Following the brutal gang rape and murder case in Delhi in December 2012 (the "Nirbhaya" case), there was a nationwide outcry for stronger laws against sexual violence. The Government of India constituted a three-member committee to recommend amendments to the Criminal Law to provide for quicker trials and enhanced punishment for criminals accused of committing sexual assault against women. This committee was headed by the former Chief Justice of India, Justice J.S. Verma, and its other members were Justice Leila Seth and Gopal Subramaniam. The committee's recommendations formed the basis of the Criminal Law (Amendment) Act, 2013.