RATE OF FEMALE CRIMINALITY CAN BE REDUCED BY INCREASING THE RATE OF EDUCATION

Female criminality has always been a subjectwhich is generally not discussed because of less number of women indulge in crimes but recent years told us the story in other way. They are still not at par with men but that does not mean they need not to be focused upon. A girl child in a country like India consider as parayadhan grows up in the protection of her father and brothers then to her husbands after marriage. Many times she becomes victim because of broken families, physical or mental assault which turns her into a victim and then to a criminal the quick example of which is of Phoolan Devi. We may trace the presence of women in heinous crimes as well though it is a very small in number but on reciting their facts cried out not to be ignored like in Shabnamcase who could be the first woman to be hanged after the independence of India. In the following research in the light of various theories and reasons of female criminality we have tried to establish that the rate of female criminality can be reduce by increasing the rate of female literacy. Education not only helps in reducing the number of crimes but also helps to reform and rehabilitate female offenders after their release.

Female criminality has always been a subjectwhich is generally not discussed because of less number of women indulge in crimes but recent years told us the story in other way. They are still not at par with men but that does not mean they need not to be focused upon. A girl child in a country like India consider as "parayadhan" grows up in the protection of her father and brothers then to her husband"s after marriage. Many times she becomes victim because of broken families, physical or mental assault which turns her into a victim and then to a criminal the quick example of which is of Phoolan Devi. We may trace the presence of women in heinous crimes as well though it is a very small in number but on reciting their facts cried out not to be ignored like in Shabnamcase who could be the first woman to be hanged after the independence of India. In the following research in the light of various theories and reasons of female criminality we have tried to establish that the rate of female criminality can be reduce by increasing the rate of female literacy. Education not only helps in reducing the number of crimes but also helps to reform and rehabilitate female offenders after their release.

…………………………………………………………………………………………………….... Introduction:-
Human civilization cannot be treated in isolation with crime. We can hardly dissociate both these terms. One cannot imagine a society which is devoid of any crime. It is a dynamic concept which varies from society to society. We are living in era where cyber-crimes and white collar crimes have replaced some traditional styles of crime commission. With the changes like modernisation, urbanisation and industrialization, crime has also changed its forms and shapes. Another aspect of crime varies when we talk about gender. Although our criminal justice system does not discriminate on the basis of gender but when it comes to female criminals it has different dimensions like many theories claims that reasons for female criminality are different than male. Earlier the presence of women in crimes were negligible but with due course of time, their presence has been increased. They have been a topic for many researchers now. There are sociological and psychological reasons behind their commission of crime. Particularly talking about India which is a country where society is primarily a patriarchal one and women are considered to be in need of protection of her father, brother or husband. It has always been considered that her happiness is nothing but the happiness of her family. She needs to make best possible sacrifices for her family"s growth and prosperity. And many times these sacrifices include of education where a girl child needs to give up her education only because her family cannot pay for her education or may be when she just needs to sit back at home and do household chores.

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She is considered as "Laxmi" and "Annapurna" for her family. That is why when there was an increase in the rate of female criminals; it drew attention of society and many researchers of this unattended topic. Female criminality is more complex to understand. During the research, we have tried to understand its reasons and to draw a hypothesis that education is the key by which female criminality may be reduced. It is equally important to understand the ways by which they can be reformed and rehabilitate after their release.

