Author: Merry Bernard Ollukaran, 4th year, BBA LL.B(H), AIM Law College, Thrissur
Honour killings and honour crimes have been rapidly increasing even in this developing era of India. This offense is presumed to be done on the restoration of one’s family pride and honour. Even though there are sufficient laws in India to curb these honour crimes due to lack of proper execution of the said laws, such brutish crimes still occur in India. The preliminary step to wipe out these honour crimes is to clear false beliefs of honour and dignity for families and caste in the Indian society from the minds of the Indians.
This paper discusses about honour killings in India, its intensity, the laws against this offence and measures to be taken in reducing these crimes. In the later part, some of the main reasons which lead to these offenses such as notions of patriarchy, some of the superstitious beliefs of Indian society, shame of losing the dignity of the family and individual and due to some of the illegal and illogical trusts, organizations or groups operating in India are also explained.
Keywords – Honour killing, Dishonour, Kaph Panchayat, Patriarchy, Caste.
Honour based violences (usually murders) are termed as Honour Killing and Honour crimes, which are principally viewed as a problem through the lens of cultural materialism. The Indian culture gives much importance towards the patriarchy system, prestige of the family, dignity in the society and the honour in caste systems. These beliefs are carved in the hearts of Indian people especially for the illiterate and among the village people who did not step into civilization, who cannot think out of this box of honour to live with dignity in this Indian society. If anything or anyone obstructs this dignity or prestige some of them become blind to this and provoke themselves. The restoration of this honour leads to honour based violences. Usually the honour crime victims are the members of the family itself and generally female members of the family are chased by these honour crimes. Thus honour killing and honour crimes can be simply defined as the offense committed by the perpetrators [one’s family members itself] in the restoration of honour and pride which was alleged to be patched out by the victim.
- Reasons for honour crimes in India.
- Fallacy, Patriarchy and Honour crimes.
- Developing India and execution of laws in Honour crimes and Honour Killing.
- Whether Honour killing only a caste crime or there are other reasons for honour crimes.
- Whether the Indian beliefs are connected with Honour Killing.
- Whether the existing laws are sufficient to curb Honour Killings and Honour Crimes in India.
The methodology adopted by the researcher is doctrinal research .
In the article ‘Honour’ crimes in India: An assault on women’s autonomy  written by Kavita Krishnan, violence against women’s autonomy, gender violance, domain of the male members over female members in a family, intrusion of others in a woman’s right to life etc. are elaborated. The author had focussed more on the domain of male over rights of female and intrusion to right to choose life of a woman by her family members as the content and reason for honour crimes. The author had excluded other reasons such as Khap panchayats and other Indian superstitions. This is critically analysed and has been added to this research paper.
In the article Honour Killing: India’s Own Pandemic Of Patriarchy  written by Sanhati Banerjee, caste crimes, provincial patriarchy, cultural packaging etc. with respect to honour Killing are explained in detail. But here the author gulped the other types of honour crimes than the caste based crimes such as loss of virginity of women outside marriage, unapproved relationships, refusal to accept an arranged marriage, girls’ divorce, and rape. These points had been evaluated and included in this paper.
In the article of Honour Killings: Are we prepared to tackle the problem? written by Kaushiki, the author did mention about kaph panjayaths, reasons for honour killing other than caste based crimes, laws which can be applied against honour Killing in IPC etc. But the author precluded the other laws which can be applied against honour crimes such as constitutional laws, laws under Protection of Women from Domestic Violence Act etc. This has been included in this paper.
Honour killings or honour crimes are not only caste crimes but there are several other reasons hidden in the dark shades of India and Indian beliefs which could be curbed out if the proper implementation of the existing laws itself against perpetrators of honour crimes is done.
