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Arguing The Lethal Imaginaries of Terrorism And Methods of Its Tackling

Arguing The Lethal Imaginaries of Terrorism And Methods of Its Tackling - An Analysis Under Politico- Legal Framework

A worse crime against humanity is reflected in the death of innocent civilians. Over lakhs of innocent people are estimated to have been killed in India alone due to different terror strikes.
Terrorism is1not a new phenomenon in the world. Though the phenomenon was present for centuries and history has witnessed many assassinations of Kings and their allies by the rebellion groups, the last few decades witnessed the rising graph of terror strikes across the world. Undoubtedly, India is one of those countries worst affected by the curse of terrorism.2

Terror activities in different parts of the country forced the Government to take some serious steps. The establishment of specialized and dedicated anti-terror agency i.e. National Investigation Agency (NIA) is one of the landmark steps. Today, the modus operandi of the terror outfits has become more sophisticated and conclusive that required scientific and technological approach to tackle them. The NIA‘s way of

The intensity of Maoist movement, insurgency in Northeast region and Kashmir, Anti-India activities by the neighboring States like Pakistan and Bangladesh are some of serious threat to India‘s national
security. Pakistan-based terror outfits have been indulged into anti-India terror activities through their countless sleeping cells which are fully financed and protected by Inter Service Intelligence (ISI). In 1993, a series of bomb blasts in Mumbai in which more than 3000 lost their lives. Dropping of arms in Purulia (West Bengal) and reports of logistics support provided to some separatist organizations of North-east region by the Bangladesh and Myanmar are some example to show how terrorist groups are active in India. India has lost its prominent leaders , Mrs. Indira Gandhi and Rajiv Gandhi, in terror attacks. The Indian Airline IC 814 hijacking by the Pakistan based terror organization Jaish-e- Muhammad (thereby releasing some hardened terrorists including Maulana Masood Azahar) still afresh in our mind. The Mumbai terror strikes on November 26, 2008 on famous Taj and Trident Hotel besides, attack on Mumbai CST and a number of other terror attacks in Indian cities have shocked our conscience and our sensibilities. The national security, right to life of citizens and property is under threat due to constant terrorist strikes.

functioning is altogether different from its predecessor i.e. ATS, CBI and Special Cell etc. while tackling terror related cases. The NIA knows well that whenever terrorism strikes its victims are from both the communities i.e. majority and minority. Hence, it would be wrong to give a communal or religious color to any terrorist activity. Terrorism has no religion, caste or creed.

II. Identifying Terrorism
There are many definitions and explanations of terrorism. Terrorism is ‘a coercive intimidation‘.3 It is systematized use of destruction, and the threat of murder and destruction in order to terrorize individual, groups, communities or governments into conceding to the terrorists‘ political demands. It is one of the oldest techniques of the psychological warfare.4 Terrorism involves violent criminal activities for provoking terror or fear, and thereby achieving certain political goals.5

In Hitendra Vishnu Thakur v. State of Maharashtra,6 the Supreme Court opined:
It is possible to give a precise definition of terrorism by laying down what constitute terrorism. It may be possible to describe terrorism as use of violence when it‘s most important result is not merely the physical and mental damage of the victim but the prolonged psychological effect it produces or has the potential of producing on the society as a whole. There may be death, injury or destruction of property or even deprivation of individual liberty in the process but the extent and reach of the intended terrorist activity travels beyond the effect of an ordinary crime capable of being punished under the ordinary penal law of the land and its main objectives is to overawe the Government or disturb the harmony of the society or ‗terrorize‘ people and the society and not only those directly assaulted, with a view to disturb even tempo peace and tranquility of the society and create a sense of fear and insecurity.7

In the judicial exposition of terrorism, fear and intimidation becomes inherent contours of the terrorism. While Paul Wilkinson outlines the terrorism in three broad categories, namely, (i) revolutionary terrorism (aims at political revolution); (ii) sub-revolutionary terrorism (it has political motives but not the revolution), and (iii) repressive terrorism (it aims at restraining certain groups, individuals or forms of behavior deemed to be undesirable).8