Female: a criminal or a victim
Considering a woman as a criminal is still like an alien concept in our society. It is because our society is primarily a patriarchal society and women are considered as a subordinate to men she needs to be in care of her father, brother, husband and children. Her prosperity lies in the happiness of her family. Indian culture is set up in a manner that a woman"s role is considered primarily confined to home serving her family.
However, it is small in number, it is equally important to closely assess the female offenders. Long term involvement in crime is extremely rare with the female offenders. In recent years the female criminality has grabbed the attention of scholars and researchers because of increase in participation of crime by women. These criminals were usually given importance while studying the prostitution or when there was a need to analyse the depravity of violent women. It is believed that since normal women are passive, the women who commit crimes must be sick. A female criminal is considered as "out of place" in criminal justice system where "presence of men is considered as "normal" discourse. A woman falling into a criminal activity first needs to be looked as a "victim". In fact, there is a link between gender abuse and women"s involvement in illegal activity and women being marginalised in society are vulnerable to both problems. She is a victim of domestic violence, physical assault, rape and abusive relationships. According to study at Bedford Hills Correctional facility in New Yorkstate, many incarcerated women were victims of serious previous domestic and sexual violence. Further study after ten years revealed that more than 80% of incarcerated women in same facility had higher rate of traumatic past abuse. Female criminals are usually victims of unmet social, educational, medical and economic needs.
They are not considered as "career criminals" because they are more involved in petty offences but it needs to be understand that problem of female criminality is more complex. Generally it has been understood that because of small number of female criminals the need to understand their criminal behaviour is not much.
Gender is fundamental but largely ignored issue in criminal justice system because female offenders are different than men with different pathways to crime, different life circumstances and different habilitative or rehabilitative needs. There is a need to focus on women"s ability to reason and reflect on their circumstances rather than viewing them as conditioned and self-conscious objects.
Crime and gender are related deeply even in criminal justice system while dealing with different kinds of crimes. Criminal justice policies have a major effect by the idea that primarily crimes are committed by males but this effect is different from time to time and society to society, with the changing expectations and gender roles. Society"s expectations depend upon the culture and traditions than the law because law does not differentiate between men and women and instead of defending gendered circumstances, factors which derive the women to commit crimes must be taken into consideration. Female offenders are treated more leniently by the courts while sentencing. This is may be because the system is too "chivalrous" with females may be because they are more in need of protection as their mental requirements are different than men. Also, the system propagates a stereotype image of Indian women they are treated less dangerous than men. It is believed that women are generally ready to make sacrifices for their families and they are the prime caretaker of a home. Therefore, judicial discrimination could be beneficial to a society as a whole it should not lead to a discrimination which may create rifts into the society.

Some theories
There are various theories propounded time to time which helped in understanding the crimes and its reasons for commission.
In 1876, Cesare Lombroso introduced his biological theory in his book "The Criminal mind", where he observed the physical characteristics of Italian prisoners and compared them to Italian soldiers from which he claimed that criminal constitute a distinct "born" type. They have certain physical abnormalities. Later, Lombroso and Ferrero wrote a book called "The Female Offender", where they examined the skeleton of female offenders and the bodies of living female prisoners. They concluded that the number and types of physical abnormalities in female offenders 807 indicated the extent to which women were predisposed to criminal acts. They even attempted to determine which particular acts women were likely to commit. They described these offenders as "born criminals" tended to display greater criminal propensities and perversities from the psychological and behavioural standpoint than the male born male criminal type. According to Lombroso, a woman criminal is a monster who surpasses man when she wants to be wicked, cruel or diabolical. As a criminal she is an exception among criminals and her perversity knows no bounds.
Masculinity theory by Freda Alder suggests that female criminality is mainly dependent on the masculinity behaviour of females. The empowered women are involved in more serious crimes than non-empowered women due to masculinity. Although this view cannot be taken as appropriate in every situation because empowerment of women cannot be ignored on this view point. It is the basic human right of every girl /women to be empowered. Women Empowerment means developing a sense of self-worth, a belief in one"s ability to secure desired changes and the right to control one"s life.
Opportunity theory makes no difference between morality of male and female. The theory states that biological characteristics are not relevant for the commission of crime. The theory explains that with the increase in female opportunity, efficiency and social communication, the rate of female criminals also increases accordingly. "Some women take advantages of these opportunities just as men do before." Although increasing opportunities of women reduces the rate of violent female criminality but increases the rate of offences like theft, embezzlement, fraud and forgery Opportunity theory by Rita J. Simon proposed that increasing different opportunities to women increases criminal activities as well. This theory believes that this phenomenon reduced the rate of violent female offending but increased the rate property crimes.
The Marginalization theory states that marginality like low salary, inadequate job, lower class position and family victimization of a woman penetrates criminality in contemporary societies. Victimization instigates them to commit crimes. They have the responsibility of taking care of household. Many women opt for drug smuggling as it is an occupation which does not need any specialized training. Most of these women come from neighbourhood that are rooted in poverty and do not have possible social support.

