International Commercial Surrogacy and Child Abduction.

SUBMITTED TO

THE TAMILNADU NATIONAL LAW SCHOOL, TRICHIRAPALLI.

In Fulfilment of the Requirements for Internal Component in

Private International Law

By

Kumar Nischay

(Regd. No. BA0130080)

To:-

Mr. Mahindra Prabhu

(Faculty in charge Private International Law).

1
 Contents.
I. Introduction. .................................................................................................................................... 3
1.1. History of surrogacy and its evolution. ................................................................................... 3
1.2. What is International Commercial Surrogacy? ...................................................................... 4
II. Position in India. ............................................................................................................................. 4
III. Commercial Surrogacy, Child Abduction and Trafficking. ........................................................ 6
3.1. Human Trafficking. ................................................................................................................. 7
IV. Conclusion. ................................................................................................................................. 9
V. Refrences....................................................................................................................................... 11
Annexure I. ........................................................................................................................................... 13

2
 I. Introduction.
Due to infertility problem lot of people are unable to fulfil their desire to produce offspring.
Their growing number combined with the solution offered to them by biotechnology has
resulted in the growth of assisted reproductive technology market. The usual methods which
are involved in Assisted Reproductive Technology are (a) Artificial Insemination (b) in Vitro
fertilization (c) Surrogacy.

Artificial insemination is one of the oldest methods of assisted reproduction. It is the method
mimicking nature: a woman's ovum is fertilized by the artificial delivery of semen in her
vagina or uterus

In vitro fertilization (IVF) is the medical procedure which involves mixing semen and ova in
a test tube or petri dish. The pre embryo that may be formed is transferred to the woman's
womb or fallopian tube (ZIFT) or is frozen and stored to be implanted later.

The technique of surrogate embryo transfer (SET) which involves the removal of an embryo
from a surrogate by uterine lavage and implantation in another woman's uterus is surrogacy.
Surrogacy resembles the donation of ova, except that the egg is first fertilized in the donor's
body, usually by artificial insemination.1

Surrogacy is one of the artificial methods of reproduction. Unlike artificial insemination and
in vitro fertilization, in surrogacy there are no genetic ties with the surrogate mother. In
recent period the increase demand for alternative method of reproduction had led to
international commercial surrogacy agreement, at the same time lead to child abduction and
child trafficking due to unregulated law2.

1.1. History of surrogacy and its evolution.

Surrogacy, though just recently making headlines, is a practice that dates back in its
traditional form to biblical times.3 Traditional surrogacy occurs when the surrogate mother is
both the childs genetic and gestational mother. In more technical terms, traditional surrogacy

1
Anastasia Grammaticaki-Alexiou, Artificial Reproduction Technologies and Conflict of Laws: An Initial
Approach, 60 La. L. Rev. (2000) Available at: http://digitalcommons.law.lsu.edu/lalrev/vol60/iss4/8
2
Erica Briscoe, The Hague Convention on Protection of Children and Co- Operation in Respect of Intercountry
Adoption: Are Its Benefits Overshadowed by Its Shortcomings?, 22 J. AM. ACAD. MATRIM. LAW. 437,438
(2009), (For the most part, international adoptions were unregulated until the 1980s and 1990s when several
disturbing child trafficking stories made headlines in the international media, generating a political response.).
3
Brock A. Patton, Note, Buying a Newborn: Globalization and the Lack of Federal Regulation of Commercial
Surrogacy Contracts, 79 UMKC L. REV. 507, 509-10 (2010) (The practice of surrogacy dates back to biblical
times when infertile women gave their handmaids to their husbands in order to provide their spouses with
offspring.)

3
is where the surrogate womans own egg is fertilized with the intended fathers sperm . . . .
Gestational surrogacy, in contrast, occurs when the surrogate mother is solely the childs
gestational, and not genetic, mother. Technically, gestational surrogacy is where an embryo
is created from the gametes of the intended parents or those of donors and the fertilized
embryo is then implanted into the surrogate mother, who carries the child to term. Gestational
surrogacy became possible just within the past few decades, due to the advent of assisted
reproductive technology (ART)4

1.2. What is International Commercial Surrogacy?

It can be difficult to find a single commercial surrogacy definition, the term generally refers
to any surrogacy arrangement in which the surrogate mother is compensated for her services
beyond reimbursement of medical expenses. The alternative to commercial surrogacy is
altruistic surrogacy, in which a woman volunteers to carry a pregnancy for intended parents
without receiving any monetary compensation in return.

