Outraging Modesty of Woman - IPC Section 354

Edited By Ritika Jonwal | Updated on Jul 02, 2025 05:48 PM IST

In Indian society, women's modesty is highly esteemed, and any actions that are perceived as insulting this modesty are met with harsh consequences. The act of outraging a woman's modesty includes intentional verbal or nonverbal offences in addition to physical assaults. By definition, the offense is cognizable, non-bailable, and non-compoundable. The Indian government has put more deterrents in place to try and make the laws against rape and sexual assault stronger. However, sexual offences against women are still a significant issue in India, and more needs to be done to guarantee that the law is applied correctly.

This Story also Contains

Meaning of Outraging Modesty of a Woman
Meaning of Modesty
Provisions Under IPC- Section 354
Essentials of Section 354 IPC
Punishment Under Section 354 IPC
Actions Amounting to Sexual Harassment
Insulting the Modesty of a Woman
Various and Newer Offences Against Women
Indian Government’s Efforts to Make Provisions on Outraging
Women’s Modesty
Case Laws on Outraging Modesty of Women
Conclusion

Outraging Modesty of Woman - IPC Section 354

Meaning of Outraging Modesty of a Woman

The meaning of outraging modesty of a woman was defined under the landmark judgement in the Court of State of Punjab v. Major Singh. The Supreme Court stated that "a woman's sex is the essence of her modesty." Her body is a living example of an adult's modesty. Whether she is young or old, wise or foolish, awake or asleep, the woman has the humility to be angry.

Anyone who intends to offend a woman by using criminal force is subject to punishment under Section 354 of the IPC. Three types of acts are listed in Section 354 as being offensive to a woman's decency.

Section 354A IPC- Sexual Harassment
Section 354C IPC- Voyeurism
Section 354D IPC- Stalking

Meaning of Modesty

The IPC, 1860's Section 354 addresses assault or use of force against a woman to offend her modesty. Up until 2007, there was a great degree of uncertainty on what exactly defined a woman's modesty, and there were many different theories about what constituted a girl's modesty. Several situations were identified, but the precise meaning of a woman's modesty was not.

In the case of, Ramkripal v. State of Madhya Pradesh

The Supreme Court ruled in this case that a woman's sex is the "essence of her modesty" and that this revealed printed modesty. As a result, associate-degree crimes against women that fit within the heading of wanting penetration will now be included in the list of offences covered by section 354 of the IPC.

Provisions Under IPC- Section 354

The Indian Penal Code, 1860, Section 354, forbids disparaging a woman's modesty. According to this clause, there is a fine and a jail sentence (which cannot be less than one year and can be up to five years) for anybody who assaults a woman, employs unlawful force against her in an attempt to upset her, or knows that doing so will likely cause her to lose her modesty.

Essentials of Section 354 IPC

Assault or Use of Criminal Force

The accused must assault a woman or use unlawful force against her. To willfully cause hurt or to arouse fear of harm is to commit assault. The use of force against a woman's will and without her agreement is known as criminal force.

Intention to Outrage Modesty

The attack or use of illegal force must have been motivated by a desire to violate the woman's modesty. The term "modesty" relates to a woman's sense of propriety and decency; a woman's modesty may be wounded or offended in a variety of situations and contexts.

Knowledge of Outraging Modesty

In addition to the intention, the accused must also have a reasonable expectation that his conduct will offend the woman's modesty. This means that the accused could still be held accountable under Section 354 even if he had no particular intention of upsetting modesty if he knew or should have known that his acts were likely to have that effect.

Punishment Under Section 354 IPC

The sentence in this section, which stipulates that each type of imprisonment may be served for a minimum of one year and a maximum of five years, has come under heavy fire. In addition, the fine will be computed. As a result, the judge has the power to provide a light or harsh punishment. Since there will be a cost in addition to the jail term, the offence is not compoundable. State laws may also affect penalties. Additionally, the accused will have the chance to file a countercomplaint or offer a legal defence in cases of Section 354 false charges.

Actions Amounting to Sexual Harassment

Unwanted and overtly sexual attempts and solicitations during physical contact
An appeal or requirement for sexual services
displaying explicit material on a woman's request; and
making remarks that are suggestive of sex.

