From Stigma to Sovereignty: Assessing the Impact of Sukanya Shantha (2024) on the Dignity of Bedia Women in Madhya Pradesh

The Criminal Tribes Act of 1871 has had a lasting impact on the history of the Bedia Trib of Madhya Pradesh. The label of “Criminality” endured despite the tribe’s official de-notification in 1952 due to systematic administrative bias and biased enforcement, resulting in an ongoing state of monitoring. Under the Immoral Traffic (Prevention) Act, traditional and cultural manifestation like the Rai Dance is often confused with commercial sexual exploitation, creating a unique intersection of vulnerabilities for Bedia Women. This socio-legal marginalization is acutely gendered. The historic Supreme Court judgement in Sukanya Shantha v. Union of India, which invalidated caste-based discriminatory clauses in prison manuals and denounced the “habitual offender” stereotype frequently applied to Denotified Tribes (DNTs), is examined in this paper for its revolutionary potential. This study will examine how the Constitutional Morality and the Right to Dignity as guaranteed under Art. 21 of Indian Constitution in Sukanya Shantha can be used to combat the extrajudicial stigmatization of Bedia Women using a socio-legal methodology. The report contends that the ruling gives Madhya Pradesh’s state police manuals and administrative structures, which still enable arbitrary detention and social discrimination, the requisite judicial mandate to audit them. The study also examines the transition from “protectionist” state interventions to a “sovereignty-based” strategy, arguing that Bedia women should be seen as holders of substantive rights rather than as targets of official surveillance. In order to ensure that the promise of article 14, 15, and 17 reaches the most unseen edges of the Indian Tribal Terran, the research will conclude with a plea for legislative reform that harmonizes local governance with the Supreme Court’s vision of an egalitarian social order.