There are no internationally recognized surrogacy laws protecting intended parents, surrogate
mothers and children. Some countries, including France, Germany, Italy and Spain, prohibit
all forms of surrogacy, whereas others, including Australia, the United Kingdom and
Denmark, allow only altruistic surrogacy. These limitations on surrogacy prevent many
couples from pursuing this path to parenthood, and lead others to pursue commercial
surrogacy where it is allowed notably in countries like India, Thailand, Russia and
Ukraine.5

II. Position in India.

Each nation's approach to the legality of surrogacy varies, as each nation has a different view
on the ethical and moral questions surrounding surrogacy. The various national laws on
surrogacy can be broken down into four categories: Category 1 are those countries whose law
is silent on surrogacy (e.g. Belgium); Category 2 are those countries where all surrogacy
contracts, whether commercial or altruistic, are prohibited (e.g. France and Germany);
Category 3 are those countries where only altruistic surrogacy is permitted (e.g. United

4
Jessica M. Cammano, International, Commercial Gestational Surrogacy through the eyes of children born to
surrogates in Thailand : A cry for Legal Attention, Boston University Law Review, Vol. 96:571, Pg 574- 75.
5
What is Commercial surrogacy? , Last accessed 25th March 2017 available on <http://surrogate.com/intended-
parents/types-of-surrogacy/what-is-commercial-surrogacy/>

4
Kingdom); and Category 4 are those countries where all forms of surrogacy are permitted
(e.g. Ukraine and Israel).6

Until recently India fell into Category 4, where all forms of surrogacy were permitted.
However, a recent order from the Supreme Court of India ("the Order") has made commercial
surrogacy for foreign couples illegal.7 In 2008, in Baby Manji Yamada vs. Union of India and
Another8, the Supreme Court of India held that commercial surrogacy was legal. In this case
a commissioning couple contracted with a surrogate mother, but prior to the birth of the child
the commissioning couple divorced and the commissioning mother no longer wanted to move
forward with the surrogacy. When the commissioning father went to pick up the child, the
government of India did not offer the child an exit permit since she did not have a legal
mother listed on the birth certificate. The case reached the Supreme Court of India where the
court decided to honour the surrogacy contract. Following this case, commercial surrogacy
was considered legal, even though there were no uniform laws in India requiring any
prerequisites for a commercial surrogacy.

Commercial surrogacy in India is currently estimated to generate more than USD 2 billion in
revenue annually. The procedure that became legal in India in 2002 is different from other
countries which have adopted the same practice in one very critical way-India does not strive
to provide a rare solution for infertile couples, but instead seeks to maintain hegemony in an
increasingly viable industry. This booming market comes at a dangerous time because India
has no laws in place to protect the rights of the surrogate.9 The Indian government has passed
a bill to legally codify the use of ART, but this bill has neither become law nor contains
essential provisions needed to protect the rights of surrogates.10 While India may have
become one of the world's largest economies, poverty remains rampant.11 In 2010, thirty-
three percent of the population was living below the international poverty line of USD 1.25 a

6
Jargilo, Izabela (2016) "Regulating the Trade of Commercial Surrogacy in India," Journal of International
Business and Law: Vol. 15 : Iss. 2 , Article 12.
Available at: http://scholarlycommons.law.hofstra.edu/jibl/vol15/iss2/12
7
Union of India & Anr. v. Jan Balaz &Ors. (2015) SC (India)
8
Baby Manji Yamada vs. Union of India and Another , (2008) 13 SCC 518
9
Caroline Vincent and Alene D. Aftandilian, Liberation or Exploitation: Commercial Surrogacy and the Indian
Surrogate, Suffolk Transnat'l L. Rev. Vol. 36:3, Pg 671.
10
See generally MINISTRY OF HEALTH & FAMILY WELFARE, GOV'T. OF INDIA, NEW DELHI, The
Assisted Reproductive Technologies (Regulation) Bill 2010, available at
http://icmr.nic.in/guide/ART%20REGULATION%20Draft%2OBilll.pdf [hereinafter Assisted Reproductive
Technologies Bill] (creating new regulations for ART clinics).
11
Cosima Marriner, Booming Surrogacy Demand Sparks Exploitation Fears, SYDNEY MORNING HERALD,
Sept. 2, 2012, http://www.smh.com.au/national/boomingsurrogacy- demand-sparks-exploitation-fears-20120901
25742.html (identifying strength of industry).

