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As per the data homosexuals have suffered and have been targeted the most during the implementation of this section. This led to a legal battle to decide the fate of this section. The legal battle surrounding this section started with the petition by Naz Foundation before the High Court of Delhi. The Delhi High court in Naz Foundation v NCT of Delhi[2] read down the section to not to apply to consensual private sexual acts but still be applicable to non-consensual acts. Thus the effect of the decision was that homosexual acts are not illegal.

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