BULLDOZERS, DISCRIMINATORY LAWS AND DEMONIZATION OF MINORITIES: COMMUNAL VIOLENCE 2022

Irfan Engineer and Neha Dabhade

The Hindu right wing weaponized Hindu festivals to foment communal rights in 2022, according to the monitoring of Centre for Study of Society and Secularism (CSSS) based on the reports that appeared in three English newspapers of The Hindu, Indian Express and Times of India. In the year 2022, these newspapers reported 40 incidents of communal riots in India.

This is 400% increase from 10 in the last year. While as far as the mob lynching incidence are concerned, there was no increase, as compared to the year 2021, which remained constant at 15 incidences reported in the three newspapers monitored. Out of the 40 incidents of communal riots, 19 took place owing to processions taken out by Hindu right wing organizations, a trend that continued from 2020 and 2021 when similar major communal riot took place in Indore, Mandsaur, Ujjain and Manawar in Dhar. Religious processions were used to masquerade in order to mount communal attacks. The communal riots targeted Muslims predominantly in the respective areas damaging, vandalizing and looting their property. Instead of controlling the riots, the response of the state was to further the objective of the rioters, viz., to inflict maximum damages on the Muslims. This was done by the state by demolishing their prime properties using state owned equipment like the bulldozers, JCBs and other heavy machineries, and falsely branding the Muslims as rioters and stone pelters, which according to fact finding reports of civil society organizations were baseless allegations. The state allowed demonization of Muslims and Christians and hate speeches against them, making them vulnerable to hate crimes, mob lynching and targets during communal riots. The narratives and hysteria created around conversions and inter-faith marriages have polarized communities along religious lines. These are the dominant emerging trends of communal violence in 2022 according to annual monitoring of CSSS. While communal riots and mob lynching are forms of physical violence, however, violence is more than physical violence, and includes structural violence and symbolic violence.

Structural violence:

According to Galtung, ‘violence is present when human beings are being influenced so that their actual somatic and mental realizations are below their potential realizations’ (Galtung, 1969). Galtung in his writings made a distinction between direct violence, structural violence and cultural violence. The understanding that emerges from Galtung’s ideas is that structural violence is similar to social injustice and the structures that promote this social injustice. It is an invisible force that is formed by the structures that prevent the satisfaction of basic needs. It usually expresses itself indirectly and has no directly visible cause. It occurs when people are influenced in such a way that they cannot realize their full potential possible.

When applied to the context of communal violence in India, structural violence can be construed as violence perpetuated by structures which prevent full realization of individuals as citizens and individuals. Individuals face discrimination and exclusion on the basis of their religious identity. Laws, policies, political institutions, unjust social conditions are included in structures. What is the significance of structural violence unfolding in India and its implications on society? The way structural violence is unfolding in India and that too at a rapid pace, it marks a transition from a civic nationalism in India to ethnic nationalism. The Constitution of India guarantees equality, liberty and fraternity to all irrespective of caste, sex, class and religion. The idea of citizenship in India is not based on religion but on the values of equality, acceptance and inclusion, which is civic nationalism. However, in the last few years, with the advent of laws, policies and overall changing nature of state institutions, there are steps taken towards establishing ethnic nationalism in India. Ethnic nationalism draws symbols selectively from one particular religion and upholds it to be superior or dominant over others. The Hindu right wing in India has been demanding the establishment of ‘Hindu State’. Hindu state is also the raison d’etre of RSS, the ideological parent of BJP, the ruling party in India. The state has been ushering laws and policies which actively promote discrimination and exclusion of marginalized groups- steps towards Hindu state.

Structural violence in India leading towards ethnic nationalism is also manifesting in the right ward shift and loss of independence of state institutions including the judiciary, the election Commission, state funded educational and research organizations, various commissions to protect the rights of women, minorities etc. The robust and independent working of these institutions ensures democracy and strong civic nationalism. The breakdown of these institutions or ineffectual actions is pushing further towards an ethnic nationalism. Ethnic nationalism is sought to be justified by a warped communal narrative. Different issues and narratives woven by the Hindu right wing have normalized violence and exclusion of the Muslims and Christians. Some of the prominent issues are as follows:

Anti-conversion Laws:

