If you’re a woman and you are sitting on a train so that others can see your crotch why is it worse to take a picture of what can already be seen?
She would be guilty of public indecency and parties in support also.
These ‘photographers’ put cameras on their shoes so they can see up your skirt while you’re standing next to them. You needn’t be flashing anyone publically. Just walking on a public sidewalk will do.