Home > 2016 > A Tale of Elusive Justice

Mainstream, VOL LIV No 28 New Delhi July 2, 2016

A Tale of Elusive Justice

Friday 1 July 2016, by A K Biswas

Following the verdict in the Gulbarg Housing Society massacre, a television channel flashed as breaking news almost the whole day the Special Court’s observation imputing blame on the riot victim, former parliamentarian Ehsan Jafri that ‘his firing was the catalyst, infuriated the mob’.1 The communal violence claimed 69 lives including the former lawmaker himself. The case has captured the public domain for a long period. The riotous mob, said the Court, was not “really interested in causing deaths” but turned murderous after Ehsan opened fire at them. The Court went on record to state that the witnesses’ testimonies “are not sounding realistic or truthful”. Of 24 convicts in the case, 11 have been sentenced to life imprisonment for murder. Many may recall the Urdu couplet as very apt in the situation:

“Qatal kyon ho gaye, mujh pe ilzam hai

Qatal jisne kiya, hai vahi Muddai

Vakilon mein ab ye bahas chir gayi

Ye jo qatil ko thodi si zahmat hui,

Ye jo khanjar pe thoda sa kham a gaya

Is ka tawan kisse liya jayega.

(I have been accused of getting killed, killer is the complainant. Now the lawyers debate as to who will compensate the slight inconvenience caused to the killer and the slight bent caused to the knife.)”2

 According Section 96 of the Indian Penal Code, “Nothing is an offence which is done in the exercise of the right of private defence.” Section 97 IPC declares: “Every person has a right to defend:

1. His own body, and the body of any other person, against any offence affecting the human body; and

2. The property, whether movable or immovable, of himself or of any other person, against any act which is an offence falling under the definition of theft, robbery, mischief or criminal trespass, or which is an attempt to commit theft, robbery, mischief or criminal trespass.”

The verdict duly noted in the judgment that the mob “was largely involved in stone-throwing and attempting to burn and damage the vehicles, and properties of members of the minority community outside Gulbarg society.” The situation, speaking matter-of-factly, was justifiable for exercising the right of private defence by the victim in question under the Section of the IPC cited above. Of course, it is not known. if or whether the ex-parliamentarian had used a licensed gun in the right of his private defence while he fired on the frenzied mob engaged in destruction of private properties. His action to defend himself along with the lives of others and private properties is protected by law.

A popular film actor, Salman Khan, along with co-stars, was charged by a Jodhpur Court with poaching black bucks, a protected animal “on the night of October 1-2, 1989......”3 Speaking about the habitat of black buck, a British naturalist had written long ago that “..... it is common in the wooded parts of Rajputana, throughout the Bombay Presidency, the Central Provinces, and the northern parts of Madras....”4 Though the crime of poaching was committed at mid-past-mid-night (October 1-2), there were witnesses and the court inflicted punish-ment on the poacher on their testimonies. We loudly appreciate the importance the court attached to the protection of wildlife.

Paradoxically, on the other hand, the murderer of Jessica Lal, a model who, at Tamarind Court, Qutab Minar, Delhi was acting as bartender, was let off by the trial court though the crime took place in a crowded place in Delhi! She was shot dead at around 2 am on April 30, 1999 in the crowded bar for refusing to serve drinks beyond the prescribed hour of business. Dozens of witnesses pointed to Siddharth Vashisht, alias Manu Sharma, the son of Venod Sharma, a wealthy and influential Member of Parliament from Haryana, as the killer. On February 21, 2006, a Delhi trial court acquitted Manu Sharma along with all his accomplices for want of eyewitness to testify for the murder.5 Later the case, under intense public pressure and media hype, was reopened. On December 18, 2006 the Delhi High Court convicted Manu Sharma, Vikas Yadav and Amardeep Singh Gill alias Tony and acquitted Aloke Khanna, Vikas Gill, Harvinder Singh Chopra, Raja Chopra, Shyam Sunder Sharma and Yograj Singh.6 The law-enforcing agencies obviously were browbeaten to derail the legal process and frustrate the award of punishment. Presiding officers of courts, public prose-cutors and lawyers are like any other normal human beings susceptible to extralegal forces, external pressures, temptations, influences and suffer from the same weakness and aspirations. The Indian society, divided deeply by caste and communal affiliations, at large is full of pitfalls. The census returns of 2011 show that 4.2 lakh people were in prison in 2013. Muslims, Dalits and adivasis—three of the most vulnerable sections of the Indian society—account for 53 per cent of the prison population though they together are 39 per cent of India.7 Of the prison population, “nearly 20 per cent of them were Muslims although the share of Muslims in India’s population is about 13 per cent according to Census 2001.... Dalits make up 22 per cent of prisoners, almost one in four. Their proportion in population is about 17 per cent according to Census 2011. While adivasis make up 11 per cent of prisoners, their share in the general population is 9 per cent.”8 Disproportionate population in prisons of each group bears the hallmark of prejudice of the minuscule dominant sections against them.

