Constitutionalism and the sacred cow: the secular mythology of the Indian Supreme Court

ABSTRACT

This article examines the judicial discourse around cow protection laws in India, tracing the trajectory of the Indian Supreme Court’s reasoning in cases where the constitutional validity of anti-cow-slaughter laws was challenged in post-independence India. The mainstream scholarship on Article 48 of the Indian Constitution has emphasised the existence of a religious motive behind this constitutional provision and its apparent justification through utility-based economic reasoning. However, most critical writings utilise a simplistic, binary formulation: religious versus secular. Through a close analysis of the judicial decisions in which anti-cow-slaughter laws were constitutionally challenged, the article proposes a move beyond the religious/secular divide and attends to the implications of the uneasy coexistence of the secular and the mythical. It further demonstrates that the invocation of the common law doctrine of presumption of constitutionality has acquired the status of what I term ‘secular mythology’ in the context of anti-slaughter laws.

KEYWORDS:

• Presumption of constitutionality doctrine
• anti-cow slaughter
• anti-cow-slaughter laws
• post-independence India

Acknowledgments

The author is thankful to Prachi Deshpande (Centre for Studies in Social Sciences Calcutta) for her comments on various previous versions of this draft. Latika Vashist (Ambedkar University Delhi) for suggesting amendments to the argument on the doctrine of presumption of constitutionality. Ashley Tellis for editing an earlier draft and his insistence on productively embracing the contradictions of law. Various comments on a shorter version of this paper presented at the Faculty Seminar at Jindal Global Law School proved useful in arriving at the final draft of the article. I want to particularly thank Mathew John, Vanessa Chishti, and Shivprasad Swaminathan for their suggestions.

Notes

1 Ronojoy Sen, ‘The Indian Supreme Court and the quest for a rational Hinduism’ (2020) 1 South Asian History and Culture 86; Ronojoy Sen, Articles of Faith: Religion, Secularism and the Indian Supreme Court (Oxford University Press 2010) 40–72. For a critique of the Indian Supreme Court on reason-oriented interpretation of religion, see J Duncan Derrett, ‘Freedom of Religion under Indian Constitution: Excommunication (based on Sardar ST Saifuddin Saheb v State of Bombay)’ (1963) 12 International & Comparative Law Quarterly 697.

2 Rajeev Dhavan, ‘When the judiciary rewrites a faith’ (The Hindu, 15 October 2018) <www.thehindu.com/opinion/op-ed/when-the-judiciary-rewrites-a-faith/article25221633.ece> accessed 11 June 2023. For a rigorous treatment of a similar argument, see Rajeev Dhavan and Fali Nariman, ‘The Supreme Court and Group Life: Religious Freedom, Minority Groups, and Disadvantaged Communities’ in BN Kirpal and others (eds), Supreme but Not Infallible: Essays in Honour of the Supreme Court of India (Oxford University Press 2000).

3 PK Tripathy, ‘Secularism: Constitutional Provision & Judicial Review’ (1966) Journal of Indian Law Institute 1, 18. For a different version of the same argument, see PK Tripathy, Spotlights on Constitutional Interpretation (NM Tripathy 1972) ch 2, 105. Tripathy argues that ‘asking the state to keep its hands off religion would amount to giving constitutional protection to social injustice.’

4 Peter Fitzpatrick, The Mythology of Modern Law (Routledge 1992) 10; Peter Goodrich, ‘Law and Modernity’ (1986) 49 Modern Law Review 545.

5 Fitzpatrick (n 4) 14. For Fitzpatrick, the Western enlightenment tradition defines itself in opposition to myth. However, myth has been incorporated into the foundational precepts of modernity. The ‘autonomous’ and ‘self-sustaining’ character of the law likens it to its mythic and divine counterpart, God. The omnipresence and omnipotence of the law is reflected in its claim to do anything, if not everything.

6 Throughout this article, ‘State’ with a capital ‘S’ is used to refer to the overall Indian state/governmental structure, while ‘state’ with a small ‘s’ is for the state law or the state governments of West Bengal, Maharashtra, etc.

7 For the ancient historical emergence of sacredness of the cow in the Hindu tradition, see W Norman Brown, ‘The Sanctity of Cow in Hinduism’ (1964) Economic Weekly 245 (Brown argues that the ‘doctrine of cow’s sanctity’ only emerged in the beginning of the Christian era. It was strengthened during the Gupta period around 4 CE and largely within the Brahminical circles.).