Insulting the Modesty of a Woman

Section 509 brings an act that is done to demean a woman's modesty which may not necessarily include physical force under the purview of this article. This section aims to prevent any form of assault towards a woman's modesty, including words, gestures, acts, and invasions of her privacy. The "Eve Teasing Section" is another name for this portion. Anyone found guilty of violating Section 509 faces a fine and up to three years of simple jail as their punishment. The essential ingredients in this section are-

a desire to disparage a woman's modesty;
The offence must be inflicted by either violating a woman's personal space or by making any noise, gesturing, speaking, or displaying any object.

You may also read

Various and Newer Offences Against Women

Section 354B IPC- Disrobing a Woman

The offence of attacking or using unlawful force against a woman, or aiding and abetting any such act with the intent to cause her to undress or be forced into the nude, is punishable under Section 354B by a minimum sentence of three years, which may be increased to seven years, as well as a fine. This is a gender-specific offence, meaning that only men are subject to punishment under it.

Section 354C IPC- Voyeurism

This crime was created in the wake of the 2012 Nirbhaya Rape Case. The IPC's Section 354C addresses it. The term "voyeurism" refers to the enjoyment one experiences when surreptitiously observing the intimate or sexual acts of another person. There are two sections to this regulation. First, when someone observes or records a picture of a lady doing a private act; and second, when someone shares or circulates that picture. A minimum of one year in prison and a maximum of three years in prison are the penalties for the first offence. A minimum sentence of three years in jail, with a maximum sentence of seven years, together with a fine, is imposed for the second offence. The essential ingredients in this section are-

The accused needs to be a man.
He needs to observe or record the picture.
The woman being photographed needs to be involved in a private activity.
The situation ought to be such that she anticipates not being seen by the offender; or
That picture is spread by the accused.

Section 354D IPC- Stalking

The term "stalking," as defined by Section 354D of the IPC, refers to the act of pursuing or attempting to contact a woman despite her lack of interest. There are two offences under this section. First, when a guy persistently tracks, contacts, or tries to contact a woman despite her overt signs of disinterest; and second, when a male keeps an eye on how a woman uses the internet, email, or any other electronic communication tool. In the event of a first conviction, a fine and up to three years in prison are the recommended penalties. A second conviction carries a maximum sentence of five years in prison and a fine.

What Amounts to Stalking?

There is a proviso attached to Section 354D that defines an exception to this crime. It won't be considered stalking if a person must assist the state in preventing and detecting crimes if such crimes must be prosecuted under applicable laws, and if the person's actions must be reasonable and justifiable under the given circumstances

Section 326A and 326B IPC- Acid Attack

Sections 326A and 326B were included by the Criminal Law (Amendment) Act, 2013 to establish precise guidelines for punishment in cases of acid attacks.

Section 326A deals with intentionally utilizing acid to cause great harm. According to this section, anyone who throws or administers acid with the intent to cause permanent or partial damage, burns, disfigures, or disables any part of a person's body, or causes grievous harm, will be punished with at least ten years in prison, with the possibility of a life sentence plus a fine.

The act of attempting to hurl acid with the intent to do great harm is the subject of more legislation in Section 326B. This clause imposes a minimum five-year prison sentence and a fine that can be as high as seven years.

Section 354A IPC - Sexual Harassment

This new clause was inspired by a Supreme Court ruling on the problem of sexual harassment in the workplace. The Criminal Law (Amendment) Act, 2013 introduced Section 354A into the Indian Penal Code, delineating the definition of the offence of "sexual harassment" and prescribing the associated penalties.

A person shall be guilty of the offence of sexual harassment against a woman under Section 354A under the following situations:

If he initiates unwanted physical contact and suggests an explicit sexual act;
requests or demands for sex favours;
displays pornography against a woman's request;
Make sexually suggestive comments

For the offences listed in Section 354A (1) (i) through (iii), the penalty is rigorous imprisonment for a term that may last up to three years, along with a fine or both. Under subclause (iv), the punishment consists of a fine or both, as well as a period of imprisonment that can last up to a year.

Indian Government’s Efforts to Make Provisions on Outraging

Women’s Modesty

The Indian government has strengthened the country's anti-sexual offence laws to combat the issue of sexual offences. Among the significant initiatives are:

The Protection of Children from Sexual Offences(POSCO) Act, 2012

Sexual offences against minors are punishable under this Act with more severe penalties, including life in prison in certain cases. The Act also calls for steps to safeguard the rights of child victims, such as the installation of closed-circuit television cameras in courtrooms and the recording of child victims' testimonies via video conferencing. The act also mandates that any cases involving sexual offences against minors be tried in special courts within a year of the offence being committed.

