IMPACT OF RELIGION ON CRIME CAUSATION

Adv Sreelakshmi K S.

Member, Centre for Criminal law and practice

“In the name of religion, many great and fine deeds have been performed. In the name of religion also, thousands and millions have been killed, and every possible crime has been committed.” — Jawaharlal Nehru

In India, religion encompasses a diverse range of behaviours and beliefs that date back thousands of years. The word “religion” can be used to describe a wide range of distinct behaviours, convictions, and ideas. Hinduism, Jainism, Buddhism, and Sikhism are four of the world’s major religions that originated in India. Religion has had a significant role in the culture of the nation throughout its history. The nation’s laws and customs have established religious diversity and tolerance.

 According to the Indian Constitution, the country is a secular republic that must safeguard the freedom of its people to practice and spread any religion or belief. The Right to Freedom of Religion is a Fundamental Right according to the Indian Constitution. The word Secular was inserted into the Preamble by the 42nd Amendment Act of 1976. In S.R. Bommai v Union of India^[1], the Supreme Court of India held that Secularism was an integral tenet of the Constitution. Religion is a way of life in India. It is fundamental to Indian tradition. Religion affects every part of life for the majority of Indians, from routine daily tasks to politics and education.

India is a union of all the diverse religions in the world. All the religions ranging from Hinduism, Buddhism, Jainism, Sikhism, and Islam to Christianity can be found here. They also have their sects and sub-divisions. Despite this, there is still evidence of religious unity because every religion teaches its followers to behave morally and do good things. As a result, there is harmony among the various religions in society.

Religion has many positive aspects. Uniformity is one of the positive attributes of religion. There is closeness and intimacy among members of a single faith. It binds individuals together and creates a feeling of oneness in them.

Secondly, religion builds moral sentiments and values in an individual. These moral values define the person’s actions and thereby develop a personality. Religion regulates the conduct of people. Several thinkers including Karl Marx have pointed out that religion helps in social control by setting limits on conduct and laying out the rights and wrongs so that people do not act unethically.

But at the same time, it is also having negative shades. Crime in India originates from various sources of which religious practices and controversies are important sources.  It is a fact that all religions speak of communal harmony and peaceful co-existence but it is rightly said that most wars on this earth are fought in the name of religion. According to the Encyclopaedia of Wars, out of all 1,763 known/recorded historical conflicts, 121, or 6.87%, had religion as their primary cause. Matthew White’s The Great Big Book of Horrible Things gives religion the primary cause of 11 of the world’s 100 deadliest atrocities.^[2]

Constitutionally India is a secular state, but large-scale violence has periodically occurred in India since Independence in the name of religion. Organized religion can be said to be like organized crime, it preys on people’s weaknesses and generates huge profits for its operators, and is almost impossible to eradicate.

Negative aspects of religion are quite a few. Groupism is a main issue. Due to different ideologies and cultures, religions have caused a divide among the populations and have also grown from just being beliefs to favour people of their religion. Secondly, conflicts and riots. Since India accepts all religions, every society has different compositions of people from different religions and these differences in opinions have often taken the shape of rifts among people possessing diverse religions. Thirdly, religions do support superstitions. Finally, hinders social change. Religion often resists social changes. Religious people have a conservative mindset and always resist changes be it in religious views or customs.

With different groups of people having diverse religious backgrounds, there are several challenges faced. One such challenge is hate crimes. There is no single universally accepted definition of hate crimes, they are broadly defined as crimes that are motivated by some pre-conceived notions or biases about a community or a person. The community could be based on caste, religion, etc.  So, hate crimes are targeted crimes committed against persons belonging to these groups and are generally violent in nature.

