Consent and will in emphasis

with section 375 of IPC

By Diganth Raj Sehgal - December 14, 2020

Image Source: https://bit.ly/2xuVCQP

This article is written by Darshit Vora of Narsee Monjee

Institute of Management Studies. The article analyses the
concepts of will and consent in detail. Further, it lists
down points of distinction with emphasis on section 375 of
the Indian Penal Code.

Table of Contents 
1. Introduction
2. Consent
2.1. Capacity to consent
2.2. Types of consent
2.3. Where consent need not be obtained
3. Will
4. Law against the will and without consent
4.1. Essential of Rape
4.1.1. Act committed against the will
4.1.1.1. Case law
4.2. Himachal Pradesh v. Mango Ram (2000) 
4.2.1. Act committed against the consent
4.3. Queen vs flattery (1877) 
4.4. Types of Non-Valid Consent
4.4.0.1. Case Law
4.5. Bhupender Singh v. Union Territory of
Chandigarh (2008) 
4.5.0.1. Case Law
4.6. Dileep Singh v. State of Bihar (2004)
4.6.0.1. Case Law
4.7. Tulsidas Kanolkar vs State of Goa (2003)
4.7.0.1. Case law
4.8. State of Maharashtra vs Prakash (1992) 
4.9. Punishment for Rape
5. Difference between without her consent and against her
will under Section 375
6. Exceptions to Section 375 
6.0.1. Exception 1 
6.0.2. Exception 2 
6.0.2.1. Case Law
6.1. Shree Kumar v. Pearly Karun (1998)
7. Landmark judgments under Section 375 
7.1. Rao Harnam vs Union of India (1957)
7.2. Mukesh & Anr. vs. State for NCT of Delhi & Ors.
(Nirbhaya Gang Rape Case) (2017)
7.3. State of Maharashtra v. Vijay Mohan Jadhav and
Ors. (Shakti Mills Gang Rape) (2019)
7.4. Tukaram and Anr. v. State of Maharashtra (1978)
7.5. Vishaka v. State of Rajasthan and Ors. (1997)
7.6. State of Maharashtra v. Madhukar Narayan (1990)
7.7. Independent thoughts v. Union of India (2017)
 8. Conclusion
9. References

Introduction
While performing any act, the two essential ingredients
are consent and will. Different courts have interpreted the
ingredients differently. The plain reading of consent
mentions that act should be voluntary and willing. Many
authors and researchers still believe that willingness and
consent are the same. This article explains the clear
differentiation between will and consent in consideration
with Section 375 of the Indian Penal Code through various
judgments of the courts. While considering Section 375 of
the Indian Penal Code both the clauses need to be
satisfied to avoid liability from the offence of rape. 

Consent
Consent refers to an activity done by a person under a
free state of mind. According to Merriam Webster, consent
refers to an act committed by a person by giving assent
and approval. According to Section 375 consent can be
referred to as an unequivocal voluntary agreement when a
woman by communication, verbal, or non-verbal, shows
her willingness to commit a specific act. The core concept
under consent is choice, and not will. 

To interpret consent, it is necessary to prove:

The person can give consent; and

 The person, with his free choice, has accepted the act. 
For example, if A has accepted to perform the
construction of B’s house under his free choice, it would
amount to valid consent. 

Capacity to consent
The person is said to be capable of giving a valid consent
when:

1. The person should be of a sound mind:  The burden of

proof would be on the person claiming this right. 

For example, A gives consent to B to sell his property to

him when he was in an unsound state of mind, and later
retracts from the agreement, then it cannot be enforced
because the consent was obtained when he was not in a
sound mind. 

1. The person should have attained the age of majority:

In law, it is believed that minors are incapable of giving
consent. 

For example, if A and B are in a sexual relationship where

B is a minor girl, though the sexual activity is consensual,
it would still amount to the offence of rape.

Types of consent
Section 90 of the Indian Penal Code mentions the
meaning of free consent. Consent is not said to be free
when a person is put under the fear of injury, or
misconception of facts. 