Chivalry or paternalism theory by Thomas and Otto
Pollack suggests that lower rates of female criminality exist because of the more lenient treatment of female offenders by criminal justice personnel. Men commit certain crime with the instigation of women.
Social Bond theory by Ram Ahuja has put an explanation from an Indian perspective. This perspective is primarily concerned with the pattern of family relationships within the family and outside the family either nuclear family or joint or by kinship groups or neighbourhood and peer groups. These "family-centred explanation" or "pressure of primary relations perspective" produces a desire or a need to deviate from social and/or legal norms. The personality structure or characteristics like frustrations, deprivations or dominant underlying need prevent this deviation I some women, but failed to do so in other cases. Thus, both personality system and pressures of environment in which a woman works contribute to female criminality. This theoretical model focuses on "strength of character", "role conflict", "opportunity" and "totality of situation" in family.
This theory is presented on the basis of interaction of a woman with her family members. It has tried to explain the etiology of female crime in terms of "maladjustment" in interpersonal relationships with in the family.
On the other hand strain theory by Cohen states that women are subjected to less pressure compared to men that is why they do not commit the full range of offences. Boys have various ambitions while girls have ambitions focussed on men and procuring a husband. Men are achievers and doers whereas women are inactive and unambitious helpmates because of lack of pressure from society to achieve the same goals as men, women do not deviate in the same way a man does.
Strain theory by Agnew and Broidy believe that the gap between men and women criminality is due to men being subjected to more and different strains than women and therefore men are more likely to find the strain as more stressful.

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According to the Strain theory by Simon and Nath, men were more likely to report positive or neutral emotions. Women not only are most likely to feel anger but their anger is "more intense and of longer duration than men"s".
Labeling theory by Morris, believe that deviant women are more likely to be labeled as "mentally ill" where their male counterparts are labeled as "criminal".
Double standard theory suggests that women use their physical charm to attract the victim. Frustration, envy, false accusation also create female criminality.

Reasons behind female criminality
The early 1900s marked important economic a social shifts that were particularly dramatic for women. Participation in labour market increased with that young working women"s interaction with men also increased which increased their sexual desires with contrast to middle class values. Many reformation campaigns were launched to curb immoral behaviour and preserve women"s purity. The goal was to install in working middle class woman that the marriage is the only proper venue under which sexual behaviour could be legitimately fulfilled and motherhood as its prime goal. In the early 1920s, marriage was centre to women"s identity and motherhood as a virtual mandate. Thus, Female criminality is also a result of socio-economic cultural changes, industrialization, westernization and urbanization.
Another aspect of female criminals is related with migration. The term "crimmigration" generally refers to the intersection of criminal law and immigration, which leads to the increasing enforcement and punishment of immigrants in the criminal justice system. Migrants are often from weaker social and economic backgrounds. Female migrants have to survive through activities like seasonal labour, temporary work, domestic help, help from friends or neighbours and sometimes theft, fraud or prostitution.
There are various reasons for commission of crimes by women; some of them are as follows: 1. Economic causes: economic hardships and poor economic conditions is the basic cause of female criminality.
Economic insecurity results in shop-lifting, fraud, theft of services and welfare frauds. Most of the offenders are from lowest economic strata of society. 2. Social causes: despite of constitutional safeguards, Indian women are subjected to inequalities and social oppression affecting her financial dependence. Strained relations in family, extra family relations, ill-treatment by husband, denial of basic needs, maladjustment in marital conflicts, unemployment, child care expenses, broken homes, torture and sexual abuse and dowry deaths of women are some factors which may lead a woman towards the crime. 3. Illiteracy and low education: in India, a large population of women is illiterate or they do not have minimum educational opportunities. There is a clear relation between illiteracy and crime. 4. Psychological cause: many female criminals have signs of emotional instability and frustration. Stress level in women is higher than men although it can be said that they are psychologically stronger than men but they are more likely to explode with extreme uncontrolled violence. They are also more suspicious than men which may become a factor of the commission of crime. 5. Cultural cause: the education received by women is more repressive than received by men. One of the most determinative factors for women creating their own subcultures with regard to female criminality in the family.