In the year 2022, continuing the trend observed in other states in 2021, four more states, namely-Uttarakhand, Karnataka, Himachal Pradesh and Haryana introduced or amended existing anti-conversion laws ironically called, “freedom of religion” acts. The objectives of the anti-conversion laws ushered in by states are twofold: firstly, to stop or create obstacles in the voluntary religious conversions from Hindu religion to other religions and not vice-versa. Secondly, the laws seek to criminalize people who want to convert into other religion from Hindu religion. Additionally, the laws and the propaganda of “large scale” conversions by Hindu right wing is used to justify and legitimize the attacks of state and non-state actors of pastors, prayer meetings, churches and houses of Christians, Muslim men and their families. It is worth noting here that the need for such laws don’t emanate from the grassroots. There is no data cited by the state to support such laws. It has no evidence of forcible conversions. On three separate occasions in 2021 and 2022, questions about the “danger” of religious conversions were posed in the Parliament- regarding forcible conversions for marriage and claims about large scale conversions of adivasis in the form of starred questions, but the government maintained the same stand that it doesn’t collect data on conversions (Arora, 2022)![2]

These laws essentially made religious conversion illegal and imposed stringent punishment maximum up to 10 years and fines up to INR 3 lakhs in some cases. The laws forbid change in religion through “force or allurement” and state that marriage for the sole purpose of conversion is declared null and void. The definition of the terms “fraud”, allurement” or “force” are so vague and broad as defined under these laws that it poses a threat to bring under its ambit also voluntary conversions and provides a weapon to the state to persecute innocent citizens who are not converting forcefully but out of their own will. The inter-faith couple that wishes to marry has to give the District Magistrate (DM) a prior notice of one or two months depending on the state. Similarly, those seeking to convert have to give prior notice to the DM.

While there is hysteria created by political leaders around ‘large scale’ conversions from the ruling dispensation claiming demographic changes, the census data shows no significant change in demographics. The legislations are used to criminalize Muslims and Christians. It is also used to legitimize the attacks on these communities. For instance, as many as 302 attacks against Christians took place in the first seven months of 2022 according to the United Christian Forum, which has collected data on the basis of distress calls it received on its helpline numbers (Pal, 2022).

In another incident, a group of Christian missionaries was allegedly attacked by more than 30 men armed with sticks two days before Christmas in Uttarakhand’s Uttarkashi district over reports of forced conversions (Indian Express, 2022). In another worrisome incident, between December 9 and December 18, there were a series of attacks in about 18 villages in Narayanpur and 15 villages in Kondagaon in Chhattisgarh displacing about 1,000 Christian Adivasis from their villages. The Christians are forced to take refuge in the open in the harsh winters. The other villagers were mounting pressure on the Christians to give up their faith and convert into Hinduism (Indian Express, 2022).

It is to be noted that the passing of the anti-conversion law in Karnataka was preceded by a Christian delegation opposing such a law meeting with the Karnataka Governor and appealing to him to not give assent to the bill. The delegation stated that the Christian community in Karnataka is against such a law. The delegation questioned the need for such an exercise when sufficient laws and court directives were in place to monitor any violation. Referring to the Fundamental Rights enshrined in Article 25 and Article 26, the delegation said that introducing such laws would infringe on the rights of citizens, especially of the minority community. Right on cue, recently, St Mary’s Church at Mysuru’s Periyapatna was vandalised two days after Christmas. The miscreants also damaged the statue of baby Jesus at the church (M S & Gautam, 2022).

In Uttarakhand in another incident, charges were slapped against Ravi Francis and his family members under the anti-conversion law when the members of the Bajrang Dal surrounded the house of Francis and alleged that forced conversion of Hindus inside the house in Dehradun in November. The Francis family however denied these allegations and explained that they were having a Sunday prayer with their guests from the Christian community and not carrying out conversions (Das, 2022).

Interfaith marriages or propaganda of ‘Love Jihad’:

The anti-conversion laws and the fabricated narrative based on allegations and conspiracy theory of Muslim men “luring” Hindu women into marriages to convert them have led to assaults on inter-faith couples by Hindu right wing organizations. Such laws and inaction by the state to protect them have made it very difficult for two adult individuals and citizens to marry a partner of their own choice. It especially undermines agency of women to step out of patriarchal institutions like families and exercise their choice to marry the person they want. Ironically, there is no data to prove the theory of ‘love jihad’ at state level or at centre.