There are two types of consent:

1. Implied Consent: It is a type of consent given by the
person in the form of actions. Consent can be given
through gestures or various non-verbal
communications. According to the legal dictionary,
implied consent refers to the consent that is inferred
from signs, actions, or facts, or by the inaction or
silence. For Example,. A owns a firecracker shop. 
When B enters his shop he gives an implied consent
that he wants to purchase products from his shop. 

2. Express Consent: It is a type of consent that may be

given by a person in an oral or written form. If it is
express consent, it becomes easier to prove in the
court of law. For example, A asks B to Purchase a
property for him and if he agrees and says yes, then it
is expressed consent. 

Where consent need not be obtained

According to Section 92 of the Indian Penal Code where it
is not possible for the person to give consent and the
other person acts in good faith, there is no need to wait
for the consent of the person.

For example, If A is facing epileptics and bleeding, he is

unable to give consent. Then if B, a surgeon, operated
without A’s consent, During the operation A was declared
dead, B cannot be held liable for his action because it was
a case of emergency and the patient was unable to give
consent. 

Will
The word refers to the reasoning power of the mind to
determine whether to do an act or not. According to
Merriam Webster, ‘will’ is defined as a thing that is done
with desire or choice. In other words, an act of will refers
to a desire to participate by a person without being under
pressure or under the influence of any other person. 

E.g. A instigated B to shoot C to which B willingly agreed

and shot C. In this scenario, there was a clear will of B to
shoot C though instigated by A he had a clear choice to
say no. 

Law against the will and without

consent
Section 375 of the Indian Penal Code includes both the
components it is an act that is committed against the will
and an act committed against the consent of the women. 

This section mentions the offence of rape. The word rape

is derived from the Latin word “rapio” which means to
seize in other words it refers to the ravishment of women
without her consent. Recently in the year 2013, an
amendment was passed in-laws of rape to safeguard the
interest of innocent victims. 
Essential of Rape
Against her will;

Without her consent;

Consent is obtained by force or putting a person of her

interest under fear of death;

Consent obtained by a misconception;

Consent was obtained when the person was unsound,

intoxicated, or under undue influence;

Women under the age of eighteen with or without her

consent;

A woman who is unable to communicate her consent. 

The two prominent essentials of rape are:

Act committed against the will

Will is a significant concept to prove the offence of rape.
According to Section 375(1) where sexual intercourse is
done against the will of the other person amounts to the
offence of rape. In the State of Uttar Pradesh v. Chhotey
Lal (2011)   the Supreme Court explained the concept
stating that an act done by a man against women despite
her resistance or opposition.

Case law

Himachal Pradesh v. Mango Ram

(2000) 
Facts:
In this case, Prosecutrix was the eldest daughter Jagia
Ram. The accused who was aged 17 years accompanied
the prosecutrix. The accused caught her from behind and
was forced to lie on the cowshed and committed a sexual
act. 

The Supreme Court held that the girl tried resistance to

stop the accused from committing the act but the accused
overpowered her and the act was committed against the
will of the victim and was held liable for the offence of
rape. 

Act committed against the consent

According to Section 375(2), an act of sexual intercourse
committed against the will of the women amounts to the
offence of rape. If the consent is not obtained freely then
the other person can impose criminal liability. In the
recent amendment in 2013 changes were made that if
women claim that while having sexual intercourse there
was no consent then the court shall presume the same.

Queen vs flattery (1877) 

Facts: In this case, the girl was in ill health and had gone
to the accused’s clinic and she was advised to undergo a
surgical operation to which she agreed while operating the
accused had sexual intercourse with the girl. The court
held that consent was not a valid one and was obtained
through misconception. Thus accused liable for the
offence of rape. 

Types of Non-Valid Consent

Consent obtained under misrepresentation, fraud, or
mistake: During the time of having sexual activity with a
woman if consent is obtained misrepresentation, fraud, or
mistake such consent won’t be held valid and the accused
can be still held liable for the offence of rape.