According to Colin Gonsalves, human rights activist and lawyer, “Our system has an ingrained communal and casteist bias. Also, the proportion of these communities in the police officers and even judiciary is less. These are key factors behind this shocking imbalance.”9 If we take into account the custodial deaths across the country, we will find, without doubt, proponderence of SCs, STs and Mulsims as victims. During the colonial era down to 1964 (the year when the jury system of trial was abolished) when trial by jury was in practice, caste provided safeguard for certain sections of Indians. Acquittal of offenders belonging to those castes and communities in India was a certainty. The conviction of offenders of certain castes and communities, on the other hand, was a certainty too. Caste and communal bias is predominantly pronounced in every sphere, not excluding the police, judiciary and legislatures. What the census report 2011 has brought on record I would view the results, with long and sustained study and analysis of census reports since 1872 to 2001, as largely, sanitised.


Laxmanpur Bathe marks a Dark Era of Indian Nation

 Anti-Dalit Prime Minister in league with Ranvir Sena 

On the night of December 1, 1997 the Ranvir Sena, the savage “militia of upper-caste Bhumihar landlords of Bihar” marched to the village Laxmanpur Bathe on the river banks of Sone and accomplished an unprovoked genocidal massacre claiming the lives of 58 Dalits, men, women, children and old—including 19 men, 29 women and 10 children of whom one was one- year old, about 90 kms off Patna, Bihar’s capital.10 A Patna High Court Division Bench of Justices V.N. Sinha and A.K. Lal ruled that the prosecution witnesses “are not reliable” and the appellants deserved to be given the benefit of the doubt. The acquitted persons should be released forthwith if they were not wanted in any other case.11 A Sessions Court convicted 26 accused, sixteen of them with death sentence. Doubts of the Bench benefited the convicts, for example, Girija Singh, Surendra Singh, Ashok Singh, Gopal Sharan Singh, Baleshwar Singh, Dwarka Singh, Vijendra Singh, Nawal Singh, Baliram Singh, Nandu Singh, Sheomohan Sharma, Pramod Singh, Shatrughan Singh, Ramkeval Sharma, Dharma Singh and Nand Singh bringing them back from the jaws of gallows. Other beneficiaries were lifers.12 Veteran journalist Kuldip Nayar wrote in his column: “An upper caste judge has released all the accused on the plea that there was no evidence. It is a travesty of justice.... If the High Court judge did not find any evidence, he could have constituted a special investigation team (SIT) to work under its supervision to hold a fresh probe.... What has happened at Laxmanpur is the fate of Dalits all over the country. The equality before law, enshrined in the Consti-tution, is a farce.”13 The warning as also prognosis that the brutal treatment meted out to the Dalits of Laxmanpur Bathe happen to be the “fate of dalits all over India” and these are chilling and awe-inspiring. The dream of equality enshrined for all citizens under the Constitution stands shattered. What was his basis for issuing such a shattering note? President K.R. Narayanan had condemned the Laxmanpur Bathe massacre as “a national shame”.

A former High Commissioner of India to London and an ex-Member of Parliament, Nayar had consciously, without inviting contradiction, raised his finger at one of the judges on the Bench for acquitting his caste-men in Ranvir Sena from the gallows. The whole of Bihar knew who he was. He did precisely what the State Government of the day, despite monumental pressure exerted by that caste lobby, could not accomplish publicly for fear of political fallout. The acquittal seems to be a part of a long-drawn conspiracy hatched by political leaders of the ruling party against the Dalits who started slowly and gradually asserting themselves against feudal exploitation, caste oppression and subjugation. In a year-long sting operation code-named ‘Black Rain’, carried out by Cobra-Post, it came to light that after the command of the Ranvir Sena, founded by Dharichan Chaudhary of Bhojpur district in 1994 to counter the rising weave of assertion by the Dalit labouring class, passed into the hands of Brahmeshwar Singh, he turned it into a war- machine. Modern and sophisticated weapons were acquired by them from the Indian Army for using against the Dalits. Besides, the Ranvir Sena men were trained by Army jawans, either retired or on leave. Arms collected by the private militia included AK-47, LMGs, auto-matics, SLRs and Mausers etc., known for their enormous lethal power.