Hate crimes can take various forms like communal riots, mob lynching, honour killings, cow vigilantism, hate speeches, etc.^[3]

Communal Violence in India

Communal violence is a type of violence that crosses ethnic or communal boundaries, when the perpetrators are motivated by a sense of allegiance to their respective communities and the victims are selected according to membership in the groups in question. The phrase refers to disputes, riots, and other acts of violence between groups belonging to various religions or ethnicities.^[4]

Historically, there have been many conflicts between different communities in India. Prior to independence, the nation had experienced the worst communal violence. In August 1893, Mumbai experienced one of the earliest significant racial riots, which resulted in roughly 100 fatalities and 800 injuries. A particularly challenging time was the years 1921 through 1940. The worst communal unrest in independent India’s history occurred in 1948 following the division. In the first ten years after partition, community violence on a large scale had significantly decreased. However, during the 1960s, the politics of conciliation and vote banking transformed this period of relative peace into one that was more violent. A thorough examination of communal violence in independent India would reveal that it started to persist after the 1960s.^[5]

The major incidences include the^[6]

• 1969 Gujarat riots – Religious violence broke out between Hindus and Muslims in Gujarat. It was the deadliest Hindu-Muslim violence since the 1947 partition of India. The violence included attacks on Muslim chawls by their Dalit neighbours. Some 660 people were killed (430 Muslims, 230 Hindus), 1074 people were injured and over 48,000 lost their property.
• 1984 anti-Sikh riots – After the assassination of Prime Minister Indira Gandhi
• 1992-1993: Babri Masjid demolition/ Bombay riots – In the UP city of Ayodhya, the iconic Babri Mosque was attacked and destroyed by Hindu rioters. An unresolved political and communal land issue that had persisted for ten years was finally resolved on November 2019 by a five-judge bench of the Supreme Court in a unanimous ruling.
• Godhra train burning, 2002 Gujarat riots – The burning of a train in Godhra on 27 February 2002, which caused the deaths of 58 Hindu pilgrims and karsevaks returning from Ayodhya, is cited as having instigated the violence. According to official figures, the riots ended with 1,044 dead, 223 missing, and 2,500 injured. Of the dead, 790 were Muslim and 254 Hindu. Many brutal killings and rapes were reported as well as widespread looting and destruction of property.

Bilkis Bano was brutally gang-raped during the communal violence that followed the Godhra train-burning incident. She was 21 years old at the time, and five months pregnant. Seven members of her family were killed by rioters. The Bilkis Bano case began in 2004. It was the first riot case to be transferred out of Gujarat to Mumbai by the Supreme Court. The 11 men were jailed in 2008 for life in the gang rape and murder case. The Supreme Court awarded Bano Rs.50 lakh as compensation in 2019. It was the first case and only case among the riot cases to see a monetary reward. The convicts were released in August 2022, coinciding with 75 years of India’s independence.^[7]

• 2013 Muzaffarnagar riots – The clashes between the Hindu and Muslim communities in Muzaffarnagar district of Uttar Pradesh, India in August–September 2013, resulted in at least 62 deaths including 42 Muslims and 20 Hindus, and injured 93, and left more than 50,000 people displaced.

The report of the Ministry of Home Affairs (MHA) states that there were as many as 3,399 cases of communal or religious rioting in the country in the five-year period from 2016 to 2020. The data revealed that there was a total of 276,273 cases of rioting during these five years of which 3,399 were of communal or religious nature. In 2020 there were 51,606 cases of rioting of which 857 were religious or communal.^[8]

Communal violence is one of the best examples where in the name of religion various crimes like murder, rape, property destruction, etc are committed.  All the above-cited incidents depict how religion has an impact on crime causation.