Case Law

Bhupender Singh v. Union Territory of

Chandigarh (2008) 
Facts In this case, the accused had sexual intercourse with
the prosecutrix through which she became pregnant and
she had undergone an abortion. They again had sexual
intercourse. The accused promised her that he would
marry her again and she again became pregnant. Later,
she got to know that the accused was already married and
had children and in confrontation, the accused failed to
perform his promise. She filed a suit against the accused. 

Judgment: The court held that the accused had sexual

intercourse with the victim in a state of fraud and thus the
consent of the victim is not a valid one and the accused
was held liable under Section 375.

Consent obtained under the false assumption of marriage:

Where sexual intercourse happens between man and
woman where she is made to believe he would marry her
but he fails to perform the promise would constitute the
offence of rape. 

Case Law
Dileep Singh v. State of Bihar (2004)
Facts: 

In this case, the accused forcibly had sexual intercourse

with the prosecutrix. He consolidated her by assuring that
he would marry her. After which she again had sexual
intercourse. The accused failed to perform his promise. A
suit was filed against him on the charge of rape. 

Judgment: False promise to marry her by the accused and

having sexual intercourse would amount to the liability of
rape. The court then accused never wanted to marry the
victim was merely a hoax. Thus the accused is liable for
the offence of rape.

Consent obtained under the misconception that the person

is the husband: If a woman gives consent to the person
believing that he is her husband in that scenario such
consent won’t be held valid and the person can be
charged with the offence of rape under the Indian Penal
Code. 

Consent is given by a girl below the age of 16: It is being

assumed that the girls below the age of 16 years are not
capable of giving valid consent. According to
Section375(6) if sexual intercourse is committed by a
person with or without the consent of the women would
amount to the offence of statutory rape. 

Earlier the age was below 16 years but after the criminal
amendment Act, 2013 the age is being increased to 18
years. 
Consent obtained when the woman is intoxicated is of an
unsound mind: A consent obtained during the state of
unsoundness and intoxication cannot be termed as valid
consent. 

Case Law

Tulsidas Kanolkar vs State of

Goa (2003)
Facts: In this case, the girl was not having a proper
mental condition to give consent for sexual intercourse.
The accused claimed the defence of valid consent. 

Judgment: The additional session judge holding the

accused liable of the offence ordered rigorous
imprisonment and a fine of 10,000. The High Court
reduced the imprisonment to 7 years. The Supreme Court
dismissing the appeal there was only mere submission
and no consent. 

Consent obtained by putting a person of interest under

fear of death is not a valid consent: If an interested
person of a woman like children, parents, husband, etc is
under fear of death and in that situation consent of a
woman is obtained then it cannot be termed as valid
consent.

Case law

State of Maharashtra vs
Prakash (1992) 
Facts: In this case, the police office r and a businessman
put the husband of the victim under remand where her
consent was obtained to have sexual intercourse. 

Judgment: The court held that consent given by the

women is not a valid one where a person of her interest is
put under fear of hurt or death. Therefore they were liable
for the offence. 

A person not capable of communicating consent: If a man

has sexual intercourse with a woman who is not able to
communicate her consent would amount to the offence of
rape. 

E.g. If A is and B has sexual intercourse believing that she

has conceived for the sexual act. Later A claims that she
didn’t consent to that act then B would be liable for the
offence of Rape. 

Punishment for Rape

The offence that is committed would be non-bailable, non-
compoundable, and a cognizable offence. That would lead
to an imprisonment of at least seven years and extend to
life imprisonment along with a fine. A person commits an
offence of gang rape, custodial rape would be liable for
punishment not less than 10 years extending to life
imprisonment and with a fine. 

Difference between without her

consent and against her will
under Section 375
There is a significant difference between an act committed
against the will and an act done against the consent of the
women. It is many times considered as they are
synonymous with each other but they are not. 

An act done by a person willing would mean that the

person has consented the act. While on the other hand an
act done with consent cannot necessarily be interpreted
as an act done with his will. 

E.g. A asked B to have sexual intercourse with him but

she declined it. Due to the constant pressure imposed by
A, B agreed. In that scenario, she consented but the act
was not done willingly. 