The Criminal Law (Amendment) Act, 2013

The Indian Penal Code, 1860 was amended to provide harsher penalties for rape and sexual assault, including the death penalty for repeat offenders and situations in which the victim is rendered vegetative. The amendment also broadened the definition of rape to encompass acts like inserting items or body parts into the mouth, anus, or vagina, as well as oral, anal, and vaginal penetration.

The Criminal Law (Amendment) Act, 2020

The Indian Penal Code, of 1860 was amended in some ways by this Act, one of which is the addition of strong penalties for sexual offences such rape, acid attacks, and stalking. A new section regarding the penalties for sexual harassment, including those for harassment at work, was also included in the Act. The Act also makes it illegal to reveal the identity of a family member or victim of a sexual offence.

Case Laws on Outraging Modesty of Women

In the case of, Swapna Barman v. Subir Das

In this case, it was held that the term "modesty" as defined by Section 509 does not only exclude indecency but also acts as a catalyst for thinking about engaging in an inappropriate sexual connection. Therefore, it is crucial to consider that any actions that do not constitute rape must be explained away as the woman's indignation at her lack of modesty. It's also crucial to remember that the codified sections of the Indian Penal Code, 1860 do not specifically name any gender as an offender for the crimes in issue, meaning that a woman might face prosecution for the offence of outraging the modesty of another woman. Because of this, offenders male and female may face legal consequences for this offence.

In the case of, Major Lachhman Singh v. The State

In this case, it was given considerable thought to and discussion of the concept of "modesty" as it relates to women. Regarding the offence under Section 354 of the Indian Penal Code, 1860, it was decided that mere accusations would not be adequate to satisfy the element of outraging a female's modesty, which is a required and crucial component of the offence.

Conclusion

The Government of India from time to time has taken strict steps to deal with offences against women and steps to prevent such offences. The offences of Outraging Modesty of a Woman is a serious offence in India and the Indian Law system makes provisions for imprisonment and fine for offences relating to Outraging Modesty of a Woman. The Indian Law system has made efforts to make stricter laws to punish the offenders as offences against women are a major offence in India and to deal with it various amendments have been made in the Indian Criminal law as mentioned above in the article.

Frequently Asked Questions (FAQs)

1. What is the Outraging Modesty of a Woman?

When a woman's modesty is offended, it is considered a crime, especially if the offender uses unlawful force or assault with the knowledge that the victim will be offended.

2. Which Section of IPC deals with Outraging Modesty of a Woman?

Section 354 of the IPC deals with the Outraging Modesty of a Woman.

3. What is the punishment for Section 354A?

Under section 354A the offence shall be penalized by a fine, a term of harsh imprisonment that may not exceed three years, or both.

4. What is Section 354B?

A man violates section 354B if he assaults, uses unlawful force against, or aids and abets any woman to strip her naked or force her to be in public.

5. What is Stalking?

The act of pursuing or making contact with a woman notwithstanding her lack of interest is referred to as "stalking," as described by Section 354D of the IPC.

6. What is the significance of the term "assault" in Section 354 IPC?

The term "assault" in Section 354 IPC is significant as it covers situations where there might not be actual physical contact. In legal terms, assault refers to the threat or attempt to apply force to another person, creating a reasonable apprehension of immediate harm. This means that threatening gestures or actions that make a woman fear for her modesty can be covered under this section, even without physical touch.

7. Can a person be charged under Section 354 IPC for actions committed through electronic means?

While Section 354 IPC was primarily designed for physical world offenses, it can potentially be applied to actions committed through electronic means if they meet the criteria of outraging a woman's modesty. However, for offenses committed through electronic means, more specific laws like the Information Technology Act, 2000, particularly Section 67 (publishing or transmitting obscene material in electronic form), are often more applicable.

8. Can a person be charged under Section 354 IPC for actions committed under the influence of alcohol or drugs?

Yes, a person can be charged under Section 354 IPC for actions committed under the influence of alcohol or drugs. Intoxication is generally not considered a valid defense for criminal actions in Indian law. In fact, being under the influence might be seen as an aggravating factor rather than a mitigating one, as it shows recklessness and disregard for others' safety and dignity.