Mob lynching

Mob lynching is the act of a group of people circumventing the legal system in order to enforce what they believe is justice. Mob lynching has increased dramatically in India during the last few years. Many innocent people have been mercilessly tortured, and some have even died for no reason. Extremism, casteism, anti-nationalism, witch-hunting, class struggle, and political causes are only a few of the grounds for mob lynching. Mob lynching violence calls the rule of law into question since a group of people becomes the law, judge, and executioner.^[9]

Lynching occurs when a group of people kills a person accusing him of committing an offence that is frequently motivated by religious prejudices. When one community’s beliefs about an issue disagree with the views of the other, an unlawful act of mob lynching occurs as a result of the conflict. When people become incited by hatred and rage and prepare to impose their own laws, crimes like these occur. Based on the hatred that some people have for a particular group, religion, region, caste, or sex, this violence is referred to as hate crime.^[10]

While there are many factors that contribute to mob lynching, religion is at the top of the list. In India, in states like UP, Delhi, Rajasthan, Madhya Pradesh, etc cow related mob attacks are in large numbers. It is termed cow vigilantism. They display a form of religious extremism and target specific groups under the guise of cow protection. Mostly minorities are targeted.

The 104-page report of Human Rights Watch, “Violent Cow Protection in India: Vigilante Groups Attack Minorities,” states that between May 2015 and December 2018, at least 44 people – including 36 Muslims – were killed in such attacks.^[11]

Violence in the name of caste and religion is deep-rooted in India. Presently increasing mob lynching cases are mostly the result of intolerance and hatred towards other religions and castes in the name of professing, practice, traditions, and caw.

Recently increased Mob Lynching in India shows a strange barbarous behaviour of humans.

• Five Dalits from Haryana were slaughtered in 2002 on the rumour of cow slaughter.^[12]
• In September 2015, a Hindu mob lynched Mohammad Akhlaq and his son Danish in Bidara village, Uttar Pradesh, accusing them of stealing and slaughtering a cow-calf and storing the meat for consumption. This was the first case of a Hindu mob lynching a Muslim in the name of cow or beef (The Hindu, 2015). The incident, known as the Dadri Lynching, brought disgrace to the country.^[13]
• Mazlum Ansari (32), and Imteyaz Khan (15), were brutally killed in March 2016 by a mob known as ‘Gau Rakshak,’ who are cow vigilantes in Chatra, Jharkhand. They were suspected of cattle smuggling when, in fact, they were on their way to sell eight oxen at a cattle market.^[14]
• In June 2017, a Muslim boy who travelled with his two brothers was killed by a mob of Hindus after accusing him to a terrorist, Pakistani, anti-national, and a consumer of beef. ^[15]
• In August 2018, Rakbar was transporting cows on foot along with an associate. He was attacked by the VHP’s Gau Raksha on suspicion of being a cow smuggler. He died in police custody^[16]

According to a recent count, there have been 24 incidents of lynching and vigilante violence, resulting in the murder of 34 persons and rape of 2 women, in recent years mostly after 2015, most of the victims belonging to the minority Muslim community and Dalit community. The lynching gangs also threatened other minority communities in addition to the Muslim community. While incidents involving churches and priests accused of converting Hindus to Christianity persist, attacks on Christians are still infrequently reported. In Gujarat, seven Dalit family members were attacked by cow vigilantes in 2016, which sparked widespread Dalit protests. Mobs have historically attacked Dalits with physical violence, including rape, murder, and other types of assault. ^[17]

Mob lynching is thus another example of how religion acts as a crime causation factor. Brutal crimes like murder and rape are being perpetrated as part of this offence.

Honour Killing

In India, especially in the North, honour killing has long been a problem. Honour killing is the word used to describe the murder of a family member by other family members who feel that the victim has broken social norms and has brought shame to the family. Many teenagers in India have been murdered as a result of this crime to date. It’s because the idea that women are objects and commodities rather than human beings with inherent dignity and rights drives so-called honour killings.^[18]

Honour killings are mostly done in the name of caste, but there are reported incidents where it is committed in the name of religion. In May 2022, a man named Billapram Nagaraju was brutally killed.  The deceased and his wife belong to different religions and got married against the wishes of the latter’s family members. ^[19]