In Holman vs Queen, it was stated that it must not be

necessary for willingness to constitute consent. A woman
giving the consent would be reluctant, hesitant, and
grudging but she consciously permits then it is consent. A
consent given under protest and tears would still be
consent. For example, if a prostitute gives her consent for
having sexual intercourse not because of her will but
because of her constraint but her consent cannot be
turned as invalid. Consent is therefore valid even if it is
against the will. 

In the State of Uttar Pradesh vs Clottey Lala (2011), the

court stated that the expression against her will and
without her consent may overlap but they have different
connotations and dimensions, the expression against her
will would mean that that act is done by man despite her
resistance and opposition. The other without her consent
would mean an act done with deliberation. 
In Dileep Singh vs State of Bihar, the court has
interpreted as consent and will often interlace and an act
done against the will cannot be said as an act done
against consent. Under the Indian Penal Code, they are
two expressions under two different heads.  

From the above cases, the court has clearly explained the
difference between the two though they both are the
essential ingredient under Section 367(5) they don’t mean
the same. 

                    

Exceptions to Section 375 

There are two exceptions to the offence of rape: 

Exception 1 
A medical procedure or intervention shall not constitute
the offence of rape. This exception clause states that any
medical intervention against women cannot be termed as
an offence of rape under the court of law.

Exception 2 
It mentions that a man cannot be held liable under the
offence if he has sexual intercourse with his wife. The
section presumes that marriage is an implied consent
given by the wife to the husband. There is a provision to
this exception which mentions that sexual intercourse with
a wife below the age of 15 is not an offence. Recently in
Independent thoughts vs Union of India, the court
increased the age from 15-18 years. 
Case Law

Shree Kumar v. Pearly Karun (1998)

 Facts: In this case, a suit was filed against the husband
on the change of marital rape by his wife. At the time of
having sexual intercourse, they weren’t in judicial
separation. The court mentioned at the time of sexual
intercourse the wife was not living separately from his
husband such sexual intercourse doesn’t involve the
offence of rape. The husband was not held liable for the
offence and observed that rape within marriage is not
possible.

Landmark judgments under

Section 375 
Section 375 is one of the most-talked-about sections
nowadays due to the significant increase in the number of
rape cases in India. Some of the landmark cases are as
follows:

Rao Harnam vs Union of India (1957)

Facts: In this case, Kalu ram sent her wife aged 19 years
to please the accused. The girl protested against this act
of the husband but was later induced to surrender. The
accused ravished her due to which she died immediately.
The High Court observed that she surrendered her body to
the accused under the pressure of her husband therefore
the accused would be liable for the offence. 
This judgment is a landmark because it explains the
difference between consent and mere submission  the
high court while pronouncing the judgment held that 

A mere act of helpless, inevitable compulsion cannot be

deemed as consent. 

If the submission involves fear then the consent is not

free. The Mere act of submission doesn’t involve
consent.

consent is said to have been given by the woman if she

freely agrees to submit herself. It involves conscious
and voluntary acceptance of what is proposed to be
done.  

Mukesh & Anr. vs. State for NCT of

Delhi & Ors. (Nirbhaya Gang Rape
Case) (2017)
Facts: In this case, a young girl was returning home with
her male friend after watching the movie and boarded a
bus. Six people were there at the bus including the driver
firstly knocked on the guy with the iron rod then she was
brutally raped by all of them. Within 24 hours, they were
arrested. The Supreme Court while pronouncing the
judgment considered it as the rarest of the rare case and
ordered the death penalty to the offenders. 

This was a landmark judgment where the court observed

it as the rarest of the rare case and ordered them with the
punishment of the death penalty. 
This case also generated a lot of public outcries which led
to the formation of the JS Verma committee and various
suggestions were suggested and finally an amendment
was passed in the year 2013. 

Legal Changes 

Articles inserted were Section 354A(Sexual

harassment), Section 354B (Use of criminal force
against women), Section 354C (Voyeurism), Section
354D (stalking), Section 376E(Punishment of repeat
offenders) and Section 53A. 

Amendments were made in the various article where

Section 354 (Outrage women Modesty), Section 26
(Offence are triable), Section 160 (Information in
cognizable cases), Section 161 (Examination of
witnesses), Section 197(Prosecution of Judges and
Public Servants), Section 273 (Evidence in presence of
accused). 