9. How does Section 354 IPC apply to cases involving minors as victims?

When the victim is a minor, Section 354 IPC applies with additional gravity. Such cases may also invoke the Protection of Children from Sexual Offences (POCSO) Act, 2012, which provides more stringent punishments for sexual offenses against children. The investigation and trial process in such cases often involve special provisions to protect the minor's identity and well-being.

10. How does Section 354 IPC interact with laws against domestic violence?

While Section 354 IPC can be applied in domestic settings, cases of domestic violence are more comprehensively addressed by the Protection of Women from Domestic Violence Act, 2005. However, if a specific incident within a domestic relationship meets the criteria of outraging modesty as per Section 354 IPC, it can be charged under this section alongside or independent of domestic violence charges.

11. How does the law determine if a woman's modesty has been outraged?

The law considers various factors to determine if a woman's modesty has been outraged, including the nature of the act, the surrounding circumstances, and the impact on the victim. The test is whether a reasonable person would consider the act offensive to a woman's sense of decency and dignity. It's not solely based on the victim's subjective feelings but also on societal standards of decency.

12. Is physical contact necessary for an offense under Section 354 IPC?

No, physical contact is not always necessary for an offense under Section 354 IPC. While many cases involve unwanted touching, the offense can also be committed through gestures, words, or other non-physical actions that are intended to outrage a woman's modesty or are likely to do so.

13. What is the difference between Section 354 and Section 509 of the IPC?

Section 354 deals with assault or use of criminal force to outrage a woman's modesty, which often involves physical acts. Section 509, on the other hand, pertains to words, gestures, or acts intended to insult the modesty of a woman. Section 509 typically covers non-physical offenses like verbal harassment or indecent gestures.

14. How does Section 354 IPC differ from the offense of rape?

Section 354 IPC (outraging modesty) differs from rape in several key aspects. Rape involves non-consensual sexual intercourse or penetration, while Section 354 covers a broader range of less severe sexual offenses. The punishment for rape is generally more severe, and the elements of the crime are different. Section 354 focuses on acts that violate a woman's dignity and modesty, which may or may not include sexual contact.

15. Can a woman be charged under Section 354 IPC for outraging another woman's modesty?

Yes, a woman can be charged under Section 354 IPC for outraging another woman's modesty. The section uses gender-neutral language for the offender, stating "whoever" commits the offense. While it's less common, cases of women being charged under this section do exist.

16. Is intention to outrage modesty always required for conviction under Section 354 IPC?

No, intention is not always required for conviction under Section 354 IPC. The section covers two scenarios: (1) where the accused intends to outrage the woman's modesty, and (2) where the accused knows it is likely that their actions will outrage her modesty. This means that even if there was no specific intention, knowledge of the likely consequence is sufficient for conviction.

17. What is the role of consent in cases under Section 354 IPC?

Consent plays a crucial role in cases under Section 354 IPC. If the woman has given clear and voluntary consent to the act in question, it would not constitute an offense under this section. However, the consent must be genuine and not obtained through coercion, misrepresentation, or when the woman is incapable of giving consent (e.g., if she's unconscious or underage).

18. Can a person be charged under Section 354 IPC for actions committed in a public place?

Yes, a person can be charged under Section 354 IPC for actions committed in a public place. The location of the offense doesn't affect the applicability of the section. In fact, many cases under this section occur in public spaces like streets, public transport, or crowded areas. The public nature of the act might even be considered an aggravating factor in some cases.

19. Can a woman file a complaint under Section 354 IPC if the incident occurred in a foreign country?

Generally, Indian criminal laws, including Section 354 IPC, apply to offenses committed within Indian territory. If the incident occurred in a foreign country, it would typically be subject to that country's laws. However, if the offender is an Indian citizen and the act is also an offense in that foreign country, they might be prosecuted in India under certain conditions as per Section 4 of the IPC.

20. Is it necessary for the victim to physically resist for a case to be made under Section 354 IPC?

No, it is not necessary for the victim to physically resist for a case to be made under Section 354 IPC. The absence of physical resistance does not imply consent or negate the offense. Many victims may freeze or be too scared to resist physically. The focus is on the accused's actions and intent, not on the victim's response.