8 Sanford Levinson, Constitutional Faith (Princeton University Press 2011) ch 1; Ran Hirschl, Constitutional Theocracy (Harvard University Press 2010); Thomas C Grey, ‘Constitution as Scripture’ (1984) 37 Stanford Law Review 1. All these works demonstrate, from different vantage points, the profound similarity between the language of faith and the reasoning of constitutional law as discourses and symbolism of nation-states. For a different version of locating the vocabulary of ‘faith’ in legal positivism, see Peter Goodrich, Legal Discourse: Studies in Linguistics, Rhetoric and Legal Analysis (Palgrave Macmillan 1987) 32.

9 Michael R Anderson and Sumit Guha, Changing Concepts of Rights and Justice in South Asia (Oxford University Press 1998) 2. The authors highlight the drawback of existing legal history scholarship, in avoiding ‘the questions of doctrinal development’ in preference to ‘statutes as definitive expressions of the law rather than looking to judicial interpretation or doctrinal exegesis’.

10 In July 2018, the Supreme Court of India issued guidelines to curb the increase in cow vigilantism in the country. See Tehseen S Poonawalla v Union of India (2018) 9 SCC 501. For a critical analysis of lynchings of Muslims in India on account of eating beef, see Shabnum Tejani, ‘Cow Protection, Hindu Identity and the Politics of Hurt in India, c.1890–2019’ (2019) 3 Emotions: History, Culture, Society 136.

11 1959 SCR 629. The Supreme Court judgment uses the spelling ‘Quareshi’ which I have retained throughout this article while referring to this case. Rohit De uses ‘Qureshi’ in his book and I have used this spelling wherever I have referred to his work: Rohit De, A People’s Constitution: The Everyday Life of Law in Indian Republic (Princeton University Press 2018) 150.

12 The Supreme Court uses the term ‘progeny’ to refer to the inclusion of ‘bulls and bullocks’, as the male offspring of a cow, within cow slaughter bans. As will be discussed later in this article, bulls and bullocks fell outside the slaughter bans until 2005. However, in 2005, the Supreme Court approved a ban on their slaughter, arguing that a total ban on the slaughter of cows also includes all the progeny thereof.

13 (1969) 1 SCC 853.

14 (2005) 8 SCC 534.

15 The invocation of the doctrine of presumption of constitutionality has a long and complex history in Indian constitutional law. However, I will limit my analysis and argument with respect to its use by the Supreme Court while adjudicating on constitutionality of the anti-slaughter laws.

16 The Arya Samaj movement emerged in the northern provinces of the late nineteenth century colonial and undivided India. Its first branch was founded at Lahore on 24 June 1877. Soon it attained a prominent presence in Punjab and the United Province (now Uttar Pradesh). Its theological idea was premised on the supremacy and infallibility of Vedic wisdom and challenged idol worship and religious symbolism. Dayanand Saraswati died in 1883, and within a decade there was an official split in the movement. In 1893, the movement was split into two main divisions in Punjab. The first was the Gurukul Party, which founded the gurukul in Kangri, Haridwar in 1901. The other wing, under the leadership of Lala Hansraj and Lala Lajpat Rai, remained in control of the major institution established in the memory of Dayanand Saraswati in 1886: the Dayanand Anglo-Vedic (DAV) school system in Lahore. See GR Thursby, Hindu-Muslim Relations in British India: A Study of Controversy, Conflict & Communal Movements in Northern India (Brill 1975) ch 2; CS Adcock, The Limits of Tolerance: Indian Secularism and the Politics of Religious Freedom (Oxford University Press 2014) 17–18.

17 I use the notion of ‘ideology’ in the classical Marxist sense as false consciousness. The cow was a symbol of political resistance against the British on the one hand, and consolidated the Muslim as ‘enemy’ in the emergent idea of a Hindu nation on the other.