Hate Speech

In layman’s terms, “hate speech” refers to offensive statements that may endanger societal harmony and targets a group or a person based on intrinsic traits (such as race, religion, or gender). The UN Strategy and Plan of Action on Hate Speech defines hate speech as “any kind of communication in speech, writing or behaviour, that attacks or uses pejorative or discriminatory language with reference to a person or a group on the basis of whom they are, in other words, based on their religion, ethnicity, nationality, race, colour, descent, gender or other identities.^[20]

Hate speech has become more prevalent in today’s society especially those by politicians. The freedom of speech and expression guaranteed by the Constitution of India is misused or rather used to justify instances of hate speech. Some of India’s political leaders use their power and their words to spread hate, most often focused on fuelling class divides, Islamophobia, and communal hate. Politicians deepen existing divides when they use inflammatory language, such as hate speech, and this makes their societies more likely to experience political violence and terrorism.^[21]

A study by NDTV found that the use of hateful and divisive language by high-ranking politicians has increased by almost 500% in the past four years. Based on what the survey found, from May 2014 to the reporting date of April 2018, there have been 124 instances of VIP hate speech by 45 politicians.^[22]

Some recent instances of hate speech are^[23]:

• Tablighi Jamaat Markaz was the reason for the Covid-19 spike in Delhi: Arvind Kejriwal, CM Delhi. Kejriwal also issued regular updates on the number of ‘infections’ from the Jamaat. This added massive anti-Muslim hate across the National Capital. The consequences are still being felt.
• Parvesh Verma, Member of Parliament while campaigning for BJP during Delhi Assembly elections 2020. He referred to the anti-CAA protests saying, “These people will enter your houses, rape your sisters & daughters, kill them…”  Such words fuelled hate and Islamophobia and multiple fact-finding reports investigating the North East Delhi riots have held such hate speech responsible for fuelling the communal violence.

Superstitious Beliefs

Committing a crime on the basis of false or superstitious beliefs is an important one. Many of the practices trace their origin to religious beliefs, for e.g., Human sacrifice. Even though they are uncommon, India still practices human sacrifices. According to data from the National Crime Records Bureau (NCRB), 103 ritualistic sacrifices were carried out nationwide between 2014 and 2021. The year 2015 saw the most of these incidents, with 24, while the year 2018 saw the fewest, with only 4. Six instances of human sacrifice were reported in 2021, according to government records.^[24] According to NCRB data for 2021, 68 murders were committed for witchcraft, and six deaths were related to human sacrifices. In India in 2020, there were 88 deaths attributed to witchcraft and 11 deaths related to human sacrifices.^[25]

The various reported incidents are as follows:

• Couple killed two women in Kerala as “Human Sacrifice” and buried the chopped-up bodies. (October 2022)^[26]
• Assam police arrested five people in connection with a 2019 human sacrifice incident that happened close to the Kamakhya Temple in Guwahati. A 64-year-old woman Shanti Shawis was beheaded during the Ambubachi Mela. (April 2023)^[27]
• Human sacrifice ceremony Kills 4-Year-Old Child in UP. It was explained to the boy’s stepmother that the boy had to be sacrificed in order for her to have a child of her own. The stepmother was arrested. (June 2023)^[28]

Recent Judicial Interventions

Mob Lynching

In July 2017, the Supreme Court in the case of Tahseen s. Poonawalla v. Union of India^[29] laid down several preventive, remedial and punitive measures to deal with lynching and mob violence. The Supreme Court in this case aptly referred to mob lynching as a ‘horrendous (extremely unpleasant, horrifying, or terrible) act of mobocracy’ and asked Parliament to pass a law establishing lynching as a separate offence with punishment.

The following guidelines were laid down

• Designated Fast Track Courts: States were directed to set up fast track courts in every district to exclusively deal with cases involving mob lynchings.
• Special Task Force: The court had also mooted the setting up of a special task force with the objective of procuring intelligence reports about the people involved in spreading hate speeches, provocative statements and fake news which could lead to mob lynchings.
• Victim Compensation Schemes: Directions were also issued to set up Victim compensation schemes for the relief and rehabilitation of victims.