21. How does Section 354 IPC address cases of mob harassment or group offenses?

Section 354 IPC can be applied to cases of mob harassment or group offenses where a woman's modesty is outraged. Each individual participating in such an act can be charged separately under this section. Additionally, other sections like Section 34 IPC (common intention) or Section 149 IPC (unlawful assembly) might be invoked to address the group nature of the offense and hold all participants accountable.

22. How does Section 354 IPC address cases of attempted offenses?

Section 354 IPC covers both completed acts and attempts to outrage a woman's modesty. If a person attempts to use criminal force or assault with the intention to outrage a woman's modesty, but is prevented or fails for some reason, they can still be charged under this section. The law recognizes that the attempt itself is a violation of the woman's dignity and safety.

23. What is the legal definition of "outraging the modesty of a woman" under IPC Section 354?

IPC Section 354 defines "outraging the modesty of a woman" as any act by a person that assaults or uses criminal force against a woman, intending to outrage or knowing it is likely to outrage her modesty. This includes unwanted physical contact, lewd gestures, or any behavior that violates a woman's dignity and sense of decency.

24. How does the concept of 'modesty' in Section 354 IPC apply to different cultural contexts?

The concept of 'modesty' in Section 354 IPC is interpreted considering prevailing social and cultural norms, but with a universal understanding of human dignity and respect. Courts generally apply an objective test, considering what a reasonable person in society would find offensive to a woman's dignity. While cultural contexts may influence interpretation, basic principles of respect and dignity are considered universal.

25. What is the significance of the term "criminal force" in Section 354 IPC?

The term "criminal force" in Section 354 IPC is significant as it defines the physical element of the offense. Criminal force refers to the intentional use of force on another person without their consent, in a way that causes them to feel personal contact. This could include actions like grabbing, pushing, or any unwanted touching. The inclusion of this term ensures that the section covers physical violations of a woman's bodily integrity.

26. How does Section 354 IPC apply in cases involving married couples?

Section 354 IPC can apply in cases involving married couples. Marriage does not grant automatic consent for all physical acts. If a spouse uses criminal force or assault to outrage the modesty of their partner, it can be prosecuted under this section. However, such cases can be complex due to societal attitudes and the private nature of marital relationships.

27. What is the significance of the term "knows it to be likely" in Section 354 IPC?

The phrase "knows it to be likely" in Section 354 IPC is significant as it extends the scope of the offense beyond just intentional acts. It means that even if the accused didn't specifically intend to outrage the woman's modesty, they can still be held liable if they should have known that their actions were likely to have that effect. This broadens the application of the law and holds individuals accountable for reckless or negligent behavior as well.

28. What is the punishment for outraging the modesty of a woman under Section 354 IPC?

The punishment for outraging the modesty of a woman under Section 354 IPC is imprisonment for a term which shall not be less than one year but which may extend to five years, and shall also be liable to fine. The severity of punishment can vary based on the specific circumstances of the case and any aggravating factors.

29. Is Section 354 IPC a cognizable offense?

Yes, Section 354 IPC is a cognizable offense. This means that the police can arrest the accused without a warrant and start an investigation without the permission of a court. It also implies that the offense is considered serious enough to warrant immediate police action.

30. What is the statute of limitations for filing a complaint under Section 354 IPC?

There is no specific statute of limitations for filing a complaint under Section 354 IPC. As it is a criminal offense, it can be reported and investigated at any time after the incident occurs. However, practical considerations like availability of evidence and witness memory may affect the strength of the case if there's a significant delay in reporting.

31. Can a minor be charged under Section 354 IPC?

Yes, a minor can be charged under Section 354 IPC, but the case would be handled differently. If the accused is under 18 years old, the case would be dealt with under the Juvenile Justice (Care and Protection of Children) Act, 2015. The focus would be on rehabilitation rather than punishment, and the proceedings would take place in a Juvenile Justice Board rather than a regular criminal court.

32. Can a case under Section 354 IPC be settled out of court?

As Section 354 IPC is a non-compoundable offense, it cannot be legally settled out of court without the court's permission. This means that once a formal complaint is filed, the case proceeds even if the victim wants to withdraw. However, in practice, if both parties agree to a settlement, the court may consider it, especially in less severe cases, but this is at the court's discretion and not a right.