Honour killing or shame killing is the act of committing murder of the member of a family by another family member[s] of the same family itself on their credence that the victim has brought shame or disgrace to the family, or has breached the principles of a community or a religion with an honour and privilege culture. Usually it is done by patriarchal men in the family to the women in the family who are accused by them as a person who gave dishonour and shame to their family and dignity in their society. India has been very much particular about what sort of development it has undergone throughout these years. ‘On an international level with the nuclear deal, 8% growth rate and the recognition India is enjoying to voice its opinion’ , which implies India is excelling. But when we go deeper into the dark secrets of this developing nation and we still find unbridled murders of budding couples by their own family members to save the family’s honour because of the electral love of the couple.
IS HONOUR KILLING A CAST CRIME
Honour killings are generally considered as caste crimes. Although a major part of those are based on marriage out of caste, this is only one side face of the honour killings. There are many other reasons under the shadows of this through which honour killings occur. Some of the main reasons are divorce, marriage by personal choice, homosexuality, pregnancy before marriage,unapproved relationships, marital infidelity, loss of virginity outside marriage, inappropriate dressing etc., which the perpetrators believes as the causes for losing their honour of their family and their caste and religion and subject to brutal harassments towards the victims. Most of this honour crimes and honour killings are later disguised by the perpetrators, that is family members itself, into a suicide are missing after family member.
NOTIONS OF PROVINCIAL PATRIARCHY
Women were exchanged in marriages for gaining kingdoms, prizes and booties to be won and devoured in war and brokering deals of peace and patronage in the ancient times. It’s a circle that recognized the right to wield patriarchal control over a woman’s body just as a sovereign would wield his control on his properties. The circle operated by Kings, feudal lords, state councillors, priests and Princes would confine a women’s sexual and marriage rights within the strait boundaries of kinship and caste approved provinces. Cross-state and cross-religious marriages could befall only if the patriarchal lords would have material gains or career and ego boost out of it. Today’s honour killings crimes are rooted in such a collective memory of primordial, provincial patriarchy. Thus, according to them, the purity of a female family member who is the pride of the family is said to be disturbed by any act of the female or otherwise is considered to be dishonour on to the family and their caste and for regaining the pride back on crimes and honour killings are commenced.
Women in inter-face and inter-caste relationships are subjected to immense torture and cohesion not only at the hands of their families and communities but also by some of the political organizations. These political organizations claim that such inter-faith relationship such as between a Hindu women and Muslim man is a trap to love jihad where, the Muslim men target women belonging to non-Muslim communities for conversion to Islam by fake love. They averred that it was trick used to reduce the members of a religion. The title ‘Love jihad’ was also used as a veil to hide the true inter-faith love and to separate the couples. In Shafin Jahan v. Asokan K.M and Ors. , (popularly known as Hadiya case) Hadiya the daughter of the defendant converted from Hinduism to Islam add chose to marry the plaintiff. The defendant claimed that his daughter was trapped in love jihad and pleaded for custody of his daughter. Initially, the high court ordered that “As per Indian tradition, the custody of an unmarried daughter is with the parents, until she is properly married” Later when appealed the supreme court held that Hadiya was free to choose her faith and her partner in marriage, as a legal adult.
In 2014, in another issue, Shalu, a Hindu woman who was in love with Kaleem, a Muslim  was forced to file cases of gang rape against Kaleem and his family members. This also was later disguised to be love jihad and was so spread throughout the media. But Shalu eventually managed to escape her parent’s home and to reveal the truth to the police. Shalu and Kaleem were united later.
‘Khap’ is an ancient concept but still followed in some parts of northern India which is a social-political group, with no legal status, where clans under the same gotra and families in a village form together. They combine their position and power covering an area containing a pack of villages and it’s set of rules. According to their rules, a boy and a girl linked in the same gotra are brothers and sisters. Love marriages are considered as taboo in the villages where the khap panchayat operates. Khap rules and punishment for the couple of marrying within the same sub- caste are ruthless, especially for the women. The female who becomes the victim to it is often raped, stoned, burnt or beaten to death, stabbed, fed with pesticides by family members, cut at the throat, beheaded, suffocated slowly or even forced to commit suicide. All this is done in the name of honour. The murderers do not feel contrition or shame on their such activities, rather they defend their act with the belief that they have restored and saved the family’s honour which was earlier lost by the girl’s actions. These killings have been increasing mostly in village areas like Haryana, Punjab and western Uttar Pradesh. Many of the honour killings in our country occur due to the brutish rules of this Kaph panchayat.