18 John Zavos, The Emergence of Hindu Nationalism in India (Oxford University Press 2000) 85–87.

19 The All India Hindu Mahasabha was formed in 1915 at Haridwar. It represented a coalition that formally came together to promote Hindu unity as a response to the formation of the Muslim League in 1906, as well as growing tensions between Hindus and Muslims. Previously, some Hindu sabhas (associations) existed in North India, such as the United Provinces Sabha and the Punjab Hindu Sabha, but this was eventually consolidated at an all-India level with the formation of Hindu Mahasabha. In 1930s, under the leadership of Vinayak Damodar Savarkar, the Mahasabha acquired a prominent place in the Indian political formation. For an extensive historical analysis of its early emergence, see Richard Gordon, ‘The Hindu Mahasabha and the Indian National Congress, 1915 to 1926’ (1975) 9 Modern Asian Studies 145. See also Prabhu Bapu, Hindu Mahasabha in Colonial North India, 1915–1930 (Routledge 2013).

20 Peter Robb, ‘The Challenge of Gau Mata: British Policy and Religious Change in India, 1880–1916’ (1986) 20 Modern Asian Studies 285; Anand Yang, ‘Sacred Symbol and Sacred Space in Rural India: Community Mobilization in the “Anti-Cow Killing” Riot of 1893’ (1980) 22 Comparative Studies in Society and History 576; Anthony Parel, ‘The Political Symbolism of Cow in India’ (1969) 7 Journal of Commonwealth Political Studies 179.

21 CS Adcock, ‘Sacred Cows and Secular History: Cow Protection Debates in Colonial North India’ (2010) 3 Comparative Studies of South Asia, Africa and the Middle East 297, 300 (Adcock argues that in assuming that cows are the unquestioned unifying symbol for Hindus, we ‘run the risk of denying agency to non-elites’ and suggesting a unity of faith in the Hindu community at large, for which there is no historical evidence).

22 Sandria B Freitag, ‘Sacred Symbol as Mobilizing Ideology: The North Indian Search for a Hindu Community’ (1980) 22 Comparative Studies in Society & History 597.

23 Gyanendra Pandey, ‘Rallying round the Cow: Sectarian Strife in the Bhojpuri Region, c. 1888–1917’ in Ranajit Guha (ed), Subaltern Studies II: Writings on South Asian History and Society (Oxford University Press 1983) 60–129.

24 ibid, 89–95.

25 De (n 11) 150.

26 Granville Austin, Indian Constitution: A Cornerstone of a Nation (Oxford University Press 1966) 82. Upendra Baxi also notes that Article 48 is one of the few articles ‘whose worthiness for enshrinement in the Constitution is open to question’. See Upendra Baxi, ‘The Little Done, The Vast Undone: Some Reflections on Reading Granville Austin’s The Indian Constitution’ (1967) 9 Journal of Indian Law Institute 323, 346.

27 Part IV is the charter of socio-economic rights, or positive rights, of the Indian Constitution. It must be contrasted with Part III, which is the charter of civil and political rights. While rights under Part III are largely negative rights and are enforceable as claim-rights against the state, Part IV is not enforceable, yet is ‘fundamental to the governance of the country’ (Constitution of India, art 37). On the importance of Part IV rights, see Rehan Abeyratne, ‘Socioeconomic Rights in the Indian Constitution: Toward a Broader Conception of Legitimacy’ (2014) 39 Brooklyn Journal of International Law 1; Latika Vashist, ‘Enlivening Directive Principles: An Attempt to Save their Vanishing Present’ (2010) 1 ILI Law Review 205.

28 The Constitution of India, art 37.

29 Pandit Thakur Dass Bhargava, a Constituent Assembly Member from East Punjab (now Punjab) remarked that the cause of cow protection is ‘sacrificed’ as the provision is not given the status of an enforceable fundamental right. See ‘Wednesday, the 24 November 1948’ in Constituent Assembly of India Debates, vol VII (Lok Sabha Secretariat, New Delhi 2014) 568 (Constituent Assembly of India Debates). I will not pursue the discussion of Article 48 (Article 38-A in the draft Constitution) in the Constituent Assembly in this article due to constraint of space. A brief reference will be made to the discussion wherever necessary.

30 ibid. Curiously, in this insistence on non-coercive persuasion for cow protection, Ambedkar surprisingly comes close to his historical rival Mohandas Karamchand Gandhi. Gandhi insisted, through the metaphor of ‘friendship’ (mitrta) with Muslim community, upon ensuring that cow protection be attained through non-violent and persuasive means and not enforced by law. Faisal Devji, ‘A Practice of Prejudice: Gandhi’s Politics of Friendship’ in Shail Mayaram, MSS Pandian, and Ajay Skaria (eds), Subaltern Studies XII: Muslims, Dalits, and the Fabrications of History (Permanent Black 2005) 78–98. For a contrary view on the Gandhian notion of ‘friendship’, see Gyanendra Pandey, Routine Violence: Nations, Fragments, Histories (Stanford University Press 2006) 177.