5
day, with an average national annual income of USD 1,260 per person.12 By these simple
estimates, it is no wonder why so many come to India from across the world to pursue
surrogacy, and why so many Indian women are willing to carry another's
Baby.

III. Commercial Surrogacy, Child Abduction and Trafficking.

International commercial surrogacy presents a particular threat of child abduction. There may
be case if the surrogate mother flees to another country with the resulting child to avoid
relinquishing her rights to the intended parents then it would result in child abduction.13
Regulation of international commercial surrogacy is the necessary solution to avoid the
exploitation and child abduction that established human rights instruments have sought to
foreclose.
India has not yet joined the Hague Convention on Civil Aspects of International Child
Abduction. Lack of applicability of the Hague Convention in non-member states leaves only
a small number of options for the childs return [if abducted]14. The Hague Convention is
grounded in a best interests of the child standard. Accordingly, the Convention names
placement of the child into a family environment as the paramount goal, diverging from
past rigid preference for domestic solutions even when foreign parents were the childs best
option15.
The best interests of the child standard should be a cornerstone of any international
surrogacy regulation because, like adoption, the primary policy concern should be protecting
the most vulnerable (and often overlooked) party in the surrogacy arrangementthe resulting
surrogate child.16 It is worth noting, that these safeguards and principles apply only to

12
Stephanie M. Lee, Commercial Surrogacy Grows in India, S.F. CHRON., Oct. 20, 2012,
http://www.sfgate.com/health/article/ Commercial-surrogacy-grows-in-India-3968312.php#ixzz2Q08ghU9E
(finding price of surrogacy in United States to range from USD60,000-150,000).
13
Supra note 1, at pg 1117
14
Erica Briscoe, The Hague Convention on Protection of Children and Co- Operation in Respect of
Intercountry Adoption: Are Its Benefits Overshadowed by Its Shortcomings?, 22 J. AM. ACAD. MATRIM.
LAW. 437, 437 (2009) (For the most part, international adoptions were unregulated until the 1980s and 1990s
when several disturbing child trafficking stories made headlines in the international media, generating a political
response.).
15
([T]he Hague Convention, in keeping with the best interests of the child standard, maintains that placing
the child in a family environment is the ultimate objective, which may be better served by a foreign adoptive
family than by a domestic orphanage.). The domestic solution preference was established in the 1989
Convention on the Rights of the Child (CRC)
16
Supra note 1, at pg 1119 (In all instances, however, when the choice of the applicable law in incidental
questions or in the characterization of the issues affects the life of a child, it is preferable to allow the court to
exercise its discretion in each individual case and to adopt flexible approaches, which usually serve better the
interests of the child.)

6
signatory countries that have ratified The Hague Adoption Convention17. As such, a
weakness of the Hague Convention is potential non-violative non-compliance when either the
birth or receiving country has not ratified the Convention, and is therefore not legally bound
by its principles.18 There are 80 cases that in which an Indian parent has removed the child
from the US and brought them to India. There are also cases where parents have brought the
child to the US from India.19
Conversely, strength of the Hague Convention is its domestic enforcement mechanism. The
Convention requires that each signatory country establish a domestic Central Authority
responsible for monitoring adoption and compliance with the Convention in that specific
country.20
This would provide the necessary, and essentially non-existent, hands-on enforcement of
national regulations on surrogacy in those countries with booming commercial surrogacy
industries. Beyond this, however, the Convention neither establishes general consequences
for provision violations nor a general enforcement agency for punishment of non-compliant
member countries.21 This is because Hague Conventions efforts are still in their infancy,
scholars have proposed that an international convention be modeled after the [Hague
Adoption Convention].). The Hague Conference on International Private Law began
considering internal regulation of international surrogacy under standards similar to
international adoption in 2011, but chose to defer any decisions.

3.1. Human Trafficking.

The Indian government has passed a bill to legally codify the use of Assisted Reproductive
Technology ART. Indian Ministry of Home Affairs issued new guidelines on surrogacy in
January 2013. These included a visa requirement for foreign nationals commissioning
surrogacy in India, with such visas being restricted to married couples from countries where
surrogacy is legal.