MURDERS ON DIS- HONOUR
Statistical representation of honour killings in different states in India.
There had been many barbarous bloodsheds on the ground of dis-honour in India. These murders shook the bottom of the heart of India and were inhumane and savage. The reports of honour killing in India are shocking and today, Gujarat is the most reported with the honour crimes occurring in India.
In Smt. Chandrapati vs State Of Haryana And Others , a couple, Manoj and Babli were married against the rules of Khap panchayat which subsequently ordered the death of both of them to be fulfilled. On this command Babli’s brother Suresh had forced her to consume poison while four other family members strangled her husband with a rope in front of her eyes. Both were then thrown into a canal after their hands and legs were tied together with ropes.
‘While passing the judgement, the additional district I and sessions judge at Karnal, Vani Gopal Sharma, said: “[That] Bali’s brother Suresh, who should be protecting and sheltering the sister should commit such an act is beyond all comprehension of human psychology.” Expressing shock, the judge said: “The convict Suresh himself administered poisonous pesticide to his sister and actively participated in perpetration of the crime. His conscience did not even once shake him out his ignominy while he took the life of the one with whom he shared the womb and childhood. He does not deserve the leniency of the Court in any manner.” ‘ Finally the court gave capital punishment to five family members of Babli including Suresh and life sentence to Khap leader Ganga Raj.
In Vishal Yadav vs State Of U.P Nitish Katara, a young man, was killed by the sons of a prominent politician DP Yadav because he was in love with Yadav’s daughter. The relationship of the couple was a dis-honour to the lady’s family. In the Nitish Katara case, the Supreme Court of India tried to redefine the concept of “honour crime” as a crime against women’s choice, observing that a woman’s “individual choice is her self-respect and creating dent in it is destroying her honour.”
In the case of T. Padmaja v The State Of Telangana, Perumalla Pranay Kumar was stabbed, cut-throat and killed by hired killers by father of his wife, while walking out of the hospital after medical check up of his five- month pregnant wife towards their car parked outside a hospital. Pranay’s wife Amrita was from the Vysya community and their marriage was against the wishes of Amritha’s family. Amrita’s family believed that when Amrita got married with pranay who was of a lower caste according to them, they had a loss of face in the society in their dignity.
Even during this lock down period of the raising pandemic on 27th March there occurred an honour crime. In Morappan Thangal village, six months ago, M. Sudhakar, a man in the Oddar caste , married woman of his love who belonged to the vanniyar community which was higher caste than his. The woman’s family who was angered in this convoked a local panchayat and got it to nullify the marriage and unceremoniously sundered the couple. Sudhakar was subsequently beleaguered and chased away from the village. However during the Lockdown, the victim attempted to meet his wife this angered the woman’s family and the woman’s father along with a relative attacked and killed him sinked in notions of superiority over the deceased Man’s family who was ranking lower than them.
In Udumalpet Shankar’s case Udumalpet Shankar who belonged to a scheduled caste community married Kowsalya who belonged to the OBC community against the wishes of Kowsalya’s family. On July 23rd kowsalya was abducted by her family and put through some of the black magic rituals, threatened and beaten. Three days later only she was rescued after when Shankar filed a police complaint. After a year of this incident while the couple was waiting for a bus on a busy road in Tripura district they were attacked and Shankar was hacked to death, Kowsalya was left as dead but barely survived and was under treatment for six months. The honourable court punished Kowsalya’s parents and maternal uncle who conspired and arranged for the killing of her husband. The real plan was to kill them both because of the crime of her marrying a Dalit and the ‘dishonour’ it bought to her family.