In 2022, the public discourse was replete with the accusations of “love jihad”. The Shraddha Walkar case in Delhi in particular gave it an impetus in 2022. Shraddha Walkar and Aftab Poonawala, both hailing from Vasai, Maharashta were in a live in relationship in Delhi. Poonawala allegedly murdered Walkar and cut her body into pieces. Though the crime is condemnable and the culprit should get the appropriate punishment prescribed by law, the media and police machinery gave a communal spin to the case. Initially the police ignored the case but later it was not looked as a crime devoid of the religious identity of the accused and victim but the incident which was sharply communalized.

Because this case involved an inter-faith couple, the media and the state, used the case to amplify the narrative that Hindu women who marry or choose to live with Muslim men are not safe. The import was that Muslim men are a threat to Hindu women in particular and the society in general. While domestic violence and even murders are not uncommon in our society and not related to the religious identity of the spouses, the Hindu right wing and the state are manipulating these cases to demonize Muslim men and undermine the agency of Hindu women. For instance, according to the National Family health Survey 5, 24.4% of married women have faced physical violence between 2019 and 2021 in Maharashtra alone. But somehow these instances of violence and in extreme cases, murders are not highlighted by the media and political leaders. Does violence occur only in inter-faith marriages and not in marriages where both spouses are from same religions? In fact honor killings are not uncommon where family members of the spouses kill both the spouses. Domestic violence is a reality in Indian society sadly which too is not spoken about.

Not surprisingly, Maharashtra which doesn’t have anti-conversion law or laws barring inter-faith marriages, constituted an ‘Intercaste/ Interfaith Marriage-Family Coordination Committee (state level)’ to gather details about couples in interfaith marriages, and maternal families of such women if they were estranged after the Shraddha Walkar case. Later the state government amended its Government Resolution, saying the task of the committee will now be limited to gathering information about interfaith marriages, and not intercaste marriages. The new GR stated that the panel had been renamed ‘Interfaith Marriage-Family Coordination Committee (state level)’ and “it was under the government’s consideration to amend the committee that was set up”. Many dub this move as a first step towards introducing a law restricting inter-faith marriages in the state.

Demolitions as a form of collective punishment:

Razing down the properties of Muslims under different pretext has been a pronounced trend in 2022 drawing criticism from various quarters. The objective of the demolitions is that Muslims should not protest and exercise their democratic rights as equal citizen of the country. Demolitions are used to intimidate the Muslim community. Though the state has justified demolitions on different occasions by citing illegality of the properties, gradually a trend is emerging where demolition of houses is couched as a punishment for other alleged crime. Such arbitrarily demolitions which do not follow any proper laid down legal procedures or laws. In fact the Supreme Court in June observed that demolitions have to be in accordance with law and cannot be retaliatory. Yet the demolitions continued with alarming frequency and in almost all the cases without prior notices.

Demolitions in 2022, mostly targeting the Muslims, were undertaken by the state after communal riots which took place on the occasion of Ram Navami in the states of Madhya Pradesh, Gujarat and Jharkhand. Demolitions were also undertaken in Delhi after the riots that took place on Hanuman Jayanti and in Uttar Pradesh after protests against Nupur Sharma and her derogatory remarks against Prophet Mohammad. Ironically, Narottam Mishra, Home Minister of Madhya Pradesh, had stated that houses from where stones were hurled will be razed down and turned into rubble (Hindustan Times, 2022). However, the local administration where the demolitions have taken place has maintained that “illegal” structures were demolished and these demolitions are not connected with the riots or protests.

There are numerous accounts and reports by independent media houses, journalists and civil society organizations which point towards the arbitrary nature of these demolitions, some which continued even after stay orders from Courts. Different reports have pointed out that it’s improbable that stones were pelted from properties which were razed down since they were far away from the sites of communal riots. Also the properties of Muslims were selectively razed down. Though the popular narrative that was promoted by the state was that the house of the “stone-pelters” were demolished to upload law and give a strong message to them, there are testimonies and reports where the owners of the properties were either absent from the properties or too ill to indulge in stone-throwing or even disabled with no limbs! The state has targeted the Muslim community arbitrarily to silence it and muzzle it economically and morally. Heavy costs were recovered by the state from the Muslims under the pretext of recovering of damages caused during protests or riots while the Hindu right wing organizations that organize the processions and indulge in violence are let go scot-free.

