Academic Paper: LGBT Rights in North America and Asia

by Akshay Chhajed

Brief Summary

As one of the most famous globally cited and respected organizations, the International Lesbian, Gay, Bisexual, Trans and Intersex Association (ILGA) asserts in its 2017 State Sponsored Homophobia report, “Knowledge is itself power” and having this power induces a proclivity to be empathetic, informed and understanding towards a topic as divisive as LGBT rights across the world today (Carroll and Mendos, 2017, Pg. 6). In this academic paper, I systematically and critically scrutinize the background and present standing of this social movement on two continents – North America and Asia within the limited context of four countries that I analyze as case studies: United States of America, Canada, India and Singapore. Moreover, I solely focus on sexual orientation rights and largely investigate the legal and social experiences of non-heterosexual individuals along with concerned stakeholders involved in this global movement across my chosen nations. By providing a brief historical portrait for each country and then delving into contemporary laws vis-à-vis socio-cultural factors hindering or advancing the movement, I propose my comprehension of the role of different stakeholders in the process and their effectiveness. Ultimately, subsequent to analyzing the strategic actions and interests of relevant stakeholders, I bring forth my own predicted outcomes in many cases and at the end present my recommendations based on strategic synergy among all stakeholders for making the sexual orientation movement more successful.


Critical Analysis

With a history spanning several millennia, the recognition of Lesbian, Gay, Bisexual and Transgender (LGBT) people has been an essential but contentious component of human society. From a global justice perspective, it is evident that LGBT individuals possess target identities that continue to make them victims of brutal violence, oppression, discrimination, harassment and marginalization across the world even today. Having recently researched about international LGBT rights, I wish to subsequently analyze contemporary LGBT movements in North America and Asia, with a specific focus only on sexual orientation rights in four countries within both these continents. By using a highly comparative geographic approach, I hope to identify the key stakeholders and their broadly employed strategies in the United States and Canada (for North America) and in India and Singapore (for Asia) to assess the positive impacts and challenges of their current strategies. Hence, in the following paragraphs I will explore the ongoing sexual orientation equality movements in these four countries and use a variety of academic and news sources to both analyze the effectiveness of these social movements within this regional context and propose my predicted outcomes and personal recommendations for greater success.


Globally as of May 2017, there are 72 nations that penalize same-sex sexual activity while 124 nations do not, and the United States and Canada are fortunately two countries from the latter group (Carroll and Mendos, 2017, Pg. 8). North America as a continent tends to be largely supportive and accepting towards non-heterosexuals, which can also clearly be seen in the laws and social attitudes of both the US and Canada. When firstly looking at the United States, it is commendable to see how the nation has progressed far ahead from its earliest movements in the 1920s to nationwide marriage equality (same-sex marriage) in 2015 (“LGBT Rights Milestones Fast Facts,” 2017). As a highly dynamic and multiethnic country, the US has a vast array of different identities divided by religion, ethnicity and age that play a large role in determining attitudes towards non-heterosexuals, especially gays. A 2013 survey by the Pew Research Center revealed that around 60% of Americans believe homosexuality should be socially accepted while 33% responded negatively, with greater negative opinions expressed by more religious and older people (“The Global Divide on Homosexuality,” 2013). However, my identified key affected and impactful stakeholders here include the general public, the government, media groups and external organizations who are religiously, politically and culturally divided and either promote or oppose sexual orientation rights. Each of these groups have conflicting interests, most notably and simplistically seen between pro-equality liberal Democrats and anti-equality conservative Republicans. I believe that with the previous Obama administration’s efforts to acquire marriage equality and the ongoing actions of the Trump government to remove LGBT inclusion like recently in LGBT exclusion from demographic surveys, the sexual orientation movement has been unstable in the US and despite great advancements, has many social and political hurdles to overcome (Carroll and Mendos, 2017, Pg. 163).


In contrast to the unstably slow and systematic process of ending sexual orientation discrimination in the United States, Canada has seen more steady strides on the march to equality. When looking at the sexual orientation rights movement in Canada, the key stakeholders again were and presently are religiously and ethnically diverse groups in the nation that stand slightly divided on this movement with 80% expressing approval and 14% disapproval (“The Global Divide on Homosexuality,” 2013). Starting from 1969, when Prime Minister Pierre Trudeau decided that “the state has no business in the bedrooms of the nation,” the decriminalization of homosexual acts between consenting adults was the first progressive leap that was followed by several decades of policy changes against discriminatory practices in Canadian law and society (Davison, 2017). So when Canada was among the early nations to legalize marriage equality in 2005, a remarkable milestone had been achieved with the most important stakeholders – lesbians, gays and bisexuals (LGB) gaining the most with the only limited bureaucratic impact being the cost of implementing this change across Canada. Nonetheless, as the incumbent PM Justin Trudeau mentioned, there are discriminatory practices like a law preventing gay men from donating blood that still need to be repealed for true equality. Overall, I felt that North America is on a positive path to attaining equal sexual orientation rights and the current strategies of lobbying governments to enact positive changes through non-violent initiatives and demanding greater representation has been highly effective, although I would also suggest fostering more public inclusion awareness to change societal attitudes towards non-heterosexuals.