33. What is the difference between Section 354 and Section 354A of the IPC?

While both sections deal with offenses against women, they cover different aspects. Section 354 is broader, covering assault or use of criminal force to outrage a woman's modesty. Section 354A, introduced later, specifically addresses sexual harassment. It includes unwelcome physical contact, demand or request for sexual favors, showing pornography against the will of a woman, or making sexually colored remarks.

34. How does Section 354 IPC apply in cases of workplace harassment?

Section 354 IPC can apply to cases of workplace harassment if the actions meet the criteria of outraging a woman's modesty. However, workplace sexual harassment is more specifically addressed by the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. This act provides a more comprehensive framework for dealing with sexual harassment in professional settings, including mechanisms for complaint and redressal.

35. Can a person be charged under Section 354 IPC for virtual or online harassment?

While Section 354 IPC was originally designed for physical world offenses, it can potentially be applied to virtual or online harassment if the actions meet the criteria of outraging a woman's modesty. However, for online offenses, more specific laws like the Information Technology Act, 2000 (particularly Section 67) are often more applicable. The interpretation may vary based on the specific nature of the online act and judicial discretion.

36. How does Section 354 IPC interact with laws protecting transgender individuals?

While Section 354 IPC specifically mentions women, the principles of protecting an individual's modesty and dignity extend to all genders. For transgender individuals, the Transgender Persons (Protection of Rights) Act, 2019 provides specific protections. However, depending on the circumstances and the individual's gender identity, Section 354 IPC might be applicable. Courts are increasingly interpreting laws in a gender-inclusive manner.

37. What is the relevance of the victim's past sexual history in Section 354 IPC cases?

The victim's past sexual history is generally considered irrelevant in Section 354 IPC cases. The Indian Evidence Act, particularly after the 2013 amendments, prohibits any questioning about the victim's general moral character or previous sexual experience in sexual offense cases. The focus should be on the specific incident in question and the accused's actions, not on the victim's personal life or history.

38. Can a case under Section 354 IPC be filed based solely on the victim's statement?

Yes, a case under Section 354 IPC can be filed based solely on the victim's statement. The victim's testimony is considered crucial evidence in such cases. However, for a successful prosecution, corroborating evidence (if available) strengthens the case. The court will evaluate the credibility of the victim's statement along with any other available evidence.

39. Can a complaint under Section 354 IPC be filed anonymously?

While a formal complaint under Section 354 IPC typically requires the victim's identity for legal proceedings, there are provisions for protecting the victim's identity during the trial. In some cases, especially those involving minors, the court may order that the victim's identity not be disclosed. Anonymous tips can lead to police investigations, but for prosecution, a formal complaint is usually necessary.

40. What is the role of medical evidence in cases under Section 354 IPC?

Medical evidence can play a supporting role in cases under Section 354 IPC, especially if there was physical contact resulting in visible injuries. However, unlike in rape cases, medical evidence is not always crucial for Section 354 cases. The offense often doesn't leave physical marks, so the victim's testimony, witness accounts, and other circumstantial evidence are often more important.

41. How does the principle of 'innocent until proven guilty' apply in Section 354 IPC cases?

The principle of 'innocent until proven guilty' applies to all criminal cases in India, including those under Section 354 IPC. This means that the burden of proof lies with the prosecution to prove beyond reasonable doubt that the accused committed the offense. However, given the nature of these offenses, courts often give significant weight to the victim's testimony, especially if it is consistent and credible.

42. What is the role of eyewitness testimony in Section 354 IPC cases?

Eyewitness testimony can play a crucial role in Section 354 IPC cases, especially when there's no physical evidence. Credible eyewitness accounts can corroborate the victim's statement and strengthen the prosecution's case. However, courts also recognize the potential fallibility of eyewitness testimony and typically consider it along with other available evidence and the overall circumstances of the case.

43. Can a complaint under Section 354 IPC be filed if there were no witnesses to the incident?

Yes, a complaint under Section 354 IPC can be filed even if there were no witnesses to the incident. Many such offenses occur in private or isolated settings. In such cases, the victim's testimony becomes crucial. While corroborating evidence strengthens the case, courts have held that conviction can be based on the sole testimony of the victim if it is found to be credible and consistent.