Need for education
According to the data of National Crime Records Bureau, Crime in India 2016 statistics, the percentage of apprehended juveniles was the highest among those who could not completed their matric or higher secondary while it was lowest for those who have completed their matric or were above higher secondary. Similar trend was observed in 2017, 2018 and 2019 as well.
While talking about social causes, the maximum number of apprehended juveniles was from those who were living with their parents.
In the study conducted by Ms.Madhurima, it was found that more educated women were involved in violent crimes but with other crimes, as the educational status improved, the number of crimes also decreased. Majority of female were illiterate and were from marginalized sections of society. There was a lack of awareness about law and criminal activity among women resulted in offensive behaviour. The involvement of educated women were more in 809 one to one personal relationships which were violent in nature, whereas, illiterate women were involved more in property and drug-related offences. Majority of women did not have any clue where their offensive act would lead them to.
In another study by Ms.Smriti A. Bhosle, illiterate and primary school education of females inmates constituted 71.1% of the total sample. The author affirmed the illiteracy and low level of education always dominates the crime scenario however, she did not deny the presence of educated women in crimes which usually may be white collar crimes and may be they escape the eyes of police and the law.
In yet another study of Uttar Pradesh jails by National Commission for women of India, it was observed that women committed crimes due to poverty. They are vulnerable to being detained because of their inability to pay fines for petty offences. These women offenders are typically middle age young unemployed have low level of education and have dependent children. In its data, it was observed that 66.55% of women inmates were illiterate. 15.39% were educated till 5 th to 8 th class. 7.61% were educated till 10 th class. 4.95% were educated till 12 th class and 5.48% were educated above 12 th class. It was also observed that in most of the jails there was neither educational programme nor any proper and appropriate vocational training for women.
In 2011, literacy rate in India was 74.04%, the percentage of male was 82.14 and females were with 65.46, the gap of the gap of literacy rate between male and female was 16 Thus, we can see an increase in female literacy but still the percentage of female literacy needs to be improved. Education is important in one"s life because it install basic social and life skills in a person"s life. Recognition of education as a basic human right by UDHR benefitted many children to get their primary education. And when it comes to women, education helps them to get atleast a minimum level of protection which support her overall development. Education is an important step by which a society provides equal social and economic opportunities and the least-developed members of society gets the benefits. It is important to deal all members of society equally so that the basic structure of society establishes itself with fairness. This idea should not remain merely an idea but needs an action. This is one of the ways by which a level of protection can be installed in a girl or woman. By education means knowledge will be a part and parcel of life which in return gives many opportunities in life. It has the capability to enlighten not only the receiver but also the person who spreads it.
Apart from food, shelter and basic medical care, education is a "welfare right", which is also a means to other welfare rights. Education let the maximum use of an individual"s skills and talents in all dimensions whether physical, intellectual and social.
Education decreases woman"s poverty and brings more employment opportunities. It prevents early marriages and improves their health.
As rightly pointed by Dr.Vibha Gupta, "Education is truly the key to empower women and also provide for all round economic growth of countries. First and foremost education will help women with increased job opportunities, thus increasing their disposable income. Educated mothers can provide their children with an opportunity to have healthier lifestyle. Education helps an individual escape from poverty through development of skills that they need to improve their livelihood." Thus, education of women is the most powerful tool which may bring reduction in inequalities and a means by which status of women may be improved within the family and society.
After going through various theories and causes behind crimes committed by women it is quite important to look into the measures which can as preventive as well as corrective measures for these women.
As Preventive measures-in a country like India with huge population is a tough task and when it comes to female criminality it becomes even more difficult. It may be achieved by providing general awareness about their rights along with legal awareness about illegal activities and to keep themselves away from such activities. And as Corrective measures-female criminals should be given opportunities to rectify themselves so that after their release 810 they should be free from any criminal attribute. They must have enough support to be independent and to support herself and her children and her family. In prisons, they are provided training and activities like cooking, tailoring, paintings, handicrafts, card making, jewellery making etc. which can be called a step for a corrective measure. Public must be aware and not be taunted by everyone which might result in their indulging in other harsher crimes.
By a close look into the subject matter in particularly the reasons we may find that all aspect may be somewhere closely linked with the lack of education and even opportunities provided to girls in our country. Causes specially the economic and sociological are nothing but can easily minimise the rate of criminality among women. Education is the most powerful tool for every human being especially for girls which not only empower them but make them to lead a normal, happy and successful life. They can achieve whatever they want to.