Demolitions to Punish Protests:

In the state of Uttar Pradesh, in response to the derogatory remarks made by BJP spokesperson, Nupur Sharma, protests took place in different parts of UP. The state government in retaliation demolished properties of Muslims who the government alleged participated in the protests. Properties were especially targeted in Saharanpur and Kanpur, claiming they are “illegal constructions”. The Saharanpur Police razed parts of the gates and outer walls of houses of accused Muzammil and Abdul Waqir. In Kanpur, police demolished a property belonging to one Mohammad Ishtiyaq, who the police said, was linked to Zafar Hayat Hashmi, the main accused in the violent protests that took place in Kanpur on June 3. The UP Police arrested 230 people across the state in connection with the protests. The demolitions come on the heel of UP CM Adityanath’s instruction to the administration to take stern action against “anti-social elements” (The Wire, 2022). 

In Prayagraj, the authorities demolished the house of Javed Mohammad, an activist, who they claimed is the “mastermind” behind the protests against the derogatory comments of Nupur Sharma. Javed Mohammad was also arrested by the police. While the authorities claimed that they had served notice for demolition to the family following due procedure, the family members of Javed Mohammad have told that the administration stuck a back dated notice only the previous night before the demolition. Also Javed had no legal stake on the property since the property belonged to Parveen Fatima, Javed’s wife. The property was gifted to her by her father and stood on ancestral property (Rai, 2022).

Demolitions to punish Communal riots:

Communal riots took place in Gujarat, Madhya Pradesh, Rajasthan, Jahangirpuri in Delhi including other places on the occasion of Ram Navami and Hanuman Jayanti. The administration in these places demolished the houses of mostly Muslims claiming them to be “encroachments” or “illegal”. Though the narrative sought to be promoted by ministers like Narottam Mishra in MP was that the houses of stone pelters will be razed down, the local administration cited illegality of the properties and razed them down. Bulldozers and the demolitions have come to symbolize the weapon used by the state to force the Muslims to submit to the hegemony of Hindu right wing organizations which openly insult and provoke the Muslim community by targeting their mosques and raise derogatory slogans against the Muslim women.

In Khambhat, Gujarat, after the Ram Navami procession and ensuing communal riots, the local administration razed down small kiosks of poor Muslims selling operating small businesses on the road. In Khargone, Madhya Pradesh, the administration demolished shops of Muslims running small businesses and also demolished restaurants and bakeries owned by the Muslims. Approximately 45 properties were demolished. In Jahangirpuri, the demolition by the Municipal Corporation of Delhi targeted carts and small shops owned by Muslims. The women who mostly sold fruits, wares and other small products having hand to mouth existence were the most affected. Shockingly, even after the Supreme Court issued a stay order against the demolition, the administration continued with the demolition in violation of the stay order in Jahangirpuri. Civil society organizations and some political leaders protested at the sites of demolitions and also tried to stop the illegal demolitions but to no effect.

Other demolitions:

In Uttar Pradesh, in March, the police in Saharanpur district took a bulldozer to the house of two brothers, Amir (19) and Asif (22) who were accused of gangraping a minor girl on the pretext of marriage. A case against the accused was lodged based on the complaint of the girl’s mother. The police allegedly threatened the accused to surrender to the police by demolishing some part of their house (Sahu, 2022). It is worth noting that the nowhere else in India; persons accused of rape are subjected to demolitions of their houses. The law on rape in India doesn’t prescribe demolition as the punishment for rape. Further, the gruesome rape that occurred in Hathras in UP wasn’t met with the same action by the state as the accused was not Muslim.

 In a case which seems is motivated by feeling of personal revenge and abuse of position, sub-divisional magistrate, Gyanshyam Verma ordered demolition of a furniture shop owned by Zahid Ahmed, claiming it to be an illegal structure. However, the orders of demolition came after Ahmed asked Verma to pay a bill of INR 2.6 lakhs for the furniture that Verma bought from Ahmed’s shop.Verma was enraged with the bill and threatened to teach Ahmed a lesson. Ahmed was given only three day’s notice to vacate his shop. Also, while complaints had been received about several alleged encroachments in the area, Verma chose to demolish only Ahmed’s shop (The Wire, 2022).

In October, the Gujarat government demolished around 45 structures- mostly residential and commercial premises and mazars of Muslim community in Bet Dwarka, an island off Okha coast in Devbhumi Dwarka districtin Gujarat. The administration claimed that these demolished structures were “encroachments” on government land, freeing up to around one lakh square feet land (Indian Express, 2022) .