Thus, any attempt at defining ‗terrorism‘ is bound to raise questions and disclose different contours thereof. Nevertheless, some of the lowest common denominations which are agreed upon world over about terrorism are:9
(i) Terrorism always involves a criminal act.
(ii) It involves the use of violence and element of spreading fear.
(iii) It focuses on choice of targets both animate and inanimate.
(iv) It declares reliance on the publicity rather than the events.
(v) Fight for an ostensible political/communal cause.
(vi) It does not follow the convention of war.
(vii) Maximum use of planned surprise.
(viii) It demands immediate action from the establishment.
The purpose of terrorism, obviously, is to wreak revenge and to draw attention to the demands of some aggrieved section.10

III. Growth of Terrorism: What Went Wrong?
Primarily the growth of the terrorism in India has been gifted to us due to ill- governance and bad politics of the political class. Some historical blunders had also been responsible for the rise of terrorism in India e.g. Kashmir issue brought by India in the UN forum despite the fact that it was a direct infiltration by the Pakistan army under the guise of tribal forces in 1948. It was also evident that former Prime Minister of India Jawaharlal Nehru hugely relied on Lord Mountbatten‘s advises and it was his advise that Kashmir issue should be resolved through UN, its mean we consider Kashmir was a disputed subject. India has been still paying the price of that historical blunder in the form of cross border terrorism.11

The earliest terrorist organization in pre-independence era seems to have been Chapekar Association of Maharashtra, founded by the Chapekar brothers sometime prior to 1897. Its existence came to light as a result of the murder of the plague commissioner of Bombay. Mitra Mela was started around 1899 by the Savarkar brothers and in 1900 developed into the Abhinav Bharat of Young India Society. The Society aimed at an organization modeled on the revolutionary societies of Russia. It had members in various parts of western India and a secret branch in Satara in Maharashtra. The investigation in connection with Nasik conspiracy exposed this Society. The Gwalior conspiracy led to the discovery of the Nav Bharat Society of Gwalior. Similarly, in Bengal there had been many secret organizations and Samitis and their important centers are Calcutta, Dhaca, Faridpur, Mymensingh, Chittagaong, Cooch Behar and Dinajpur. The umbrella organization of northern India, and also the most influential, was the Hindustan Republican Association, formed with the combination of Anushilan Party in north India. The objective of these organizations was to establish a federal India through the armed revolution.12

The growth of terrorism to a great extent has also been owing to communal politics of certain political class and organizations of the country. Different ideological sects, organizations, like RSS, Young India Society, Hindu Mahasabha etc, and different secret societies have been active since long and spreading communal venom in the community.13 M.S. Golwalkar, the RSS ideologue and popularly known as ‗Guruji‘ (master) of Rashtriya Swayamsevak Sangh (RSS), in his book, We and Our Nationhood Defined, had written about the approach the Hindu Rashtra should adopt towards its religious minorities: There are only two courses open to the foreign elements, either to merge themselves in the national race and adopt its culture, or to live at its mercy so long as the national race may allow them to do so and to quit the country at the sweet will of the national race. There is, he says, at least should be, no other course for them to adopt. Even if Golwalkar‘s proposal is accepted, it is well-nigh impossible to crush a huge minority of 12.4 per cent Muslims in India as of 2001. In Hitler‘s Germany, Jews were only around one per cent; so it was much easier to subjugate them. Even the Christian minority in India today is 2.3 per cent as per the 2001 Census. Attempts to forcibly subjugate these communities can only lead to the tearing apart of the social fabric which would be detrimental to the interests of even the dominant social forces because in such a situation, a regime of unhindered accumulation cannot be sustained.14

These communal ideologies movement have been working in both the communities i.e. majority and minority. But some of the historical events can‘t be rejected altogether which are wholly responsible for the rise of communalism in India that led to the problem of terrorism. Some of these incidents are appended below:-
1. Who is responsible for the partition of India-Jinnah had adopted the two nation theory and the theory had been propounded by Sawarkar but the RSS held Muslims responsible for partition.

