OVERVIEW: This manuscript compares how India, the United Kingdom, Canada, and Australia define sexual consent and shows how those differences shape legal clarity, judicial outcomes, and public understanding. It argues that more explicit, autonomy-based definitions tend to support more consistent enforcement and a clearer understanding of rights and responsibilities. SUMMARY:Legal definitions of sexual consent play a central role in shaping judicial outcomes and broader social understandings of autonomy. However, these definitions are not uniform across jurisdictions and differ in scope, language, and application. This paper examines the legal frameworks governing consent in India, the United Kingdom, Canada, and Australia. Indian law provides a formal definition of consent, but its application remains uneven because of overlapping statutory provisions, age-based restrictions, and exceptions within marital contexts (Indian Penal Code, 1860; Protection of Children from Sexual Offences Act, 2012). By contrast, the United Kingdom, Canada, and Australia adopt clearer, more autonomy-focused approaches that emphasise voluntary and informed agreement (Sexual Offences Act 2003; Criminal Code of Canada, s. 273.1; Crimes Act 1900 NSW). The comparative analysis suggests that these divergences may affect access to justice and public perceptions of consent, highlighting the need for greater conceptual consistency within legal frameworks.
Khushi Meena (Fri,) studied this question.