 Cobra-Post Associate Editor K. Ashis, who conducted the covert operation, caught six Ranvir Sena accused—Chandkeshwar alias Chandreshwar, Pramod Singh, Bhola Singh, Arvind Kumar Singh, Siddhnath Singh and Ravindra Chaudhry—on camera to speak and spill the beans. “Not only are they seen admitting to their roles in the massacre of 144 destitute Dalits that shocked the nation— Bathani Tola, Laxmanpur Bathe, Shankar Bigha, Miyanpur and Ikwari—but they also also reveal some of the Sena’s shocking strategies which failed to materialise, such as the plan to carry out up to 50 massacres in 50 different villages in a single day.”14

 The Ranvir Sena’s grand plan to carry out 50 operations against Dalits in 50 different locations simultaneously on a single day warranted a massive arsenal and large trained manpower. The Laxmanpur Bathe massacre was executed under the command of Chandkeshwar Singh who was acquitted by the Patna High Court in October 2013. “Chandkeshwar Singh confessed not only to his involvement in the Bathani Tola massacre in 1996 in which he claimed the private militia massacred 22 Dalits but also to have beheaded five low-caste fishermen with his knife.”15 Brahmeshwar Singh’s aide Siddhnath Singh disclosed to Cobra-Post the secret of the source and the manner of acquisition of arms and ammunitions by the Ranvir Sena. The weapons were obtained from Indian Army depots as rejects. According to Cobra-Post, the Ranvir Sena received “military reject” arms with the help of “the then Prime Minister Chandra Sekhar”. Siddhnath’s startling admission to the police: “... toh woh military ka rejected saman tha wahi hum logon ko uplabdh hua tha... hum kahe uplabdh hua tha jab pradhan mantri humare huye the... Chandra Shekhar... (...I told them we got them from Indian military as rejected lot... we got the arms when our Prime Minister... I said was Chandra Shekhar...).”16 In Bihar parlance and ethos, “jab pradhan mantri humare huye the” people understand simply “when our caste-man became the Prime Minister”. What a towering accomplish-ment of the fire-brand socialist and Young Turk of the Indian National Congress! Solemn and ceremonial oath of office and secrecy under the Constitution to work without fear or favour.... etc., etc. is not only meaningless but it fades away before caste interest. The arms were funnelled through Surajdeo Singh, an ex-MP from Dhanbad, who was close to Prime Minister Chandra Sekhar, both of Rajput caste.17

The Dhanbad MP alone did not provide muscle to the anti-Dalit buildup. The Cobra-Post also disclosed that Yashwant Sinha, the suave former bureaucrat (IAS) who was India’s Minister of Foreign Affairs and Finance, supported the Ranvir Sena both financially and politically. According to convict Promod Singh who too got reprieve along with others from the Patna High Court, “Bhajapa ka sarkar jiss samay tha ... Atal Behari Vajpai the ... uss samay the Yashwant Sinha ... barabar aate the... mukhiya ji se barabar milte the... wo toh humare gaon mein hi ... jiss samay chhapemari ho rahi thi uss samay barabar humare gaon mein the. (It was when there was the BJP Government [at the Centre]... there was Atal Behari Vajpai [as Prime Minister]... there was Yashwant Sinha... he would visit regularly... meet the Mukhiya [Barmeshwar Singh] regularly... he was there in my village when the police were hot on our heels and raiding our places.)“ We again get an affirmative double “Hoon, hoon” when we ask him if Yashwant Sinha knew what they were doing or what they were up to. What kind of support did they get from Sinha?18

Hatred against the Dalits was not confined to these few political leaders who held high positions in the government. The list of enemies and haters of Dalits was bigger. Justice Amir Das Commission, instituted by the Bihar Government in the wake of the Laxmanpur Bathe massacre was dismissed by Nitish Kumar whose party with the BJP as the coalition partner was voted to power in Bihar. Referring to the Ranvir Sena’s patrons and protectors, Justice Das said: “I can tell some names, for instance, Shivanand Tewari, C.P. Thakur, Murli Manohar Joshi and Sushil Kumar Modi.”19 C.P. Thakur was the Union Minister for Health and Family Welfare, Murli Manohar Joshi the Minister for Human Resources Development under Atal Behari Vajpayee and Sushil Kumar Modi the Deputy Chief Minister in the first Council of Ministers of the Government of Bihar headed by Nitish Kumar. About Shivanand Tiwari, known as a habitual “aya ram gaya ram”, even sober political leaders and senior journalists have lost count of the number of occasions of his floor-crossings.