Substitution of various articles of Section 375, Section

376, Section 376A, 376B, 376C, 376D.   

State of Maharashtra v. Vijay Mohan

Jadhav and Ors. (Shakti Mills Gang
Rape) (2019)
Facts: In this case, a 22-year-old photojournalist was
interning under English magazine in Mumbai she had gone
to the Shakti mills compound near Mahalakshmi in south
Mumbai the accused had tied her up with belts and
brutally raped her. They didn’t stop there. They took the
photos of the victim and threatened to release them. The
session’s court awarded the accused a life sentence. It
was further challenged by the victim and demanded the
death penalty. The appellant court held that the accused
would be liable for the death penalty if any leniency is
shown towards the accused it would create a mockery of
justice. 

The case is considered a landmark one because the court

highlighted the rarest of the rare case and awarded the
accused the punishment of the death penalty. 

Tukaram and Anr. v. State of

Maharashtra (1978)
Facts: In this case, Mathura was an 18-year-old orphan
girl who was called to the police station on an abduction
report filed by her brother. Mathura was kept late. She
was forcefully taken to the toilet and was raped by a
constable Ganpat and Molested by Tukaram they had
bottled the door from inside.

Judgment: In the sessions court the accused were

acquainted naming it as consensual sex. The decision was
challenged in the Bombay High court which reversed the
decision distinguishing between consent and passive
submission and claimed that there was no consent and
was a mere passive submission therefore they are liable.
In the Supreme Court, they were acquainted with their
charges and claimed that there were no marks and it was
a peaceful affair. This judgment of the Supreme Court was
heavily criticized thus after this judgment in an inquiry it
was held that marks in the victim’s body are not
important. 
Recently the case that shook the whole country is the
Nirbhaya rape case four decades ago the case that shook
was the Mathra rape case. This case highlighted the flows
existing in the existing criminal laws. A criminal law
amendment was passed to nullify the effect of the
judgment.

Legal Changes 

Changes were made in Section 376 of the Indian Penal

Code. 

Custodial Rape provision under Section 376(2) was

added. 

The Punishment was prescribed to a term not less than

10 years 

Section 228A Indian Penal Code was added not to

reveal the identity of the rape victims. 

Vishaka v. State of Rajasthan and

Ors. (1997)
Facts: In this case, a social worker named Bhanwari who
was contributing her effort in stopping child marriages was
allegedly gang-raped by five men though a complaint was
logged no investigation was initiated. 

Judgment: The trial court acquainted the accused due to a

lack of medical evidence. A public Interest Litigation was
filed on the issue of sexual harassment at the workplace.
The court decided to give the judgment on international
conventions right to work with human dignity is granted
under Article 14, 19, 21 of the Indian constitution. In this
case, certain guidelines were given by the Supreme Court;
it is popularly known as Vishaka guidelines. 

This case is a landmark judgment because this case leads

to the formation of guidelines on sexual harassment at the
workplace. Before this case, India didn’t have guidelines
for the offence of sexual harassment at the workplace.
These guidelines became legislation in 2013 in the name
of sexual harassment at the workplace Act, 2013. 

Legal Changes 

Formation of sexual harassment Committee. 

The committee should be headed by a women

employee of the NGO. 

The committee Should Guide the victim for further

course of action.  

                    

State of Maharashtra v. Madhukar

Narayan (1990)
Facts: In this case, the accused went to the hutment of
the prosecutrix and had forcible sexual intercourse the
victim tried to resist him. In his defense he claimed that
he had gone to the hutment because the lady engaged in
the business of illicit liquor. She also had an extramarital
affair.

Judgment:  The Bombay High Court refused to impose a

charge on the inspector. The Supreme Court held that the
history of the women should not be taken into
consideration and removed the inspector from his service.

This case was a landmark because the court gave an

important guideline that the history of the women should
not be taken into consideration. By the virtue of Article
141 of the Indian Constitution, it is still binding on the
lower courts. 

