This form of mental aberration, which is known as Lesbian love or
Lesbianism, is practised by one woman on another and consists in friction
of the external genital organs by mutual bodily contact for the gratification
of the sexual desire. 'It is said that in some instances an unduly developed
clitoris is used as an instrument of passion, while in other cases some
artificial contrivance is employed. Aristophanes1^ mentions the use of an
artificial penis or phallus by Milesian females. This sort of sexual inversion
is found among some women, though such cases have been rarely brought
before a court of law. In a case 15 where a husband petitioned for divorce
on the ground of his wife's cruelty the Judge held that a wife's unnatural
relations with other women, coupled with neglect of her husband and home,
which so preyed upon the husband's health that it broke down3 constituted
a course of conduct which not only injured the health but gave rise to
reasonable apprehension of future injury; therefore the husband was
entitled to a decree.
Homosexual women are generally mental degenerates, and have very
often natural antipathy and indifference towards individuals of the opposite
sex. On the other hand, they are so morbidly jealous of the women with
whom they are in inverted love that they are sometimes incited to commit
This means sexual intercourse by a human being with a lower animal
and is punishable under section 377 of the Indian Penal Code. Sexual
intercourse usually takes place through the vagina, but it may take place
through the anus or any other orifice fit to receive the male genital organ.
In one case 16 sexual intercourse per nose with a bullock was regarded as
a case of bestiality within the terms of section 377, I.P.C. The lower
animals that are selected for this purpose are cows, mares, she-asses, goats,
bitches and even hens.
Cases of bestiality, though rare, do occur among young and vigorous
villagers, who go out to graze cattle in fields far away from the gaze of the
human eye. Owing to loneliness and proximity of the animals they are
excited to commit this abominable crime. Some of these men have mental
abnormalities. The crime of bestiality is also seen in some ignorant men,
who have a superstitious belief that they are cured of gonorrhoea by
committing sexual intercourse with a she-ass.
In cases of bestiality the perpetrators of the crime are caught red
handed ; medical evidence, therefore, is not required to prove the offence.
But, as false accusations by village chavMdars and others are not uncommon
in India, it is necessary that both the accused and the animal alleged to have
been used for the purpose should be examined by a medical officer. The
only important signs confirming the commissions of the crime are the
presence of human spermatozoa in the vaginal or anal canal of the animal,
and the presence of the animal hairs especially of its external genitals, on
the person or the clothing of the accused together with some suspicious
stains of the dung or blood, or abrasions on his generative organ. In
addition, there may be the marks of injuries on the person of the acctised
caused by kicks, teeth or claws of the animal. Sometimes, lacerations
14 Casper, Forensic Med^ Eng. TransL, Vol. HE, r>. 335.
15. Gardner v. Gardner (1947, AIL KR. 630); Medico-Legal Jour-, VoL XV,
1947, p. 90.
16. Khandu, (1933), 35, PXJEt 73, 35 Crim. Law Jour., 1934, p. 1096; Baferfsii
"" ' Law of Crimes, Ed. XTO, p. 917.