Scrutiny and control of women's sexuality and women's reproductive role by the state are well recognized in the history of societies [Sarkar 1993]. Tribal wars over possession of women were rooted in the struggle for survival of the tribe itself.

Legal reforms have been at the centre of the agenda for strategizing gender justice in India. This has been so, right from the time of nine-teenth century social reforms movements, through the period of nationalist struggles, down to the contemporary women's movement.