17
Supra note 14, at pg 440
18
Ibid.
19
Mayura Janwalkar, In India, 80 abduction case in which parent took the child to India, says Susan S. Jacobs,
available at < Indianexpress.com/article/india/india-news-india/surrogacy-us-abduction-cases-parents-took-
child-to-india-ban-commercial-susan-s-jacobs-3033434/>, last accessed 27th March 2017.
20
Supra note 14, at pg 442 (Through the Central Authority, parties are held accountable for their actions which
effectually could reduce the risk of bribery and baby selling in intercountry adoptions.)
21
Ibid, at pg 448- 449, (However this does not create any uniformity in the way compliance is enforced. The
Hague Convention needs to establish a technique to assess whether procedures of the Central Authority of each
country are consistent with the treatys safeguarding objective.).

7
N B Sarojini, founder of the non-profit making Delhi based womens health advocacy and
research organisation Sama, thinks that these regulations have done little to curb what the
Indian press has derisively referred to as the trade in Indian wombs for hire. Sarojini, who
has lobbied for amendments to the ART bill, hopes that the new legislation will check the
untrammelled commercialisation of Indias assisted reproduction industry but fears that the
bill will be hugely lacking in its reach.22

Anil Malhotra, a lawyer based in the north Indian city Chandigarh, raised concerns that the
bill fails to consider the background and credentials of commissioning parents, a problem that
emerged in the baby Gammy case.23 Malhotra pointed on the absence of a clause pertaining
to human trafficking for surrogacy. In 2009 the United Nations Development Programme
warned that trafficking of women for commercial surrogacy would eventually develop. Just
two years later, Vietnamese women, seven of whom were pregnant, were rescued from a
surrogate baby breeding ring in Bangkok.

Malhotra further stated, You cannot just close your eyes and hope that baby breeding cartels
wont develop with such financial incentives involved, its a false hope.

In 2014, a police raid revealed a baby factory flat, in which a twenty-year old pregnant
woman and nine babies between the ages of one month and two years old were found.24
Further investigation showed that Mitsutoki Shigeta, a very wealthy twenty-four-year-old
Japanese businessman, used Thai surrogates to father at least fifteen children. While his
primary motive could not be definitively ascertained, his reasoning included wanting a big
family and having more than 20 babies to take care of his many family businesses.
Agencies told Shigetas Thai surrogates they were helping an infertile couple, and many
surrogates expressed grave concern upon discovering the truth. Following the government
shutdown spurred by these two scandals, Shigeta fled Thailand, ultimately abandoning nine
of his babies to be cared for by nannies. Shigeta is named as the father of each of these babies
on their birth certificates, and must appear before Thai family court to obtain parentalvrights
over each of the children.

22
Sama - Resource Group for Women and Health, Taming the international commercial surrogacy industry,
available on < http://www.samawomenshealth.org/blog-entry/taming-international-commercial-surrogacy-
industry> last visited on 27 March 2017.
23
Ibid. See also, 60 Minutes: Baby Gammy (CBS News television broadcast Aug. 10, 2014),
https://www.youtube.com/watch?v=fv_sQouMcpk [https://perma.cc/G46Y-AYD5] (quoting David Farnell,
Gammys intended father)
24
Surrogate Dad Faces Trafficking Probe: Japanese Suspect Flees, DNA Tests Under Way, BANGKOK POST
(Aug. 9, 2014) http://www.bangkokpost.com/print/425774/ [https://perma.cc/4XH3-DXKM]

8
 IV. Conclusion.
Surrogacy in itself is not a bad idea. It helps the couples who cannot have babies due to some
medical problem. If any nation is providing this facility at cheap cost it is well and good.
What is wrong about surrogacy is that it is not regulated by any proper set of rules or codified
legislation. There are no proper codified set of laws both in India and Thailand, which are
commonly known as the Womb of Asia, neither either of them are the member of the
Hague Convention, which render the child or the mother helpless in case of any conflict.

As stated earlier the practice of surrogacy should not be banned, as banning surrogacy may
lead to illegal practice of surrogacy. If surrogacy will be banned People will carry it out
illegally and out of sight and may resort to human trafficking or kidnapping to get children
out of the country. Banning of surrogacy is not only the necessary solution for dealing issues
related with surrogacy. The law relating to surrogacy should be regulated. Banning in itself is
not a solution.