31 The theme of ‘scientific and sacred’ was entrenched in the Constituent Assembly debates on Article 48. One of the framers, Syed Muhammad Saiadulla, a Muslim Member from Assam, rebutted the arguments made by the proponents of the clause and highlighted this opposition. He described the debates as acquiring two fronts: the religious and the economic. His objection was based on the economic strand. To him, this meant that the ‘ingrained Hindu feeling against cow slaughter is being satisfied by the backdoor.’ Simply put, Saiadulla argued that the economic strand of arguments was just a way of sliding the religious arguments in through the ‘back door’. See Constituent Assembly of India Debates (n 29).

32 Those who pushed this provision on the grounds of pushing Gandhian philosophy upon the Constitution little noticed the Gandhian anathema to modern science or Western parliamentary forms of governance as opposed to indigenous alternatives.

33 Hanif Quareshi (n 11).

34 The Supreme Court noted that ‘species of bovine cattle’ is expansive enough to include ‘buffaloes’ within the slaughter. ibid [7].

35 UP enactment, sec 3.

36 On the caste and class composition of the 3000 Muslim petitioners, see De (n 11) 153.

37 ibid 150.

38 The text was later translated by Charles Hamilton in 1791. Charles Hamilton (tr), The Hedàya, or Guide: A Commentary on the Mussulman Laws (Premier Book House 1963).

39 The discourse of an essential practices test which espouses only central or integral aspects of religion as deserving of constitutional protection acquired a doctrinal form in Supreme Court decision of The Commissioner, Hindu Religious Endowments, Madras v Shri Lakshmindra Swamiar of Srirur Mutt, AIR 1954 SC 282. However, the idea of compulsory religious tenets acquiring constitutional protection appears in the Constituent Assembly. To illustrate, Seth Govind Das (a Member from then-CP & Berar, now Madhya Pradesh), during debates on Article 48 asked the Muslim members ‘to come forward to make it clear that their religion does not compulsorily enjoin on them the slaughter of the cow.’ Constituent Assembly of India Debates (n 29) 572. Syed Muhammad Saiadulla, a Muslim Member from Assam, acknowledged in response that ‘in my religious book, the Holy Qoran, there is an injunction to the Muslims saying … there ought to be no compulsion in the name of religion’. ibid 578. Although none of the Supreme Court decisions ever referred to this exchange from the Constituent Assembly, my point in this context is that the debate on the cow slaughter as central, compulsory, or essential appeared prior to the doctrine of essential practices in Indian constitutional law.

40 De (n 11) 154. For a discussion on status binary and hierarchy between ajlaf and ashraf Muslims, see Imtiaz Ahmad, ‘Endogamy and Status Mobility Among the Siddiqui Sheikhs of Allahabad, Uttar Pradesh’ in Imtiaz Ahmad (ed) Caste and Social Stratification Among Muslims in India (South Asia Books, 1978) ch 8. See also Gyanendra Pandey, ‘The Bigoted Julaha’ (1983) 18 Economic and Political Weekly 19.

41 Hanif Quareshi (n 11) [13].

42 ibid [14].

43 ibid [15].

44 Judicial deference to the laws made by the state legislature also emboldens the principle of separation of powers in the modern State.

45 Hanif Quareshi (n 11) [15].

46 ibid [45] includes a summary of conclusions by the Court (‘[W]e have reached the conclusion (i) that a total ban on the slaughter of cows of all ages and calves of cows and calves of she-buffaloes, male and female, is quite reasonable and valid and is in consonance with the directive principles laid down in Art. 48’). This point regarding the ban on cows of all ages requires emphasis, as some commentators have misread the case on this point. For instance, in an otherwise remarkable essay, De misreads the judgment when he comments with respect to Hanif Quareshi that the ‘[C]ourt did rule, however, that such a ban could not be absolute and that some categories of cattle, such as aged bulls or unproductive cows, may be slaughtered.’ De (n 11) 124. This reading is in clear contradiction with the text of Supreme Court judgment as quoted here.

47 ibid.

48 ibid.

49 ibid.