2. Post-independence communal riots of 1947 that claimed lives of thousands of innocent people, but blame given to only Muslims.

3. Rise of the Hindu extremists‘ organizations, the RSS propagated its communal ideology and started its hate campaign against Muslims throughout India. Slogan likes Hindu-Hindi-Hindustan given by the RSS targeting the minorities.

4. Anti-Muslim riots happened in different parts of the country i.e. Ahmedabad, Meerut, Maliana, Hashimpura, Delhi, Mumbai, Bhiwandi, Bhagalpur, Neeli (Assam)-hardly anyone punished so far. Anti-Sikhs riots had taken place in Delhi 1984, no one is punished.
5. Ram temple movement and demolition of Babri Maszid in 1992.

6. Post Babri Maszid demolition riots in UP, Mumbai and other parts of the country in 1992-93.

7. Justice Srikrishna Commission appointed by the Govt. and the Commission indicted in its finding that some political leaders were involved in the mass murderers of innocent Muslims. The Report was not accepted and even, no efforts were made by the Union Government or State Government for its implementation.

8. Gujarat riots of 2002 and killing of more than 2000 Muslims, no one is punished.

9. Government had given free hands to all state police forces which encouraged fake encounters of Muslim youths.

10. Implication of Muslim youth in a false terror charges e.g. Samjhauta Express blast, Mecca Maszid blast, Malegaon blasts by the ATS and Special Cell.

11. There have been reports of various attempts of grabbing Waqf properties (Muslim Kabristan and Mosque) by the other community; riots had taken place due to land dispute between the two communities. No efforts were made to resolve the disputes through constituting special courts for Waqf properties disputes. The riots that had taken place recently at Forbesgunj, Mujjaffarnagar, Saharanpur and Gopalgarh are some instances of land dispute riots between the two communities.

12. In addition to above, different commissions, committees and recommendations had suggested some concrete and immediate action plan for the Muslims (considering them least developed minority community) as a step to ensuring social justice to them and bringing them into the mainstream development of the nation but nothing was done. For e.g. Justice Madan Commission Report, Gopal Singh Panel Committee Report, Justice Srikrishna Commission Report, Justice Rangnath Mishra Commission Report and Justice Sachhar Commission Report etc., are never implemented.

Had there been no incidents of miscarriage of justice against minority community, there would not have any incidents of terrorist activities in India. Would government or political class care to explain why no action has been taken against the perpetrators of atrocities against minorities? Not a single politician has been punished so far for the demolition of Babri Maszid. Perpetrators of Mumbai and Gujarat riots are still at large. Not a single politician has been punished for anti-Sikh riots of 1984. It is pertinent to mention that the police had even not filed any charge- sheet in the 1984 anti-Sikh riots.15 The communal organizations have been working on the sole agenda to portraying the image of Muslims community as anti-nationalist. Moreover, instead of ascertaining the root causes of terrorism, the electronic media has been indulging in anti-Pak jingoism and politician-bashing for security lapses and started to play blame game with each other. The police and armed forces have been painted in larger-than- life images. The stereotyping and stigmatizing of the Muslims has also proceeded apace. The paranoia about security and intolerant attitudes has reached unprecedented heights. One would well wonder if we are going to have a paranoid society in the near future.