Another incident which occurred recently was that, on 24th September, Hemanth Kumar, 28 year oldwas kidnapped and murdered and his body was thrown into a clump of bushes by the roadside for marrying his love Avanti Reddy, Killers hired by Avanti’s father. Hemanth was from Vysya community of traders while Avanti was from Reddy community. The family of Avanti was furious that a girl from their family of Rich landowners had chosen her husband from the Vysya community which was a big shame for them.
Following the Supreme Court ruling on March 27, 2018 in Shakti vahini v. Union of India, laying down preventive, punitive and remedial measures to stem such honour killings and honour crimes, the Ministry of Home Affairs issued advisory to all the states that, the states has to create special cells in every district comprising the Superintendent of Police, the District Social Welfare Officer, and District Adi- Dravidar Welfare Officer to receive petitions or complaints of harassment and threat to couples of inter- caste marriages. The advisory stated that these special cells should create a 24-hour helpline to aid couples in distress. These are established in different states in different names. For example, in Hyderabad this trust is called ‘Bharosa’.
HONOUR KILLING AND IPC
There is no provision in the Indian Penal Code as such to punish the perpetrators for the crime of honour killing or honour crimes. But there are certain provision heads under which the perpetrators of honour crimes can be penalised. They are as follows :
- Section 299 to section 304 penalises any person guilty of murder and culpable homicide not amounting to murder. The punishment for murder is life sentence or death and fine. The punishment for culpable homicide not amounting to murder his life imprisonment or imprisonment for up to 10 years and fine.
- Section 307 penalises attempt to murder with imprisonment for up to 10 years and fine. If a person is hurt, the penalty can extend to life imprisonment.
- Section 308 penalises attempt to commit culpable homicide by imprisonment for up to 3 years or with fine or with both. If it causes hurt, the person shall be imprisoned for up to 7 years of fine or both.
- Section 120 A and B penalises any person who is a party to a criminal conspiracy.
- Section 34 and 35 penalises criminal acts done by several persons in furtherance of common intention.
OTHER LAWS :
- Honour killings also violates Articles 14, 15 (1) & (3) 19 and 21 of the Constitution of India, which guarantees right to equality, right from discrimination against citizens on grounds only of religion, race, sex, caste, and place of birth or any of them, right to freedom and right to life respectively.
- The provisions of the Protection of Women from Domestic Violence Act, 2005 provides for more effective protection of the rights of women guaranteed under the Constitution who are victims of violence of any kind occurring within the family and for matters connected therewith or incidental thereto.
- The Scheduled Castes And Scheduled Tribes (Prevention of Atrocities) Act, 1989 facilitated the social inclusion of Dalits into mainstream of the Indian society. The Act is linked to honour killings because numerous incidents of honour killing are in relation to caste and religion. The Act also prescribes severe punishments for the perpetrators who harass the scheduled caste and scheduled tribes.
Even though the existing laws are sufficient to punish the perpetrators of honour crimes, as not implemented strictly, a group of people demand for a separate law against honour crimes to bring more clarity of law enforcement agencies. They also claim that such a separate law against the Commission of the offense of honour crimes creates a fear in the minds of the perpetrators to commit such crimes further in future. But the researcher feels that the accurate and hasten implementation of the existing laws against the honour crimes shall be itself sufficient.
DIRECTIONS FOR PREVENTION OF HONOUR KILLING
The Supreme Court of India provided certain directions for the prevention of honour killing, which are ideal, in the landmark judgement of Shakti Vahini v. Union Of India. In this case the petitioner demanded under Article 32 of Indian constitution seeking directions to respondents, that is, state government and central government to take preventive steps to combat honour crimes, to submit a national plan of action and state plan of action to curb crimes of barbarous nature and further to direct state governments reconstitute special cells in each district which can be approached by couples for their safety and wellbeing. The honourable court in the judgement produced some preventive remedial and unity measures. Some of them are as follows:
PREVENTIVE MEASURES :
- State Governments should identify Districts, Subdivisions and Villages where occurence of honour killing or assembly of Khap Panchayats have been reported, frequently and recently.