50 Pandey (n 23).

51 De (n 11) 166–67.

52 Mirzapur (n 14).

53 Uttar Pradesh Prevention of Cow Slaughter Act, 1955 (UP Act No 1 of 1956), as amended 1958.

54 Bihar Preservation and Improvement of Animals Act, 1955 (Bihar Act II of 1956), as amended 1959.

55 Madhya Pradesh Agricultural Cattle Preservation Act, 1959 (Act 18 of 1959).

56 (1961) 2 SCR 610.

57 ibid [3].

58 ibid [9].

59 ibid [7].

60 Madhya Pradesh Municipal Corporation Act, 1956 (Act 23 of 1956), s 430. Prior to this notification, the state’s by-laws permitted the slaughter of bulls and bullocks, along with buffaloes, sheep, goats, and pigs in premises which were fixed by the state government. The notification cancelled the by-laws to the extent that they related to bulls and bullocks.

61 Article 32 of the Indian Constitution vests the Supreme Court with original jurisdiction in cases regarding the violation of fundamental rights.

62 Faruk (n 13).

63 ibid [5].

64 ibid [6]. The reference to ‘restricted scale’ indicated that this was an executive order and not a piece of legislation or legislative amendment.

65 It is no coincidence that, in 1966, there was a collective demonstration of ‘several hundred thousand people in favour of a national ban on cow slaughter.’ DN Jha, The Myth of the Holy Cow (Navayana 2009) 19.

66 Faruk (n 13) [8].

67 The relinquishing of the presumption of validity in Faruq originated from the specific, contingent historical circumstances arising from the trend of state legislatures trying to subvert the ruling in Hanif Quareshi.

68 HM Seervai, for example, merely mentions this decision without any comment on the change of interpretive stance. HM Seervai, Constitutional Law of India: Volume I (4th edn, Law & Justice Publishing Co 2021) 837–38. MP Singh’s textbook also does not accord this decision the importance it attained in the context of Article 48 interpretation. Perhaps that explains its absence from the discussion on Article 48. See MP Singh, VN Shukla’s Constitution of India (12th edn, Eastern Book Company 2013) 132, 184, and 368.

69 Austin (n 26) 82.

70 Faruk (n 13) [8].

71 (1995) 1 SCC 189.

72 Even from a strictly legal standpoint, Hanif Quareshi was the wrong precedent to cite in this case, as there was no issue of the violation of specific fundamental rights.

73 Ashutosh Lahiri (n 71) [9].

74 Article 13 of the Indian Constitution prohibits any law that purports to take away or even abridge any constitutionally guaranteed fundamental right.

75 Mirzapur (n 14).

76 (1996) 4 SCC 391.

77 Madhya Pradesh Agricultural Cattle Preservation (Amendment) Act, 1991 (Act No 21 of 1991). This amendment added ‘bulls and bullocks’ under section 4(1) (a) of the 1959 Act. Prior to this amendment bulls and bullocks did not fall under the slaughter ban because their slaughter was permissible after obtaining due certification from the competent authority.

78 The case can be seen as part of a continuous attempt on the part of the state of Madhya Pradesh to bypass the age and usefulness formula set forth in Hanif Quareshi.

79 Hashmatullah (n 76) [22].

80 The Court noted that it was the state’s fourth attempt to entirely ban the slaughter of bulls and bullocks, even when they were of no further use.

81 Hashmatullah (n 76) [19]:

We are pained to notice the successive attempts made by the State of Madhya Pradesh to nullify the effect of this Court’s decisions beginning with Mohd Hanif's case and ending with Mohd Faruk's case, each time on flimsy grounds.

82 ibid:

It is obvious that successive attempts are being made in the hope that some day it will succeed as indeed it did with the High Court which got carried away by research papers published only two or three years before without realising that they … had nothing to do with the question of the utility of animals which have ceased to be reproductive or capable of being used as draught animals. Besides, they do not even reflect on the economical aspect of maintaining such animals for the sole purpose of dung. Prima facie it seems far fetched and yet the State Government thought it as sufficient to amend the law.

83 (1986) 3 SCC 12.

84 Bombay Animal Preservation (Gujarat Amendment) Act, 1979.

85 Haji Usmanbhai Qureshi (n 83) [17].

86 Mirzapur Moti Kureshi Kassab Jamat v State of Gujarat and Others AIR 1998 (Guj) 220.

87 ibid [65].