The role of people’s representatives of Bihar merits notice in the context. Jehanabad MP Arun Kumar’s foolproof support to the Ranvir Sena cadres highlighted by the Cobra-Post, is particularly relevant. The MP would escort and ship out the underground Sena cadres in his car as and when they were cordoned by the police for arrest.20 A noble role in performance of public duty!

 Bihar People’s Party supremo and former MP Anand Mohan Singh, a notorious outlaw, threw open his arsenal to the Ranvir Sena. He has been serving a sentence for the murder of Gopalganj District Magistrate G. Krishnaiah in 1994. The Ranvir Sena men told Cobra-Post that “...Anand Mohan aaye bechare poora keh gya ki humare paas hathiyron ka jakhira hai jo jo hathiyar lena chahte ho aaker le jao. (... Anand Mohan came and told us that he has a cache of all kinds of arms. Whatever you need you can pick.)”21

Anand Mohan is a Rajput. Hardly any Rajput has a good word for Bhumihars who consider it blasphemy to speak a word in appreciation of Rajputs. They are perpetually at loggerheads. Since the pre-independence days, their mutual bad blood is known. But they solidly stood united against the Dalits.

Tahelka.com October 17, 2013, quoted Justice Das as saying that within 15-20 days of the formation of the government headed by Nitish Kumar in 2005 the Commission to investigate the Laxmanpur Bathe massacre perpetrated by the Ranvir Sena was scrapped.22 This was indeed one of the tallest achievements of the ‘vikas-purush’, a sobriquet with which the media, dominated by the same class, decorated the Chief Minister, who subscribed to appease the dominant forces operating against the Dalits. Mahadalit was his calculated ploy for harvesting electoral benefits. If and when capital punishment was awarded to the Dalit accused, their pleas and testimonies were rejected by the higher judicial authorities. In a massacre claiming several Bhumihars in Bara, for instance, the Gaya Sessions Court handed down death sentences to Nanhe Lal Mochi, Krishna Mochi and Bir Kuer Paswan, all Dalits. They have now been awaiting death after the Supreme Court has rejected their pleas. So, the formula for administration of justice is simple: If Dalits are killers of Bhumihars, sentence of death is a certainty for them. If, on the other hand, Bhumihars are the Dalit-killers, acquittal of convicts is a foregone conclusion.23 Evidence of Dalit witness, though strange it may sound, did not inspire confidence of the High Court. Laxman Rajvanshi, an eye-witness and survivor of the Laxmanpur Bathe bloodbath, reacted angrily when the High Court rejected their testimony, as unreliable: “How could I not have recognised them? We stay in the same village and I see them about 10 times a day! We worked on their fields. We had no inkling of this attack, otherwise we would have been alert.” Turning his focus on the Chief Minister, he continued in the same breath: “The Nitish Kumar Government is hand in glove with the feudal elements. He slotted us into the Mahadalit category, collected our votes and then cut our throats.”24 He has been in the infatuated company and embrace of the patrons, financiers, protectors of the Ranvir Sena all along.

Those with administrative experience of working in Bihar know too well that in any criminal or civil cases involving Dalit or tribal, on one side, and upper caste, on the other, the advocates engaged by the former often collude with advocates of their opponents to bring miseries for their clients. Medical officers hardly stand to testify truthfully in any case if Dalits vis-a-vis their upper-caste tormentors are concerned.

In cases where for a variety of reasons, including intimidation, domination or fear, truth does not come before the court, its presiding officer has the responsibility in the interest of justice to become proactive. The former Chief Justice of India, Vishweshar Nath Khare (tenure—December 19, 2002 to May 2004), was quoted by the British Broadcasting Corporation as saying:

“Sometimes when the police, the prosecution and the lawyers all have connections with the criminals, the judge should be slightly proactive. He should try to get to the truth, and not depend totally on the evidence provided in court. In a case like this, he is not going to get proper evidence. Mostly the judiciary is depended on the evidence provided by the investigative agencies, but now when the situation is so bad, the judges have to wake up, be proactive and find the truth.”25

The acquittal of convicts of the Laxmanpur Bathe massacre was perverse. The guidelines furnished by the former Chief Justice of India had no takers with the upper-caste judges, political leaders and Ranvir Sena being in tight embrace against the Dalits. The Apex Court could have intervened suo motu and frustrated the miscarriage of justice.26

Dalits and tribal are rarely considered as pressure groups.