Unlike the economically developed and relatively socially liberal North America with countries like the US and Canada, Asia is an extremely large and diverse continent where India is a developing and very conservative traditional society. Stemming from British colonialism in modern India’s history, Victorian law crept into the nascent Republic of India’s constitution in 1950 to criminalize “carnal intercourse against the order of nature” that essentially illegalized homosexual relations and any form of non-heterosexuality in practice (Crossley, Gourlay and Spraggon, 2017). As an Indian myself, I have witnessed and heard about the amount of discrimination and ill-treatment non-heterosexuals face legally in society in addition to widespread social stigma in the country. Often seen as a remnant of a backward and regressive cultural mindset, homophobia in India naturally affects its direct stakeholders – non-heterosexuals, whereas other less-impacted stakeholders include religious groups, conservative politicians, media channels and the general public. As opposed to increasingly irreligious Canada and the US, India is still a deeply religious society where its dominant religion, Hinduism is comprised of several belief systems with varying degrees of acceptance towards non-heterosexuals. I believe this stark cultural difference between the Western World and India in addition to outdated colonial homophobic laws present notable social challenges to individuals and activists fighting for equality. However, a recent August 2017 law defending an “intrinsic” right to individual privacy seems to be a step in the right direction and a beacon of hope for the marginalized LGBT community for a freer future (Ganguly, 2017). With strong right-wing political and social conservative resistance against equality, I hold that greater awareness campaigns in addition to informed public support will greatly strengthen India’s sexual orientation and broader LGBT rights movement.


To finally look at the last of the four countries, the Southeast Asian island country of Singapore is a unique blend of substantial economic prosperity and multiculturalism like in Canada but a socially conservative Asian outlook like India. By utilizing words such as “indecency,” “obscenity” and “sodomy,” Singapore’s constitution also enforces a profoundly moralistic legislation against non-heterosexual rights like that of India (Carroll and Mendos, 2017, Pg. 136). Despite being a wealthy and technologically advanced nation, Singapore was founded and developed by many immigrants under the British colonial empire that contributed to a similar state-sanctioned homophobia and discrimination as seen in India and pre-1960s North America. Most interestingly, Singapore is only partially democratic as its government exercises a great deal of control over issues like LGBT rights that are deemed as being “sensitive,” as even seen when corporations like Google and Apple chose to sponsor the annual 2016 Pink Dot rally in support of LGBT rights, the Singaporean government accused the companies of “foreign interference” in domestic affairs (Lakhdhir, 2017). Like all the previous three countries analyzed, the key stakeholders here are again the powerful government, general public and media companies that tend to have a largely conservative attitude about idealized families and traditional values in the multiethnic milieu of Singapore. Nevertheless, with rapidly rising higher education rates among the youth of this tiny island nation and more exposure to global progressive ideas about sexual orientation rights, I believe Singapore will eventually achieve far more equality, albeit very slowly like Eastern Europe and India today. From a personal standpoint, I contend that a public demand for more purely democratic governmental procedures in addition to adoption of LGBT rights education in schools will significantly help promote sexual orientation equality in Singapore.


After comparatively and critically examining the sexual orientation laws, social attitudes and social movement trends across the US, Canada, India and Singapore, I am convinced that the success of the movement is significantly geographically divided due to both cultural reasons and historical strategies. Creating sustainable social change for a cause as controversial as sexual orientation and LGBT rights across conservative cultures like India and Singapore or political cleavages in the US and Canada is particularly challenging due to cultural, societal and historical reasons in each of these nations. These case studies have made me realize that to truly overcome cultural resistance and formulate an effective liberalization strategy, possible crucial worldwide measures could include the decriminalization of same-sex relations, comprehensive anti-discrimination regulations, social inclusion and de-stigmatization efforts launched by stakeholders like the media and finally more reinforcing support from inclusive educational practices, as an influential new UN Human Rights Council report has also recommended (“Report of the Independent Expert on protection against violence and discrimination based on sexual orientation and gender identity”, 2017). If the multiple and monumental stakeholders, especially the general public and progressive non-profits work actively to promote equality by engendering a synergistic strategy for obtaining true sexual orientation recognition both politically and culturally, I envision this social movement becoming far more successful in the near future. In conclusion, while a disheartening number of challenges may yet torment the journey towards complete equality for non-heterosexuals and the wider LGBT community, I am confident that convicted dedication and strategically planned synergistic efforts for fulfilling this aspiration will soon one day make it a global reality.


Carroll, A. and Mendos, L.R. (2017, May). State Sponsored Homophobia 2017: A world survey of sexual orientation laws: criminalisation, protection and recognition, 12th Edition. International Lesbian, Gay, Bisexual, Trans and Intersex Association (ILGA), Geneva. Retrieved from

Crossley, Paul, Gourlay, Colin, & Spraggon, Ben. (2017, November 15). Pride, prejudice and punishment: Gay rights around the world. Australian Broadcasting Corporation (ABC). Retrieved from

Davison, Amber-Dawn. (2017, March 4). From Trudeau to Trudeau: The evolution of LGBT Rights in Canada. David McKie: Your home for data journalism. Retrieved from

Ganguly, Meenakshi. (2017, August 24). India’s Supreme Court Upholds Right to Privacy. Human Rights Watch. Retrieved from
Lakhdhir, Linda. (2017, August 7). How LGBT Activists Are Marshaling Support From Singapore’s Private Sector. Human Rights Watch. Retrieved from

LGBT Rights Milestones Fast Facts. (2017, November 9). Cable News Network (CNN). Retrieved from

The Global Divide on Homosexuality. (2013, June 4). Pew Research Center: Global Attitudes & Trends. Retrieved from

United Nations, General Assembly, Human Rights Council (2017, April 19). Report of the Independent Expert on protection against violence and discrimination based on sexual orientation and gender identity. Retrieved from (A/HRC/35/36)



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