88 See Cassie Adcock, ‘Preserving and Improving the Breeds’: Cow Protection’s Animal-Husbandry Connection’ (2019) 42 South Asia: Journal of South Asian Studies 1141 (arguing that the universal plank of breed protection has historically been linked with violence in the name of cow protection); Cassie Adcock and Radhika Govindrajan, ‘Bovine Politics in South Asia: Rethinking Religion, Law and Ethics’ (2019) 42 South Asia: Journal of South Asian Studies 1095 (arguing that the Hindu cow protectionist orthodoxy pursue their cause as a universal ethical commitment eschewing the specific element of violence which appears in the political context).

89 ibid [41].

90 ibid [71].

91 ibid [39].

92 The difference between the two cases is that Faruk was concerned with an executive order, whereas the slaughter ban of bulls and bullocks was imposed through an amendment in this case. The methodological flaw lies in the application of the doctrine without engaging with Faruk (which is approved and not overruled here).

93 Mirzapur (n 14) [67].

94 Constitution of India, art 51(A(g)).

95 PD Burdon, ‘Ecological Law in the Anthropocene’ (2020) 11 Transnational Legal Theory 33; on the notion of eco-law, see generally Margaret Davies, EcoLaw: Legality, Life, and the Normativity of Nature (Routledge 2022).

96 Article 48-A of the Constitution reads, ‘Protection and improvement of environment and safeguarding of forests and wildlife. The State shall endeavour to protect and improve the environment and to safeguard the forests and wildlife of the country.’

97 Mirzapur (n 14) [50].

98 ibid [86].

99 James Staples, ‘Blurring Bovine Boundaries: Cow Politics and the Everyday in South India’ (2019) 42 South Asia: Journal of South Asian Studies 1127.

100 Adcock and Govindrajan (n 88).

101 Mirzapur (n 14) [83].

102 In his dissent, Justice AK Mathur struck a different chord. He questioned the bland description in the government of Gujarat’s affidavits which he asserted deserved to be taken with a ‘pinch of salt’ due to their internal inconsistencies. ibid [170]. Nevertheless, by majority, the Supreme Court posited a new law for the whole of India, when the material in the case was largely specific to the state of Gujarat.

103 ibid [22].

104 Adcock (n 21) 298. Adcock highlights a unique hurdle that legal historiography faces in ex-colonial societies because of the transplantation of an alien legal system. Adcock exposes the absence of any clear distinction between ‘religion’ and ‘secularism’ in nineteenth century India, as existed in the Euro-Western imagination. She outlines how the Arya Samaj relied upon the notion of ‘dharma’ in the nineteenth century India. ‘Dharma’ is a Sanskrit term which elides an easy translation in European language. This is because it, at once, inhabits the notion of material prosperity, righteousness, and salvation. The material and the spiritual are yoked together culturally. Adcock analyses the vernacular (Hindi) pamphlets and English language literature circulated by the Arya Samaj in the nineteenth century. She demonstrates that the dual idiom of ‘dharma’ was dextrously used in the speeches and writings of Dayananda Saraswati. He conveyed different meanings by using the same word. In the English literature of the Arya Samaj, written for the British colonial administration, the term strictly adheres to the material and utilitarian benefits of the cow. Whereas, in vernacular Hindi, a different meaning was conveyed which infused a religious flavour as well. The purpose of this exercise is not to attribute fraudulent intent, but to emphasise the ‘politics of translation’ of the mythic term dharma on a secular register. See CS Adcock, ‘Sacred Cows and Secular History: Cow Protection Debates in Colonial North India’ (2010) 3 Comparative Studies of South Asia, Africa and the Middle East 297.

105 Fitzpatrick (n 4) 36. (‘The profane is swept up into a sacred … as a project and a progression towards that resolution. For the perfection of beginnings in pre-modern myth is substituted the perfection of ending’).

106 ibid 46, 48.

107 On the effect of cow protection laws on caste groups and their protests, see Shivani Kapoor, ‘“Your Mother, You Bury Her”: Caste, Carcass and Politics in Contemporary India’ (2018) 3 Pakistan Journal of Historical Studies 5; Surinder S Jodhka and Murli Dhar, ‘Cow, Caste, and Communal Violence: Dalit Killings in Jhajjar’ (2003) 38(3) Economic & Political Weekly 174.

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Amit Bindal

Amit Bindal is a Professor at OP Jindal Global University.