- The Secretary, Home Department of concerned State shall issue directives or advisories to Superintendent of Police of concerned District for ensuring that Officer in-charge of Police Stations of identified areas are extra cautious, if any instance of inter-caste or inter-religious marriage within their jurisdiction comes to their notice.
- If any police officer or any officer of the District Administration gets any information about any operation or gathering of a Khap Panchayat, he should inform immediately his superior officer and simultaneously intimate the jurisdictional Deputy Superintendent of Police and Superintendent of Police to take respective actions against it.
- On receiving such information, the Deputy Superintendent of Police shall immediately interact with members of Khap Panchayat and convey to them that conducting such meetings or gatherings is not permissible under law and to stop from proceeding with such a meeting. The Deputy Superintendent of Police should issue appropriate directions to Officer jurisdictional Police Station to be vigilant and if necessary, to post adequate force for prevention of such proposed gathering.
- Despite such measures, if a meeting is conducted, the Deputy Superintendent of Police shall personally remain present during the meeting and force upon the assembly and make sure that no decision is taken to cause any harm to the couple or family members of the couple, and inform the assembly that each one participating in such meeting besides organisers would be individually liable for criminal prosecution. The respective officials must ensure that video recording of discussion and participation of members of assembly is done on the basis of which law enforcing machinery which can resort to any suitable actions later.
- If the Deputy Superintendent of Police, after communication with members of Khap Panchayat feels that the gathering cannot be prevented and is likely to cause harm to couple or members of their family, then he shall submit a proposal to District Magistrate or Sub-Divisional Magistrate of District or Competent Authority of concerned area for issuing orders to take preventive steps under Criminal Procedure Code, 1973 including by producing prohibitory orders under section 144 Criminal Procedure Code, 1973, and also, by causing arrest of participants in assembly under section 151 Criminal Procedure Code, 1973.
- There should be an institutional machinery with necessary coordination of all stakeholders. Different State Governments and Home Department of India together ought to work on sensitization of law enforcement agencies to mandate social initiatives and awareness to curb such violence.
- If it comes to notice of local police that Khap Panchayat has taken place and it has passed any decision to take action against a couple or family of an inter-caste or inter-religious marriage or any other marriage which does not meet their acceptance then the jurisdictional police official shall immediately lodge an FIR under appropriate provisions of Indian Penal Code including sections 141, 113, 503 read with 506 of Indian Penal Code, 1860.
- After the registration of FIR, an intimation should be simultaneously given to Superintendent Police or Deputy Superintendent of Police who lays on duty to ensure that effective investigation of crime is done.
- Emergency steps should be taken to avail security to the couple or family and if necessary move them to a safer place within the same district or outside. The State Government may consider of establishing a safe house at each District Headquarter for that purpose under the supervision of the jurisdictional District Magistrate and Superintendent of Police, such safe houses which can provide to board.
- The District Magistrate or Superintendent of Police must deal with complaints regarding threats to such a couple or family with utmost susceptibility. The bachelor-bachelorette must be capable adults and if necessary, they may be provided logistical support for solemnising their marriage and for registering the marriage under police protection according to their desire. After the marriage, they may be provided accommodation on payment of nominal charges in the safe house (aforesaid) initially for a period of one month which may be extended upto one year, and this may vary depending on their threat assessment on the case.
- District Magistrate or Superintendent of Police to an officer of rank of Additional Superintendent of Police should go with an initial inquiry regarding complaint received from couple upon receiving information from an independent source that the relationship or marriage of such couple is opposed by their family members or local community or Khaps and must conduct a preliminary inquiry and ascertain the authenticity, nature and depth of their threat perception. On being satisfied as to the authenticity of such threats, he shall immediately submit a report to the Superintendent of Police not less than one week.