In a talk on terrorism, formerly Professor of Punjab University, S S Bindra, was insistent that one must look into the demands of the terrorist/militant organizations and their desire to sacrifice their lives for the community. One must need to understand that well before the assassination of Mrs. Indira Gandhi; she had ordered the Operation Blue Star at Golden Temple in the first week of June, 1984. In consequences, various Sikhs militants‘ organizations mobilized and they also got logistics support from the Pakistan. These organizations like Babbar Khalsa International, Khalistan Jindabad Force etc formed in reaction to what happened in June 1984 at Golden Temple and their only agenda is, to make a separate state i.e. Khalistan (Holy Place for Sikhs).16 Likewise, some misguided youths from the Muslim community too joined radical organization after the demolition of Babri Maszid and Gujarat riots episode. The demands of all terrorist organization are that they did not get justice and are still being victimized by the state agencies.17

India has one of the poorest records in punishing those guilty for killing people in the name of religion. There is no closure for families as cases have lingered on for more than 20 years that causes anguish and hatred against the establishment. Dr Riaz Ahmed of the Delhi University rightly says that terrorism is the ‗desperate reaction of a desperate people‘. Terrorists are crying for attention towards issues like the gross violations of collective human rights in Kashmir and justice to the victims of the carnage in Gujarat.18

IV. “Their Terrorism-Our Terrorism”- The Lethal Imaginaries
Is there any link between religion and terrorism? First of all, there is no link between the duos. The terrorism is a faceless menace and has no religion. However it is a worrying phenomenon that desperate attempt was given to Islam after the 9/11 episode thereby creating Islamophobia throughout the globe.The war on terrorism was targeted towards Muslim aiming to put the community in a bad light and portraying them as cruel and jehadis (fanatics). A section of Indian political class and a small chunk of media too have tried to associate Islam with the terrorism. There had been some slogan after every terror attack like Not every Muslim is a terrorist, but every terrorist is a Muslim . So long there was no problem when terrorism associated with the Islam but as soon as Hindu terrorism is used, it has become difficult to digest.19 If every Muslim is a terrorist, has Swami Aseemanand and Sadhvi Pragya Singh Thakur converted to Islam? Why there is an ambiguous silence in the media and political class on the arrest of Sadhvi Pragya Singh Thakur, Swami Aseemanand, Lt. Col. Srikant Purohit, self-styled Godman Sankaracharya Dayanand Pandey for their involvement in bomb blasts in different parts of the country.

Unfortunately, instead of facing the real challenges to the national security implications, the reactions of the political class to the latest terror revelations have oscillated between denial and demonization.20 It is to be noted that Himani Savarkar21 had justified certain activities of the Abhinav Bharat leaders stating that if we can have a bullet for a bullet why not a blast for a blast . She gave a clean chit to all the members of Abhinav Bharat.22 There have been demands of re-investigate every recent blast case and to release the accused from the minority community. While in some instances there has been a genuine miscarriage of justice, to suggest that Muslims have been victimized in every case is to reveal a complete lack of faith in the judicial process, one that can only wide the communal chasm. There has been a legitimate suspicious of the claim advanced by various police forces (ATS of different States and Special Cell of Delhi Police) about their successes in the fight against terror. One simple fact should illustrate why suspicious is well founded: take the example of Samjhauta Express bombing; the police declared with great authority that bombers were Jihadis acting under the instructions from Pakistan. Now we come to know that real perpetrators were Hindus who the NIA has in custody.23 The new avatar of radical Hindus outfits in the name of Abhinav Bharat and others put India into an embarrassing situation. Not surprisingly, Pakistan has chosen to exploit our embarrassment for its own propaganda purposes.