We may cite the case of the massacre of 13 Dalits in village Tsundur, Guntur district of Andhra Pradesh on August 6, 1991. It runs parallel to the Laxmanpur Bathe massacre. A young Dalit graduate was beaten up for his feet uninten-tionally touched a Reddy man in the cinema hall. The Dalits of the village stood by their graduate. As a result Dalits were socially boycotted by the Reddy landowners of the village and were made to suffer enormously. Significantly Dalits collectively fought to gain legal justice by invoking the SC/ST Prevention of Atrocities Act 1989. The dominant Reddys and Telagas, encouraged by the police, attacked the poor Dalits. The trail court sentenced 21 accused to life imprisonment and 35 others to a year of rigorous imprisonment besides a fine of Rs 2000 each under the SC & ST (Prevention of Atrocities) Act 1989.27

On April 22, 2014 a Division Bench comprising Justices L. Narasimha Reddy and M.S. Jaiswal of the Andhra Pradesh High Court acquitted all the accused in the Tsundur killings.28 The Bench held that the prosecution failed to prove the exact time of death, place of occurrence and the identity of attackers. It said the trial in a criminal case was not something like a mathematical exercise where common minimum factors from various numerals could be taken to be put outside a bracket.

What a Division Bench of the Patna High Court did to the Ranvir Sena in October 2013 its counterpart in the Andhra Pradesh High Court did to the Reddy and Telegas six months later. Justice for the Dalit and deprived is dependent on the vagaries of the presiding officers.

In May 1987, the Maoist Communist Centre of India massacred44 Rajputs of Dalelchak and Baghora of Aurangabad district. The accused in the case were 75, one of whom absconded. FIR was lodged after 24 hours of the incident. And the case diary reached the court three days later.

The prosecution produced 30 witnesses, including the informant Rajballam Prasad Singh and minor Shailendra Kumar aged eight years, who too did not live in the village, that is, the place of occurrence. The informant, whose statement formed the basis of the FIR, was a resident of district East Champaran to the north of the river Ganges, some 300 kms from the place of occurrence in Aurangabad. He subsequently turned hostile! The Additional Sessions Judge awarded punishment solely on an eye-witness of the child who saw murders being committed in the light of the house on fire. The minor hiding in a gaushala, cowshed claimed to have witnessed the entire massacre. Eight accused—all Yadavas—were convicted and sentenced to death. The Additional Session Judge did not find any infirmities in his evidence. One would be reeling under shock and trauma to understand as to what actually is admissible to the court and what is not.

India boasts of justice done to Nirbhaya, who was raped and murdered on December 16, 2012 in a moving bus in the glittering Capital of Delhi. This was a tragic case indeed. Her father was quoted by CNN (The Cable News Network, Atlanta, Georgia, USA) as saying: “It shook the entire nation and led to public outrage on the streets. After seeing all that, we felt humanity still prevails on this earth.”29 Only the privileged can claim as such in this country. Portrayed as a brave heart,To India, Nirbhaya has become a symbol of bravery, courage and change” is the oft-repeated theme. It underscores an inherent insinuation as if victims belonging to other (particularly Dalit) castes do not protest or fight against their rapists or violators. Such depiction by upper-caste insensitive correspondents, either for the Indian or foreign media, is endemic in their despatches.

Jisha, a gutsy Dalit law student, was raped and murdered on April 28, 2016 in Kerala. Since 2005 the police was approached by her and her widowed mother several times alleging harass-ment, stalking, abuses against Jisha by neigh-bours, strangers and undesirable elements.30 The police took no action on their complaints. There has been inordinate delay even to register FIR. Detention of a suspect of murder after two long months of the the crime testifies the administrative and political attitude of the State to the victim. The caste factor, needless to stress, is prominent in both the cases. Nirbhaya got treatment per excellence everywhere because of her caste whereas Jisha was denied precisely for the same reason. The Kerala authorities have demonstrated an attitude marked by hostility to the Dalit victim.

