3.pdf>
  61. ↑ Ajitesh Singh, “Supreme Court Issues Notice on Plea Challenging 2026 Transgender Amendment Act; Refers Matter to Three-Judge Bench” The Leaflet (May 4, 2026) <https://theleaflet.in/leaflet-reports/supreme-court-issues-notice-on-plea-challenging-2026-transgender-amendment-act-refers-matter-to-three-judge-bench>
  62. ↑ Swati Bidhan Baruah v. Union of India, WP(C) 51/2020.
  63. ↑ Apar Gupta, Indumugi C. and Naman Kumar, ‘The Transgender Portal was Down for weeks. IFF wrote to the government. Magically it came back up in 2 days. #DigitalDenial’ Internet Freedom Foundation (2025) <https://internetfreedom.in/the-transgender-portal-was-down-for-weeks-iff-wrote-to-the-government-magically-it-came-back-up-in-2-days-digitaldenial/>
  64. ↑ PIB, Rights of Transgender Persons in India Legal Reforms and Inclusive Progress, PIB (2025) <https://static.pib.gov.in/WriteReadData/specificdocs/documents/2025/nov/doc20251119698601.pdf>
  65. ↑ Shivashish Narayan, ‘Analysis of the SMILE (Support for Marginalized Individuals for Livelihood and Enterprise) Scheme, 2022’ (Impact and Policy Research Institute, August 24, 2024) <https://www.impriindia.com/insights/smile-marginalized-individuals-2022/>; Amruthavalli B.S. and Vedant Gupta, “The Uneven Implementation of Welfare Schemes for Transgender Persons (Part I): Access to Central Government Schemes - Centre for Law & Policy Research” (Centre for Law & Policy Research, August 5, 2025) <https://clpr.org.in/blog/the-uneven-implementation-of-welfare-schemes-for-transgender-persons-part-i-access-to-central-government-schemes/>;
  66. ↑ Specific to Garima Grehs: Eeshna Gupta , ‘Garima Grehs in Dire Straits: Transgender Communities Struggle to Survive without Government Funding’ (NewsClick, April 30, 2023) <https://www.newsclick.in/garima-grehs-dire-straits-transgender-communities-struggle-survive-without-government-funding>; Bhaswati Sengupta, ‘Garima Grehs Crippling: Government Stops Funding for Trans Shelter Homes’ (The Probe, July 28, 2023) <https://theprobe.in/stories/garima-grehs-crippling-government-stops-funding-for-trans-shelter-homes>; Nileena Suresh, ‘Garima Greh’s Struggle for Transgender Rehabilitation amid Funding Delays’ (Indiaspend, May 21, 2024) <https://www.indiaspend.com/gendercheck/garima-grehs-struggle-for-transgender-rehabilitation-amid-funding-delays-908714>
  67. ↑ UN Free & Equal, 'Transgender People' <https://www.unfe.org/sites/default/files/download/EN%20UNFE%20factsheet%20-%20Transgender%20People.pdf>
  68. ↑ Papia Raj and Ashwani Dubey, 'Comprehending Health of the Transgender Population in India Through Bibliometric Analysis' (2024) 69 Intl J Public Health <https://doi.org/10.3389/ijph.2024.1606598>
  69. ↑ Project TRANScend, 'Situation and Needs Assessment of Transgender People in Three Major Cities in India' Humsafar Trust (2018) <https://humsafar.org/site/assets/files/1637/draftreport_transcend_march2018.pdf>; Ankita Mohapatra, and Prasanta Kumar Mohapatra, 'Choosing my gender: Challenges faced by transgender persons in India' 18(1) Odisha J Psychiatry 21.
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