In Madhya Pradesh, the administration demolished 48 houses in Ramgarh district in May. The administration claimed that these houses were “illegal” and “encroachment” on government land but the demolitions came on the heels of a marriage procession of Dalit where stones were pelted on the procession when loud music was played in the procession while passing a religious place. Notices were served to the properties regarding their illegality merely hours before the demolitions (Times of India, 2022). Similarly, in a shocking incident, the Dindori district administration in Madhya Pradesh demolished the house and three houses belonging to the family of Asif Khan who eloped with Sakshi Sahu. Sahu’s brother filed a case of kidnapping against Khan and three days later razed three shops belonging to Khan’s family comprising an online service centre, a chicken shop and a tea stall, claiming they were constructed illegally. In the meanwhile, Sakshi Sahu went on record to say that she married Asif Khan out of her own volition (Ganguly, 2022).

Hijab controversy and denying freedom of religion and belief:

The restrictions on the use of the hijab in public spaces has fanned public debates in the country and to an extent polarized communities along religious lines. The restriction on the hijab was also used as a tool to target and deny freedom of religion to Muslim women. The colleges and universities in Karnataka demanding and imposing ban on hijab in the campuses against the wishes of the Muslim students meant that Muslim women students were compelled to choose between education and freedom to practice their religion, though the women students have argued that the hijab in no way interferes with their conduct or performance in educational institutions. Notwithstanding this reasoning, the state upheld that religious symbols are not allowed in educational institutions. An open letter, calling ban on hijabs in campuses in Karnataka as a ‘hate crime’ and amounting to “apartheid” against Muslim women, was signed by nearly 2000 academics, women’s groups, lawyers and civil society activists (Chandra, 2022). Some Muslim women students couldn’t take their exams or attend classes since they were not allowed to enter classrooms in hijab. This denial to education is detrimental to the already socio-economically marginalized Muslim community in India where the women face double discrimination owing to gender and religion.

Karnataka High Court order of March 15, 2022 had dismissed a challenge to a February 5 Government Order (GO) that mandated the use of uniforms in pre-university schools and colleges in Karnataka. In a split judgment on the issue of hijab in educational institutions, Justices Hemant Gupta and Sudhanshu Dhulia of Supreme court held diametrically opposite views on a gamut of issues ranging from the interpretation of reasonable restrictions of fundamental rights, the rights of the state vis-a-vis the fundamental rights of individuals and the right to education of young Muslim women.

Justice Gupta agreed with the Karnataka High Court verdict which upheld the ban on hijab. Justice Gupta stressed on the importance of discipline in educational institutions and that uniform in educational institutions is an equalizer. Religion, Justice Gupta said, had no meaning in a secular school run by the State, and the constitutional goal of fraternity would be defeated if students were permitted to carry their religious symbols to the classroom.

But Justice Dhulia stressed that to ask a pre-university school girl to take off her hijab at her school gate was an invasion of her privacy and dignity. It was violative of Article 19(1)(a) and Article 21 of the Constitution. She carried the right to her dignity and privacy inside the classroom as well. This right was not a derivative right. He also raised the critical issue that denying Muslim woman the right to education only because she wants to wear a hijab was handicapping her to face the challenges of life. He observed: “All the petitioners want is to wear a hijab. Is it too much to ask in a democracy? How is it against public morality, order or health? Or even decency or any other provision of part III of the Constitution.” Justice Dhulia said that reasonable accommodation was the sign of a mature society which has learnt to live and adjust with its differences, and added that the Karnataka High Court did not consider the question of diversity that the petitioners had raised but described it as “hollow rhetoric (Rajalakshmi, 2022)”. 

Justice Dhulia stressed that the question of diversity and rich plural culture was important in the present context of the case. Pre-university colleges were the perfect institutions where empathy, sensitivity, and understanding towards other religions, languages and cultures could be fostered, and when students could realise that diversity is the country’s strength.

The assault by Hindu right wing students groups wearing saffron stoles on Muslim women in Mandya demonstrated at the impunity they enjoy even in educational institutions. This assault is also an attack on the agency of the Muslim women who choose to wear hijab. The assault on Muslim women in college campuses by activists wearing saffron stoles has encouraged harassment of Muslim women making them soft targets. Aliya Assadi, one of the students protesting against the ban on hijabs reported that she was getting abusive calls from unknown numbers and some people also forcefully entered her house (Times of India, 2022). The family of another student, Hazra Shifa, who is protesting against the hijab ban in college in Udupi and approached the Karnataka High Court to allow Muslim women to wear hijab in college campuses, was not spared when her brother was attacked and a restaurant belonging to her father was pelted stones at by a mob (The Hindu, 2022).

