?Following military coups in 1962 and 1988, multiple military regimes have ruled over Myanmar (formerly known as Burma). Widespread human rights abuses conducted by police and military against the general public and ethnic minorities are well known and documented. The year 2008 saw the creation and adoption of a new constitution through a controversial referendum followed by a flawed parliamentary election held in 2010. By-elections held in 2012 saw the opposition party, the National League of Democracy (NLD), enter Parliament for the first time, though with continued reports of election irregularities. Despite significant political change in Myanmar, legal reform, especially in the sectors of human rights protection and limits to police and military power, has been slow in development and implementation. Legal reform, judicial review, and military and police limitations on power and authority have yet to occur in a systematic and comprehensive way. As a result of slow reform, entrenched homophobic social attitudes, and unrestrained police authority to arbitrarily arrest and detain, members of the Lesbian, Gay, Bisexual, and Transgender (LGBT) community human rights abuses and discrimination are rampant..? Article 377 of the Penal Code deals with "Unnatural Offences"