Conclusion:-
Ignoring rate of crime just because they are less in number or may be because they are not much heinous does not going to solve the female criminality instead we should focus more the reasons because of which females are driven towards the commission of crimes. In a country like India where a large population is living under the poverty, illiteracy, unemployment, issues of frustration, anger and mental stress becomes common. Sometimes it may happen that crime committed does not look a heinous one but its repercussions may result into broken houses. It may also result into rupture of reputation, long legal battles which are ultimately loss of time and money and stress. As in a recent research conducted by Dr.SoumiChatterjee in her work, "Dowry Laws and its misuse", there are many instances where females were misusing the laws of dowry which are made for their protection. This is nothing but crime may be not of a serious in nature but it may result into deep mental cruelty to other party along with the family. There are instances where the husband commits suicide due to embarrassment he suffered because of false case or accusations. A criminal is not a born criminal. He or she can be corrected by the taking some corrective and preventive methods. Education is the best medium to decrease the crime rate by women, it also important that along with formal education one must also be educated about being honest in her or his life. Everyone must understand to apply their minds intellectually instead in the direction of being a criminal. Success has no shortcuts. We must learn to balance our lives with the modernization and globalisation. One must go through the hard work which may pay less than expected but atleast it will not result into being in prison or broken families. We understand that education cannot totally eradicate the crime from society but it helps in reducing some of its reasons like poverty, unemployment, gaining social status, healthy environment. Moral Counselling which makes one to differentiate between right and wrong may be included in higher studies in formal education which may help to our subconscious mind to understand what is right and what is wrong. Although we cannot deny the commission of crime in exceptional situations like of extreme hunger for that we as a society needs to be more sensitive towards our surroundings. We must contribute a little so that no one remains hungry like we recently witnessed our solidarity in pandemic of Covid 19. Thus, it may concluded that everyone needs to understand the importance of education not only in civilised and formal manner to reduce the rate of crimes specially for women but even for prison inmates it is equally important for their rehabilitation and reformation and as a society we must not take them as a taboo instead we can help them to bring back to a normal life which is deviated from any kind of crime. Education brings women empowerment which brings a positive attitudinal change which increases their say in family, job premises, society and in the country as well. We would like to agree with the marginalization theory that it rightly pointed out the reasons behind the commission of crimes by women. In our contemporary society, this theory seems to be fit. Through education, the margins like unemployment, low salaries, economic and social disparities can easily be reduced. Educated women will have sufficient means and sources to run their families in a decent manner. Also, it will help in rising of women in an environment which will be free from any criminal mind set.