A typical illustration for the above sated paragraph is Baby Gammys case where an
Australian couple left Gammy a seven month old boy that was born by a Thai surrogate.
Gammys intended parents were David and Wendy Farnell, a couple who used a Bangkok-
based agency to match them with their international commercial surrogate, Pattaramon
Chanbua. The timeline is relatively straightforward: the couple found out early in the
pregnancy that Chanbua was pregnant with twins; at four months the couple found out that
one of the twins had Down syndrome; and at seven months the agency requested that
Chanbua abort the twin with Down syndrome. Despite the agencys request, Chanbua refused
to have an abortion. Chanbua delivered the twins, one male and one female, two months
premature, requiring an additional month of observation at a Thai hospital. The male twin,
Gammy, was born with congenital heart and lung defects in addition to the predetermined
Down syndrome. David and Wendy Farnell ultimately returned home to Australia with only
the female twin, leaving Gammy in Thailand.25

Following the recent Baby Gammy scandal, however, the Thai National Council for Peace
and Order (NCPO) approved the first reading of the ARTs Bill in August 2014. The ARTs
Bill finally took full legal effect as of July 30, 2015. The stated purpose underlying the
enactment of the Bill is summarized in its title: protecting children born via assisted
reproductive technology. When asked to elaborate on the Bills stated purpose, the Social

25
Supra note 4, at pg 595

9
Development and Human Security Minister claimed that the Bill is aimed at protecting
surrogate babies and suppressing human trafficking. The Minister further identified
preventing abuse of newly improved ART procedures and specifying the legal status of the
intended parents as some of the primary measures through which the drafters sought to
accomplish the goal of protecting the surrogate children. The ARTs Bill contains numerous
restrictive limitations on access to surrogacy in Thailand to prevent abuse of the once-lax
surrogacy industry. First and foremost, Section 23 of the ARTs Bill prohibits commercial
surrogacy outright, in any capacity. Sections 25 and 26 explicitly prohibit the existence and
usage of agencies or brokers in surrogacy agreements, as well as advertisements soliciting
surrogate mothers willingness to serve interested intended parents, respectively.

Further, Section 21 establishes specific criteria for intended parents and surrogate mothers.
Intended parents must be lawfully wed husband and wife unable to beget children otherwise,
who are mentally and physically prepared to be parents to the resulting child. The Bill
specifically denies surrogacy services to same sex couples and to single individuals, as can
be inferred from the reference to terms like lawful spouse being explained as lawful
husband and wife throughout the ARTs Bill. Further, surrogate mothers can be neither the
biological mother nor daughter of either of the intended parents. Surrogates must have also
already birthed children in the past, and, if she is married, the surrogate mothers husband
must consent to her involvement in surrogacy26.

Thus it is very certain that banning surrogacy is not the solution as it would result in illegal
practice. The only solution is the law relating to surrogacy needs to be regulated.

26
Ibid, at pg 598-599

10
 V. Refrences.
Articles :

1. Anastasia Grammaticaki-Alexiou, Artificial Reproduction Technologies and Conflict

of Laws: An Initial Approach, 60 La. L. Rev. (2000).
2. Erica Briscoe, The Hague Convention on Protection of Children and Co- Operation
in Respect of Intercountry Adoption: Are Its Benefits Overshadowed by Its
Shortcomings?, 22 J. AM. ACAD. MATRIM. LAW. 437,438 (2009).
3. Brock A. Patton, Note, Buying a Newborn: Globalization and the Lack of Federal
Regulation of Commercial Surrogacy Contracts, 79 UMKC L. REV. 507, 509-10
(2010).
4. Jessica M. Cammano, International, Commercial Gestational Surrogacy through the
eyes of children born to surrogates in Thailand : A cry for Legal Attention, Boston
University Law Review, Vol. 96:571.\
5. Jargilo, Izabela (2016) "Regulating the Trade of Commercial Surrogacy in India,"
Journal of International Business and Law: Vol. 15 : Iss. 2 , Article 12.
6. Caroline Vincent and Alene D. Aftandilian, Liberation or Exploitation: Commercial
Surrogacy and the Indian Surrogate, Suffolk Transnat'l L. Rev. Vol. 36:3.