Independent thoughts v. Union of

India (2017)
Facts: A writ petition was filed in the Supreme Court
under Article 32 challenging the exception 2 mentioned
under Section.375 which claimed non-consensual sex with
wife above the age of 15 doesn’t amount to the offence of
rape.

Judgment: The court observed that there is an artificial

distinction made between married and unmarried girls
without any reasonable nexus. Forcible sexual intercourse
with wife leads to mental trauma. Therefore the court
finally increased the age from 15 to 18. 

This was a landmark Judgments it was one of the most

significant steps taken to criminalize marital rape which is
an exception under Section 375 and set a limit that non-
consensual sexual intercourse with wife below 18 years
would amount to the offence of rape  

Conclusion
There is a significant difference between will and consent.
There is a proper definition of consent under the Indian
Penal Code. On the other hand, the will is still not being
clearly defined. Due to no proper definition consent and
will is being interpreted as the same thing and therefore
the decision passed by the court is vague and no proper
justice is being served to the victim. Therefore there is a
dire need to introduce a formal definition of a will under
the Indian Penal Code. Section 375 of the Indian Penal
Code is one of the talked about sections due to the
increase in the number of rape cases in India in the
amendments brought in the past few years have brought
significant changes in the section but still there are quite
many existing flaws which need to be addressed. 

References
[1]https://www.merriam-
webster.com/dictionary/consent#:~:text=%3A%20permi
ssion%20for%20something%20to%20happen,consent. 

[2]https://www.merriam-
webster.com/dictionary/willing#:~:text=Definition%20of
%20willing,without%20reluctance%20a%20willing%20sac
rifice

(3] http://ili.ac.in/pdf/php.pdf. 

[4]https://blog.ipleaders.in/shakti-mills-rape-case/.

[5]http://ili.ac.in/pdf/php.pdf.