A year later in July 2019, the Supreme Court issued notices to the Centre and several states asking them to submit the steps taken by them towards implementing the measures and file compliance reports. As of now, only three states Manipur, West Bengal and Rajasthan have enacted laws against mob lynching.^[30]

Hate Speeches

The Supreme Court in Shaheen Abdullah v Union of India^[31] a bench of justices KM Joseph and Hrishikesh Roy said, “This is the 21st century. What have we reduced God to? Article 51 says we should have a scientific temper. In the name of religion (what is happening). This is tragic.”

The Court directed police and authorities to immediately and Suo motu register cases against hate speech makers without waiting for a complaint to be filed. Cases should be Suo motu registered and the offenders should be proceeded against in accordance with law. The action should be taken regardless of the religion of the speaker. The Court warned any hesitation to act as per the directions would be viewed as contempt of court and appropriate action shall be taken against the erring officers.

Honour Killing

In Shakti Vahini v Union of India^[32], the supreme court expanded the definition of honour crimes by relying upon the Council of Europe Convention on Preventing and Combating Violence Against Women and Domestic Violence, that any crime due to transgression of cultural, religious, social, or traditional norms or customs of appropriate behaviour by an individual is liable to be prosecuted.

The court issued detailed preventive, remedial, and punitive directions to deal with honour crimes which included identification of districts where honour killings are prominent, providing shelter for the couple for a month, banning unlawful assembly, taking appropriate departmental proceedings against officials, sensitization of law enforcement agencies, and setting up 24-hour helpline numbers among others.

Analysis

Religion was initially considered as a measure that keeps people together and brings unity. But nowadays it is being used or rather misused to divide people. The old divide-and-rule policy of the Britishers is being practised with religion as a weapon. It is being misused by certain ill-motivated persons to arise enmity between various sections of society. As a result, various crimes are committed in the name of religion which we already discussed. Thus, it is the need of the hour to control these criminal activities performed in the name of religion.

Apart from IPC provisions, there are no comprehensive legislations in India dealing with hate crimes. Laws in India does not recognize hate crime as a separate class of crimes but deal with them through already-mentioned provisions under the Indian Penal Code, of 1860.  Because they are not treated as specific categories of crimes the intention or motive with which these crimes are committed is not taken into account and most of the time fails to address the root cause of the commission of such acts.

Hate crimes can also be manifested or demonstrated as rape, harassment etc. which have penal provisions of their own but due to the lack of separate hate crime laws, they are not prosecuted considering the context in which they occur.

There have been attempts to bring specific laws:

The Communal Violence (Prevention, Control and Rehabilitation of Victims) Bill, 2005

Bill, 2005 provides for (a) prevention and control of communal violence, (b) speedy investigation and trials, and (c) rehabilitation of victims. The state government can declare an area as communally disturbed under certain conditions. The district magistrate or the competent authority appointed by the state government can take measures such as regulating assembly, directing persons to deposit their arms, searching premises etc. to control communal violence. The Bill provides double the punishment as provided by other existing laws. The state government shall establish special courts to try offences under this law. These courts may direct convicted persons to pay compensation to victims or dependents. Communal Disturbance Relief and Rehabilitation Councils will be formed at the national, state and district levels. The district council shall pay at least 20 per cent of the total compensation as immediate compensation to victims. It was withdrawn in 2014.^[33]

In India, there is no central law that exclusively deals with crimes related to witchcraft, superstition, or occult-inspired activities. There are state laws. Bihar was the first State to enact a law to prevent witchcraft, identification of a woman as a witch and eliminate torture, humiliation and killing of women. Similarly, other states like Jharkhand, Chhattisgarh, Assam, Maharashtra and Karnataka have also passed the act.^[34]