Web Resources:-

1. Surrogate Dad Faces Trafficking Probe: Japanese Suspect Flees, DNA Tests Under
Way, BANGKOK POST (Aug. 9, 2014) http://www.bangkokpost.com/print/425774/
[https://perma.cc/4XH3-DXKM]
2. 60 Minutes: Baby Gammy (CBS News television broadcast Aug. 10, 2014),
https://www.youtube.com/watch?v=fv_sQouMcpk [https://perma.cc/G46Y-AYD5]
(quoting David Farnell, Gammys intended father)
3. Sama - Resource Group for Women and Health, Taming the international commercial
surrogacy industry, available on < http://www.samawomenshealth.org/blog-entry/taming-
international-commercial-surrogacy-industry> last visited on 27 March 2017.
4. Mayura Janwalkar, In India, 80 abduction case in which parent took the child to India, says
Susan S. Jacobs, available at < Indianexpress.com/article/india/india-news-india/surrogacy-
us-abduction-cases-parents-took-child-to-india-ban-commercial-susan-s-jacobs-3033434/>

5. Stephanie M. Lee, Commercial Surrogacy Grows in India, S.F. CHRON., Oct. 20,
2012, http://www.sfgate.com/health/article/ Commercial-surrogacy-grows-in-India-

11
 3968312.php#ixzz2Q08ghU9E (finding price of surrogacy in United States to range
from USD60,000-150,000).
6. MINISTRY OF HEALTH & FAMILY WELFARE, GOV'T. OF INDIA, NEW
DELHI, The Assisted Reproductive Technologies (Regulation) Bill 2010, available at
http://icmr.nic.in/guide/ART%20REGULATION%20Draft%2OBilll.pdf [hereinafter
Assisted Reproductive Technologies Bill] (creating new regulations for ART clinics).

12
 Annexure I.
International Commercial Surrogacy and Child Abduction.

Kumar Nischay

BA0130080.

Abstract:-

Regulation of international commercial surrogacy is necessary solution to avoid the

exploitation and child abduction that established human rights instruments have sought to
foreclose. Commercial surrogacy need not to be prohibited but the laws related to surrogacy
are needed to be regulated; the same has been established by Hague Convention to regulate
international adoption.

India has still not joined Hague Convention on the Civil Aspects of International Child
Abduction. As per Susan S Jacobs (Special adviser on childrens issues, US Department of
State) there are 80 cases in which an Indian parent has removed the child from the US and
brought them to India. There are also cases where parents have brought the child to the US
from India. Ninety-four countries are party to this convention and there are procedural rules
that apply to the cases including a time-line and how they should be handled. It gives people
faith in a legal system.

This project will discuss about the legal and commercial issues which are involved with
commercial surrogacy. Inconsistency in laws will create an increased potential exploitation of
parties involved in surrogacy agreements. The validity of contracts varies between states and
certain countries that allow surrogacy do not adequately protect the surrogate mothers.

The Hague Convention serves to protect adopted children who are similarly situated in
context and interest to the resulting children of surrogacy, providing support for a similar
regulatory approach. International surrogacy presents a particular threat of child abduction
because if the surrogate mother flee to another country with the resulting child then the child
would become stateless and would be devoid of his rights.

Keywords: - Commercial Surrogacy, Abduction.

13
Research Objective:

The prime aim of this project is to analyse the drawbacks which are there in commercial
surrogacy. The researcher intended to focus on child abduction and child trafficking which
could result through international commercial surrogacy. Through this project the researcher
also aims to flash the loopholes and the grey areas which are there in laws relating to
commercial surrogacy.

Research Question:

1. Whether India should join the Hague Convention?

2. Whether the laws relating to surrogacy needs to be regulated?

Chapterization:

1. Introduction.
2. Position in India.
3. Commercial surrogacy, Child abduction and Trafficking.
4. Conclusion.

Articles referred:

1. Mark Henaghan and Ruth Ballantyne, "International Child Abduction, Intercountry

Adoption and International Commercial Surrogacy.
2. Cara Luckey, Commercial Surrogacy: Is Regulation Necessary to Manage the
Industry?
3. Anastasia Grammaticaki-Alexiou, Artificial Reproduction Technologies and
Conflict of Laws: An Initial Approach.
4. In India, 80 abduction case in which parent took the child to India, says Susan S.
Jacobs, Written by MAYURA JANWALKAR.

14