Similarly we came to know that the real perpetrators of Hyderabad‘s Mecca Maszid blast were members of the Abhinav Bharat. Since, we had officially described the attack as handiwork of the Lashkar. But now after NIA‘s finding, it has been done by the Hindutva hardliners. More amazingly, some political leaders openly supported the acts done by Abhinav Bharat. The truth is that partisanship of any kind must have no place in the war against terror. When BJP president Rajnath Singh visits Malegaon blast accused Sadhvi Pragya Singh Thakur and claims that she is innocent and is being harassed by the state government, he is taking a political stance incompatible with the rule of law. But the BJP cannot take the same line that when cops arrest so- called Muslim terrorist, they are never to be challenged. Its only when cops arrest Hindus that we can accuse them of framing the suspects! We can now see what the BJP‘s message to the police really is: arrest all the Muslims as you want, we will back you unthinkingly. But if you dare to arrest Hindus for terrorist attack, we will attack you from the highest platform. That shameful double standard exposes the hypocrisy and prejudices at the root of the party‘s approach towards terrorism.

It is needs to be understood that the terrorism cannot be associated with any one religion. Terrorism is a crime against the humanity that needs to be erased. But this cannot be done by targeting any one specific community as this, apart from being patently unjust, can only be counter-productive by creating the atmosphere that breeds terrorism‘s recruits. In India‘s case, the victim of terrorist attack have been of such a diverse range that the terrorist cannot be straight jacketed into any single religious group. We have experienced the agonies of attacks on Muslims, Sikhs, Christians, Tribals, Dalits and Hindus, we lost two Prime Ministers through the terrorist assassinations, and Mahatma Gandhi himself was a victim of terrorist bullets.24

V. Strategy to Deal with Terrorism: The Ground Realities
It is true that India has been facing countless constraints in combating terrorism. In the absence of any specialized or dedicated investigative agency, the task of investigation had been carried out by the CBI and State Police forces. Apart from CBI, the state police forces have shameless record of misuse of the draconian acts and violation of the human rights of minorities. Nobody would dispute on the issue that police should do their duty and work impartially but in the name of terrorism we can‘t let the police to killing and frame innocent citizens.25 Take the series of bombing case in Delhi, when it take place we are assured with great authority that bombers were Jehadis (Muslims-the followers of Osama Bin laden) acting under the instruction from Pakistan terror outfits. So far four different states police had been claimed that masterminds of bombing are in custody with us. Now, we are being told that they were Hindus who the ATS of Maharasthtra Police has in custody. We can easily predict that what has been going on in the name of so called investigation by the police, special cell or ATS. If you go through the controversial area of encounters, the police come off even worse. Nobody seriously disputes that many of the people killed in so called encounters have actually been killed in the police custody.26 The Gujarat Police and the role of state administration is the finest example of state sponsored atrocities against the Muslim community. The former DGP of the state is absconding, many police officials are in jails-the charges are same i.e. extra- judicial killing of innocent people, unfortunately most the victims are happened to be Muslims.

In the words of Mr. Wajahat Habibullah the former chairman of National Commission for Minorities, all encounters are fake and illegal and the police are creating a kind of paranoia in the multi-cultural and multi-religious Indian society and there is strong apprehension that, these developments will certainly rise the communal atmosphere of the Indian society. The police have been completely failed to build confidence amongst members of minorities. The whole community has been under frightened and force to live under the shadow of police terror. The minority community have legitimate rights to not to cooperate with police as there had been a history of police atrocities against them. How they can trust police who framed innocent youths from their community in the false terror charges, subjected them to acute form of torture and barbaric cruelties. 27

In India the violation of human rights through state agencies in the name of combating terrorism has been a major concern for all democratic loving citizens. The TADA Act 1987 was most draconian Acts in India and the same was heavily misused by the police. Due to countrywide protest it was dropped in 1995. On POTA, the chairperson of NHRC Justice A S Anand had said that it did not have provisions to safeguards against its misuse though those provisions may not be enough .28 Justice Anand further added that undoubtedly, national security is of paramount importance but the individual human rights must be uphold by the state, without protecting the safety and security individuals rights, the nation can‘t be protected.