The Prevention of Witch-Hunting Bill 2016, was introduced in the Lok Sabha by MP Raghav Lakhanpal, but it wasn’t passed. It provides for punishments ranging from three months to life-imprisonment and a fine of Rs. 1000-50,000. Section-14 categorizes witch-hunting as a cognizable, non-bailable, and non-compoundable offence. State governments are also encouraged to provide free medical assistance to victims of witch-hunting under Section-22 and the victims’ right to free legal aid is reaffirmed by Section-24.^[35]

Kerala Prevention and Eradication of Inhuman Evil Practices, Sorcery and Black Magic Bill, 2019, was introduced but failed to get passed.  The Bill seeks to prohibit all forms of rituals that claim to summon dark and violent forces, including the use of violence to exorcise ghosts. The Bill criminalizes attempts to deny medical treatment to a suffering person in the name of religion or faith. Anyone claiming any kind of supernatural power will also invite the wrath of this law. It also prohibits isolating menstruating women^[36]

These were some of the failed efforts to bring specific laws.

The lack of official data on hate crimes is another major concern that goes unaddressed. According to the “Principal Offence Rule” used by the National Crimes Records Bureau among the various offences registered in a single case, only the most heinous crime will be considered as a counting unit, thereby representing one case. That is if lynching or any other such hate crime results in murder, all other crimes performed alongside it will be disregarded from the computation and only the murder offence would be registered.^[37]

National Crime Records Bureau (NCRB) collected data on cases of mob lynching and hate crime in 2017, but the exercise was discontinued as the data was unreliable. Nityanand Rai, the minister of state for the home, responded in writing to a question about why the NCRB left out information on mob lynchings, cow vigilantism, and hate crimes from its 2017 report. Because these offences, among other things, have not been defined, it was noted that the data was unreliable. As a result, data collection in this area was stopped.^[38]

Conclusion

Thus, there is a need to form a clear mechanism to prosecute specifically those who commit hate crimes and not to treat such acts as typical acts of violence. The incorporation of hate crimes into criminal law should be given careful thought. Recognizing hate crime as a separate type of crime is one of the strategies to combat it.

At the same time, it is pertinent to remember that bringing legislation to deal with these issues shall only mean half the battle won. The main fact lies in proper enforcement and implementation.

The judiciary nowadays is playing a tremendous role in dealing with the spectrum of hate crimes. Several directions and guidelines have been laid down by the judiciary in this regard. These directions have no teeth to tackle the menace of hate crimes in a complex, layered society like India without legislation to back them up.

A legal framework which covers all crimes in the name of so-called religion would ensure that the right of an individual is protected. So, in order to control the misuse of religion and religious beliefs, proper enforcement and implementing mechanisms should be employed. The persons who incite such communal clashes and feelings should be promptly punished and brought under the law.

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[1] S.R. Bommai v Union of India AIR 1994 SC 1918

[2] http://encyclopedia.uia.org/en/problem/161626

[3] https://www.drishtiias.com/daily-updates/daily-news-analysis/hate-crimes-in-india

[4] https://pwonlyias.com/upsc-notes/communal-violence/

[5] A detailed study on “Communal Violence in the Year 2021” by the Centre for Study of Society and Secularism

(CSSS), is attached as annexure-1 to this Joint Submission to HRC available at https://www.mha.gov.in/MHA1/Par2017/pdfs/par2022-pdfs/LS26072022/1544.pdf

[6] https://blog.finology.in/Legal-news/communal-violence-and-riots-in-india

[7] https://counterviewfiles.files.wordpress.com/2019/04/fact-sheet-bilkis-bano-case-april-24-2019.pdf

[8] A detailed study on “Communal Violence in the Year 2021” by the Centre for Study of Society and Secularism

(CSSS), is attached as annexure-1 to this Joint Submission to HRC available at https://www.mha.gov.in/MHA1/Par2017/pdfs/par2022-pdfs/LS26072022/1544.pdf

[9] Tanvi Yadav & Nagendra Ambedkar Sole, Mob Lynching in India: Sine Qua Non of Legal Intervention Volume 4, Asian Law & Public Policy Review, 298, 299 (2019)