The ban also accompanied by a slew of hate speeches. Pragya Thakur BJP MP, while stigmatizing the Muslim community said, “those who face trouble or are unsafe at their homes, need to wear the hijab there.  While outside, wherever there is ‘Hindu Samaj’, they are not required to wear Hijab, especially at places where they study. Wear hijab or khijab in madrasas, how does it matter to us? But if you disrupt the discipline of all schools and colleges across the country.. then it will not be tolerated” (Singh R. P., 2022).

Madrassas:

Vicious and unfounded myths are promoted by the right wing about madrassas alleging that they are places for indoctrination of ideas of fundamentalism and terrorism without basis or evidence. The state since the last few years has been in a process to de-recognize madrassas especially in Assam. Madrassas are still accessible educational options to a section of Muslim society which for various practical reasons are not able to send their children to other schools. Madrassas also teach religious tenets of Islam. Attacks on madrassas including demolitions of madrassas and de-recognizing them are to achieve twofold objectives: firstly to demonize the Muslim community and secondly to deny religious education to Muslim children. However, the Muslim children coming from marginalized backgrounds suffer the most as they are denied access to affordable education.

The National Commission for Protection of Child Rights alleged that government-funded and recognized madrassas are giving admission to non-Muslim students and imparting religious education. The Commission instructed all states and Union Territories to conduct a detailed inquiry into the allegations, including physical verification of such students at the madrassas. It also ordered mapping of madrassas which have not been recognized in order to find non-Muslim children studying at such institutions (Scroll.in, 2022).

Authorities in Assam’s Marigaon district in August demolished Jamiul Huda Madrasa under the Disaster Management Act and Unlawful Activities Prevention Act. The Madrassa was run by a cleric Mufti Mustafa who was arrested for his alleged links with a Bangladesh-based terror outfit, Ansarullah Bangla, an affiliate of Al Qaeda. Subsequently, around 2,500 private madrassas in Assam need to get any potential recruit for a teaching job from outside the state verified by the police as part of a government-monitored mechanism to prevent “jihadi elements” from slipping through (Kalita, 2022). The Assam government had also asked people to report to police if the imam (cleric) or teacher of a Madrasa in their locality is from outside (Singh B. , 2022).

In Uttar Pradesh, the state announced a survey to identify and document the “unrecognized” madrassas. The argument of the state is by conducting this survey; the state will “mainstream” these institutions and introduce subjects like Mathematics, English, Hindi and Social Sciences. This it claims will produce quality professionals (Kumar, 2022). After the survey was completed, 8,500 madrasas in Uttar Pradesh have been found to be functioning without securing recognition from the state madrasa education Board.

Further, keeping in with the myth that madrassas impart religious training which works against interests of India, the Registrar of UP Madrasa Education Board Registrar, issued an order in this regard to minority welfare officers in all districts of the state to make recital of national anthem “Jana Gana Mana” compulsory in all recognized, aided and unaided madrasas of Uttar Pradesh from May (Srivastava, 2022). The UP administration in July demolished a madrassa in Jebra village in Amroha after complaints from “non-Muslims” in the village that “namaz was being read over a loudspeaker”. The local administration alleged that the madrassa was illegally built on government land seven months ago (Dabas, 2022).

In Madhya Pradesh, the Shivraj Singh Chouhan-led BJP government has decided to scrutinize the study material of madrasas in Madhya Pradesh following complaints and reports about Hindu children not only having been enrolled in madrasas instead of schools but also being taught books containing objectionable religious content (Singh, 2022).

Nupur Sharma protests:

Nupur Sharma, BJP spokesperson, made derogatory remarks about Prophet Mohammad. There were nationwide protests demanding her arrests. However, she was merely suspended after the BJP ruled government came under criticism by the international community. At the same, the protests were responded with violence, demolition of properties owned by Muslims and arrests of Muslims. The killings that followed in Udaipur of Kanhanyalal Teli and Umesh Kolhe in Amravati in Maharashtra were highly communalized. The cases were handled by National Investigative Agency (NIA) likening the killings to terrorism and demonizing the Muslim community further.

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