Referring to terrorism the NHRC chairperson said:
Government should adopt the strategies which balance the dignity of the individuals with national security. The human dignity must be placed alongside the unity and integrity of the nation. Any law enacted to tackle terrorism must be very closely scrutinized and must muster the strict approval of constitutional validity, necessity and proportionality, the legislature must scrutinize whether there is at all any need for such law and whether it infringes civil liberties or not.29

However, all the liberal states have enacted certain special laws dealing with terrorists. Recently, investigation and prosecution of the terrorist offences at central level is streamlined. The establishment of National Investigation Agency under the NIA Act 2008 is the first step towards effective handling of terrorism related offences. The second piece of legislation, the Unlawful Activities (Prevention) Amendment Act 2008, makes a number of substantive and procedural changes to empower the NIA to act effectively and decisively on terrorism related activities. The powers of the NIA to arrest and search have been tightened. Sections 43A to 43F have been substituted with provisions that enlarge the power to search any premises or arrest any person who, in the opinion of the officer, is about to or has a design to commit an offence covered under the UAPA Act.30 The provision of anticipatory bail under s. 438 of the Cr.P.C does not apply to the offences under the Act. If the accused is a foreigner, who entered the country illegally, bail is not to be granted at all. Finally the Act empowers the Central Government to freeze, seize or attach the financial assets of those engaged in the terrorism. These strong provisions, if responsibly executed in combating terrorism, would undoubtedly protect the security and liberty of the citizens,which form the foundation of the Rule of Law in a constitutional system.

VI. Concluding Remarks
In the final analysis, terrorism is an extreme form of violence; it‘s a product of social dissatisfaction and frustration, denial of certain basic human rights i.e. economic and political deprivation and administrative malaise. It cannot be cured only through the military action or by use of force. Terrorism, like corruption needs to be tackled in a proactive manner. Reactive action is inadequate; it can have fatal consequences in terms of public peace and the national cause. The measures that need to tackle terrorism include political, social and administrative measures along with military

actions. Further by politicizing the terror and giving any religious color to the terrorism, our political classes are guilty of doing grave disservice to our anti-terror investigative agencies. The existing agencies i.e. NIA, ATS etc must function independently and without any influence of the political class. The immediate task is to rise above the religious prejudices when confronting terror. There must be an acute realization that there are some individuals in both the community who are seeking to settle scores through mindless violence. We must treat all terrorist equally irrespective of their religion, creed or colour.

The media is too responsible for creating panic in the society through their reporting on terrorist attacks. The visual media must shun its class and religious bias while reporting such incidents. The media gives importance to newsworthy incidents that capture the interest of viewers and maximize their profit. Terrorism is pervasive flavor of the era and undoubtedly, any profit grabbing sector will try selling the product to maximize its consumers regardless of the apprehensive effect of the act. Visual Media exploits nature of the people by filling of more tragic scenes which in turn generates more viewership and profit. The electronic media should play constructive and vital role in reporting the terrorist incidents.

The strength of republic is measured in its capacity to treat all its citizens equally without any discrimination. The Preamble of the Indian Constitution promises to do so. The incapacity to deliver this promise can only undermine the foundations of the Republic. The secular democratic foundation of the Indian Republic must be strengthened by strengthening the equality of all before the law.