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+33 - FR (France)
+241 - GA
(Gabon)
+44 - GB (United
Kingdom)
+1473 - GD
(Grenada)
+995 - GE
(Georgia)
+233 - GH
(Ghana)
+350 - GI
(Gibraltar)
+299 - GL
(Greenland)
+220 - GM
(Gambia)
+224 - GN
(Guinea)
+240 - GQ
(Equatorial
Guinea)
+30 - GR (Greece)
+502 - GT
(Guatemala)
+1671 - GU
(Guam)
+245 - GW
(Guinea-bissau)
+592 - GY
(Guyana)
+852 - HK (Hong
Kong)
+504 - HN
(Honduras)
+385 - HR
(Croatia)
+509 - HT (Haiti)
+36 - HU
(Hungary)
+62 - ID
(Indonesia)
+353 - IE
(Ireland)
+972 - IL (Israel)
+44 - IM (Isle Of
Man)
+964 - IQ (Iraq)
+98 - IR (Iran,
Islamic Republic
Of)
+354 - IS
(Iceland)
+39 - IT (Italy)
+1876 - JM
(Jamaica)
+962 - JO
(Jordan)
+81 - JP (Japan)
+254 - KE (Kenya)
+996 - KG
(Kyrgyzstan)
+855 - KH
(Cambodia)
+686 - KI
(Kiribati)
+269 - KM
(Comoros)
+1869 - KN (Saint
Kitts And Nevis)
+850 - KP (Korea
Democratic
Peoples Republic
Of)
+82 - KR (Korea
Republic Of)
+965 - KW
(Kuwait)
+1345 - KY
(Cayman Islands)
+7 - KZ
(Kazakstan)
+856 - LA (Lao
Peoples
Democratic
Republic)
+961 - LB
(Lebanon)
+1758 - LC (Saint
Lucia)
+423 - LI
(Liechtenstein)
+94 - LK (Sri
Lanka)
+231 - LR
(Liberia)
+266 - LS
(Lesotho)
+370 - LT
(Lithuania)
+352 - LU
(Luxembourg)
+371 - LV (Latvia)
+218 - LY (Libyan
Arab Jamahiriya)
+212 - MA
(Morocco)
+377 - MC
(Monaco)
+373 - MD
(Moldova, Republic
Of)
+382 - ME
(Montenegro)
+1599 - MF (Saint
Martin)
+261 - MG
(Madagascar)
+692 - MH
(Marshall Islands)
+389 - MK
(Macedonia, The
Former Yugoslav
Republic Of)
+223 - ML (Mali)
+95 - MM
(Myanmar)
+976 - MN
(Mongolia)
+853 - MO
(Macau)
+1670 - MP
(Northern Mariana
Islands)
+222 - MR
(Mauritania)
+1664 - MS
(Montserrat)
+356 - MT (Malta)
+230 - MU
(Mauritius)
+960 - MV
(Maldives)
+265 - MW
(Malawi)
+52 - MX (Mexico)
+60 - MY
(Malaysia)
+258 - MZ
(Mozambique)
+264 - NA
(Namibia)
+687 - NC (New
Caledonia)
+227 - NE (Niger)
+234 - NG
(Nigeria)
+505 - NI
(Nicaragua)
+31 - NL
(Netherlands)
+47 - NO
(Norway)
+977 - NP (Nepal)
+674 - NR
(Nauru)
+683 - NU (Niue)
+64 - NZ (New
Zealand)
+968 - OM
(Oman)
+507 - PA
(Panama)
+51 - PE (Peru)
+689 - PF (French
Polynesia)
+675 - PG (Papua
New Guinea)
+63 - PH
(Philippines)
+92 - PK
(Pakistan)
+48 - PL (Poland)
+508 - PM (Saint
Pierre And
Miquelon)
+870 - PN
(Pitcairn)
+1 - PR (Puerto
Rico)
+351 - PT
(Portugal)
+680 - PW (Palau)
+595 - PY
(Paraguay)
+974 - QA (Qatar)
+40 - RO
(Romania)
+381 - RS
(Serbia)
+7 - RU (Russian
Federation)
+250 - RW
(Rwanda)
+966 - SA (Saudi
Arabia)
+677 - SB
(Solomon Islands)
+248 - SC
(Seychelles)
+249 - SD
(Sudan)
+46 - SE
(Sweden)
+65 - SG
(Singapore)
+290 - SH (Saint
Helena)
+386 - SI
(Slovenia)
+421 - SK
(Slovakia)
+232 - SL (Sierra
Leone)
+378 - SM (San
Marino)
+221 - SN
(Senegal)
+252 - SO
(Somalia)
+597 - SR
(Suriname)
+239 - ST (Sao
Tome And
Principe)
+503 - SV (El
Salvador)
+963 - SY (Syrian
Arab Republic)
+268 - SZ
(Swaziland)
+1649 - TC (Turks
And Caicos
Islands)
+235 - TD (Chad)
+228 - TG (Togo)
+66 - TH
(Thailand)
+992 - TJ
(Tajikistan)
+690 - TK
(Tokelau)
+670 - TL (Timor-
leste)
+993 - TM
(Turkmenistan)
+216 - TN
(Tunisia)
+676 - TO (Tonga)
+90 - TR (Turkey)
+1868 - TT
(Trinidad And
Tobago)
+688 - TV
(Tuvalu)
+886 - TW
(Taiwan, Province
Of China)
+255 - TZ
(Tanzania, United
Republic Of)
+380 - UA
(Ukraine)
+256 - UG
(Uganda)
+1 - US (United
States)
+598 - UY
(Uruguay)
+998 - UZ
(Uzbekistan)
+39 - VA (Holy
See (vatican City
State))
+1784 - VC (Saint
Vincent And The
Grenadines)
+58 - VE
(Venezuela)
+1284 - VG
(Virgin Islands,
British)
+1340 - VI (Virgin
Islands, U.s.)
+84 - VN (Viet
Nam)
 +678 - VU
(Vanuatu)
+681 - WF (Wallis
And Futuna)
+685 - WS
(Samoa)
+381 - XK
(Kosovo)
+967 - YE
(Yemen)
+262 - YT
(Mayotte)
+27 - ZA (South
Africa)
+260 - ZM
(Zambia)
+263 - ZW
(Zimbabwe)
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