Parliament was told sometime back by the Minister, Social Justice and Empowerment, that the conviction rate in cases of atrocities against Dalit and tribal communities was merely two per cent. Imagine about 50,000 cases of atrocities are registered annually with the police. Those who do not go to the police for com-plaining offence against them are much larger. We can imagine that cases of rape, murder, arson, and many serious complaints from the under-privileged never ever come before the courts for trial and administration of justice. No victims expect justice from the nation’s rulers and administration. Do the Dalits or tribal communities matter at all for the nation’s rulers and law-enforcing agencies? Do they matter for them except proving that India is a Hindu-majority nation before the world?

How shocking and traumatic it is to be told publicly that India’s Prime Minister empowered an anti-Dalit private mafia like Ranvir Sena with supplies of sophisticated arms and ammunitions from the Indian Army Depots! There were Union Ministers, Members of Parliament, Ministers of Bihar too in the league with the same conspirators! A whole govern-ment was harbouring, nurturing and nourishing a savage force. Nevertheless there have been no earthquakes in political and social life of the country against such nefarious designs. Those voted to power are hostile to the Dalits. They are friends of their enemies. The conscience of the countrymen is either dead or in a comatose state. In any other country, which does not have the caste system, the people would have perhaps rose in tumultuous rebellion against treachery and violation of the oath of office and secrecy of these men.

In their motherland Dalits and tribals, autochthonous 300 million, it is appropriate to state, are under enemy occupation with no hope of emancipation.


1. The Indian Express, June 18 2016

2. I am grateful for this to Abdul Qadir, an English language journalist stationed at Gaya, Bihar.

3. The Tribune, Black buck case: I was ‘falsely implicated’, Salman Khan tells Court.

4. Blanford, W.T. (1891), The Fauna of British India, Including Ceylon and Burma. London, UK: Taylor and Francis. pp. 521—4.

5. The Hindu, All accused acquitted in Jessica Lall murder case, February 22, 2006.

6. The Hindu, Jessica Lall murder case: Chronology of events, April 19, 2010.

7. The Times of India, “Muslims, dalits and tribals make up 53% of all prisoners in India”, November 24, 2014.

8. Ibid. 

9. Ibid.

10. National Herald, news item captioned “Death to 16 in Dalit massacre”, April 7, 2010.

11. The Hindu, October 9, 2013.

12. The Times of India, HC acquits 26 convicted of Laxmanpur-Bathe carnage, October 10, 2013.

13. Kuldip Nayar, “Signs of Fundamentalism”, The Statesman, Calcutta, October 24, 2013.

14. Gaurav Vivek Bhatnagar, The Wire, ‘Confessions from Bihar’s Killing Fields Set to Singe BJP, and Nitish Too’, August 17, 2015, http://thewire.in/8661/confessions-from-bihars-killing-fields-set-to-singe-bjp-and-nitish-too/

15. Cobra-Post, ‘Operation Black Rain: Revisiting the killings of dalits of Bihar and confessions of their killers’, updated: August 16, 2015. http://cobrapost.com/index.php/news-detail?nid=8983&cid=23

16. Gaurav Vivek Bhatnagar, op. cit. 

17. Ibid. 

18. http://cobrapost.com/index.php/news-detail?nid=8983&cid=23

19. Ibid.

20. Gaurav Vivek Bhatnagar, op. cit.

21. Ibid.

22. Nirala, Laxmanpur Bathe: ‘Some from the Nitish Kumar government were also involved,” Tehlka.com, October 17, 2013.

23. https://drambedkarbooks.com/2015/07/30/death-penalty-for-dalits-and-minorities-only/Ambedkar, Caravan.

24. Bhatnagar, op. cit.

25. BBC: India campaign for murdered Delhi model, March 9, 2006.

26. The Hindu, ‘Cobrapost film on Bihar dalit massacre expose BJP link’, August 18, 2015. V.A. Ramesh Narayan, general secretary of the National Dalit Movement for justice “called for the supreme Court to take suo motu cognisance of the evidence of the film to initiate trial against the accused”.

27. https://en.wikipedia.org/wiki/Tsundur_massacre

28. The Hindu, HC acquits all accused in Tsundur killings, April 22, 2014.

29. CNN, World’s Untold Stories, ‘Nirbhaya, victim of India gang rape fought for justice’, December 15, 2013.

30. Manorama, Jisha, a long story cut short, Friday June 17, 2016.

A retired IAS officer and former Vice-Chancellor, B.R. Ambedkar University, Muzaffarpur (Bihar), Dr A.K. Biswas can be contacted at e-mail: biswasatulk@gmail.com