Dr. Ishita Chatterjee*
*Assistant Professor of Law, Department of Law, ICFAI University, Agartala (Tripura).The author can be contacted at; [email protected]
[Ed. Views expressed in the paper are personal views of the author. None of the persons associated with the IILS Law Review subscribe them]
1Webster Dictionary (1990) defines terrorism as the act or practice or terrorizing, especially by violence for political purposes, as by a government seeking to intimidate a population or by revolutionaries seeking to overthrow a government, compel the release of prisoners etc. The Chambers Dictionary (1990) calls it as an organized system of intimidation for political ends.2
3 For detailed study, See H.O. Aggarwal‘s Combating International Terrorism: State’ Approach in
International Law and Human Rights (Central Law Pub. Allahabad, 2010) chap 9, pp. 656-665.
4 Paul Wilkinson, Terrorism Theory and Practice‘, London-Allen & Unwin, 114 (1985).
5 Available at Interpol website
6 (1994) 4 SCC 618.
52Ibid., at p 620
8 Paul Wilkinson, Political Terrorism, pp. 36-40 (1974) quoted in S C Arora‘s, Combating Terrorism: The Punjab Case, Journal of Constitutional and Parliamentary Studies (230) 1995.
9 Yonah Alexandor, International Terrorism-National, Regional and Global Perspectives, Praeger Pub.
New York, 3-17 (1995).
10 Dr. Gilbert Sebastian,Getting to the Global Terror, 47(2) MAINSTREAM NEWSWEEKLY (January 24, 2009)
11See K Natwar Singh‘s interview about One Life is Not Enough , Rupa Pub. New Delhi, 2014-An autobiography of the veteran Congress leader, visited dt. 30.07.2014, some texts of interview also appeared in ‗India Today‘ newsmagazine dt. 13.08.2014
12 Yonah Alexander, International Terrorism-National, Regional and Global Perspectives, 170-171 (Praeger,New York, 1976).
13 Bipan Chandra, India’s Struggle for IndependencePENGUIN PUBLICATIONS 429 ( 2002).
14 Ibid at 430.
15 H S Phoolka, Sr. Advocate who represented the riots victim‘s case of 1984 anti-Sikh riots, the detailed interview given to Srinivasan Jain in Truth versus Hype programme, (last visited on visited 06.06.2014 10.30 PM )
16 Lt. Gen. K S Brar, Operation Bluestar-The True Story, UBS PUBLISHERS PVT . LTD, 9 (1993) (Lt. Gen. K S Brar was the operational head of the surgical army action named Operation Bluestar conducted by the Indian Army in June 1984 at Golden Temple Holy Shrine of Harminder Sahib Ji, Amritsar, Punjab)
17 Author is thankful to Prof. S S Bindra, Department of Political Science, Amity Institute of Social
Science, Amity University, Noida for his valuable comments on causes of Sikh militancy in India.
18 Gilbert Sebastian , Getting to the Global Terror, MAINSTREAM NEWSWEEKLY, (January 24, 2009).
19 D N Rath, Terrorism and Human Rights available at
20 Rajdeep Sardesai-IBN Live available at visited on 14.01.2011-09.46
21 Himani Savarkar is a niece of Nathu Ram Godse who assassinated Mahatma Gandhi and member of Abhinav Bharat (a Militant Hindu Outfit financed and controlled by the RSS). Nathu Ram Godse is dead but his legacy of hatred still thrives on, he is a martyr not terrorist, claimed Abhinav Bharat.
22 D N Rath, Terrorism and Human Rights avalaible at (last visited on dt. 23.08.2008).
23 Rajinder Puri in Samjhauta farce still on track , The Statesman ( Kolkata, 31st July,2014).
24 Sitaram Yechuri Terror has no religion in ‗Left Hand Drive’, Prajasakti Book House Hyderabad, 167 (2012).
25 See Crime in India NCRB Report- Delhi Police has been on top in all India level percentage of crime committed by the police personnel and human rights violation cases e.g. custodial violence, extortion, frame-up in false cases, outraging the modesty of woman and other serious category of crime
according to the latest report on crime released by the National Crime Records Bureau , Ministry of Home Affairs. 161-166 (2013).
26 Vir Sanghavi in Counterpoint, The Hindustan Times 11(Delhi, 23August 2008).
27 Wazahat Habibullah, Chairman, National Commission for Minorities, in a interview given to NDTV‘s Barkha Dutt for details available at (last visited on 23.02.2014 at 10.30 PM IST)
28 Text of NHRC opinion on Terrorism Ordinance 2001, issued in November 2001 8th Human Rights News Letter, NHRC, New Delhi (December 2001).
29 Ibid
30 See Unlawful Activities (Prevention) Amendment Act, 2008.

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