[10] Ibid

[11] https://www.hrw.org/news/2019/02/19/india-vigilante-cow-protection-groups-attack-minorities

[12] https://nhrc.nic.in/press-release/killing-five-dalits-jhajjar-haryana-0

[13] https://time.com/4055298/india-beef-muslim-lynched-killed-cow/

[14] https://www.outlookindia.com/national/cow-politics-the-crisis-of-vigilante-justice-in-jharkhand-magazine-256891

[15] https://www.indiatoday.in/magazine/cover-story/story/20170724-lynching-india-beef-ban-muslims-india-jharkhand-delhi-mathura-1023999-2017-07-14

[16] https://indianexpress.com/article/india/alwar-lynching-police-took-three-hours-to-reach-health-centre-4-km-away-5270484/

[17] Tanvi Yadav & Nagendra Ambedkar Sole, Mob Lynching in India: Sine Qua Non of Legal Intervention Volume 4, Asian Law & Public Policy Review, 298, 299 (2019)

[18] https://blog.finology.in/Legal-news/honour-killing-in-india

[19] https://www.deccanchronicle.com/nation/crime/050522/inter-faith-marriage-man-killed-by-wifes-family-in-hyderabad.html

[20] https://www.un.org/en/hate-speech/understanding-hate-speech/what-is-hate-speech

[21] https://sundayguardianlive.com/news/hate-speeches-of-political-leaders-and-misuse-of-media

[22] https://www.ndtv.com/india-news/under-narendra-modi-government-vip-hate-speech-skyrockets-by-500-1838925

[23] https://sabrangindia.in/10-most-hate-driven-statements-indian-politicians/

[24] https://www.deccanherald.com/national/interactive-human-sacrifices-in-india-over-the-years-1154106.html

[25] https://www.insightsonindia.com/2022/11/01/where-does-india-stand-on-anti-superstition-and-black-magic-legislations/

[26] https://www.ndtv.com/kerala-news/in-kerala-human-sacrifice-couple-killed-2-women-buried-chopped-bodies-3421197

[27] https://www.ndtv.com/india-news/5-arrested-for-human-sacrifice-at-kamakhya-temple-assam-police-3920315

[28] https://www.ndtv.com/cities/4-year-old-boy-killed-in-up-human-sacrifice-ritual-stepmother-arrested-4120962

[29] Tehseen S. Poonawalla vs. Union of India and Others, (2018) 9 SCC 501.

[30] Jasrotia, Siddharth, Legislative Mechanism and Judicial Response to Mob Lynching in India: Diagnosis and Prognosis (2019). Nirma University Law Journal: Volume-9, Issue-1, December-2019, Available at SSRN: https://ssrn.com/abstract=3545894

[31] Shaheen Abdullah v Union of India, 2022 Live Law (SC) 872

[32] Shakti Vahini v Union of India, (2018) 7 SCC 192

[33] https://prsindia.org/billtrack/the-communal-violence-prevention-control-and-rehabilitation-of-victims-bill-2005

[34] https://theprint.in/opinion/state-anti-superstition-laws-not-enough-india-needs-a-central-law-focus-on-victim-not-crime/563439/

[35] Ibid

[36] https://www.thehindu.com/news/cities/Kochi/state-yet-to-come-up-with-a-comprehensive-legislation-to-curb-inhuman-evil-practices-sorcery-and-black-magic/article65997994.ece

[37] Jasrotia, Siddharth, Legislative Mechanism and Judicial Response to Mob Lynching In India: Diagnosis and Prognosis (2019). Nirma University Law Journal: Volume-9, Issue-1, December-2019 , Available at SSRN: https://ssrn.com/abstract=3545894

[38] https://theprint.in/india/governance/ncrb-stopped-collecting-data-on-lynching-hate-crime-as-it-was-unreliable-govt-tells-ls/785201/