- District Superintendent of Police, after receiving such report, shall direct Deputy Superintendent of Police in-charge of concerned sub-division to register an FIR against persons threatening the couple and if necessary, invoke section f of Criminal Procedure Code, 1973. In addition, the Deputy Superintendent of Police shall personally supervise progress of investigation and ensure that the same is completed and taken to its logical end with dispatch. In course of investigation concerned persons shall be booked without any exclusion including members who have participated in assembly. If involvement of members of Khap Panchayat comes is found out then they shall also be charged for offence of conspiracy or abetment, as case may be.
- Any failure in execution by either police or district officials to comply with the above mentioned directions shall be considered as an act of deliberate negligence and misconduct for which departmental action will be initiated under service rules to its logical end, preferably not exceeding six months, by authority of first instance.
- States directed to take disciplinary action against concerned officials if it is found that,
(i) Such officials did not prevent the incident, despite having prior knowledge of it or
(ii) Such officials did not instantly incarcerate and institute criminal proceedings against the perpetrators despite the incident had already occurred.
- State Governments shall create Special Cells in every District including the Superintendent of Police, District Social Welfare Officer and District Adi-Dravidar Welfare Officer to receive complaints of harassment and threats to couples who had inter-caste wedlock and these Special Cells shall provide a 24-hour helpline to receive and register such complaints and to provide necessary assistance and protection to those couple.
- Criminal cases concerning honour killing or violence to the couples shall be tried before designated Court or Fast Track Court designated for that particular purpose. The trial must be proceeded on a day to day basis shall be concluded within six months from date of taking cognizance of the offence. It may expedite to add that this direction shall apply even to pending cases. Concerned District Judge shall assign the cases, as possible, to one jurisdictional court so as to ensure speedy disposal thereof.
Even a group of people and activists argue for the establishment of a new statute against the crime of honour killing, it is felt that the existing provisions in the law under which a perpetrator of honour crimes is accused shall be enough if they are implemented properly on them. Some of the suggestions that I have to make here are:
- Until and unless the people at the root level are not influenced to loathe such killings and the perpetrators consider it as a brutal offence, no law or statute can help to improve matters. Till the time the people believe from the bottom of their hearts the truth and after effects of honour crimes there shall be no solutions in the law alone.
- Khap Panchayats must be dissolved and banned. Thus the loss of power such groups on the inhabitants of the villages will help to solve the matters to an extent.
- People must be educated more about the scientific logic behind the concept of ‘gotra’, caste, religions and that these are not hindrances to marriage in the 21st century in India. The system of gotra was important in the ancient times because it prevented marriage between the people within common lineage and obstructed inbreeding depression. But in the present Era, the lineages have been diversified and the system of gotra, caste etc. need not to be followed to fulfil the motto to avoid the meeting of common lineage in the marriages.
- In each of the said cases above it was observed that there were threats given by the family members or society before the honour crimes had occurred. So even a simple threat by a family member to the couple against their marriage should be considered as a prospective danger to their lives and the couple should be given police protection.
- The punishment for such monstrous crimes should be a damper for people to attempt such wicked crimes. But life imprisonment is what can be awarded for such a barbaric crime.
Honour crimes are acts of violence, usually murder (Honour Killings), committed by male family members against female family members, who are held to have brought dishonour upon the family. This barbarous crime is claimed to be done for the regaining of the lost honour of the family and the caste. Honour killings are not only a caste crimes, there are other reasons for honour crimes such as divorce, marriage by personal choice, homosexuality, pregnancy before marriage,unapproved relationships etc. Indian beliefs such as the concept of purity of women with her family dignity, Indian patriarchal system etc. are connected with Honour Killing. The existing laws in India against the Honour crimes are sufficient to curb Honour Killings and Honour Crimes if executed properly in time.
The main solution to this problem lies in the annihilation of false beliefs in the minds of people. They need to be enlightened with the provisions given in the Hindu Marriage Act and what kinds of marriages are actually considered invalid. Khap Pachayats should at last be wrenched out of all its power so that it is impuissant to wrongly sway the native people and to dissuade them from committing such inhuman acts. Cases such as these show that more than half of the Indians still lead lives within the strong crutches of the caste system and even today youths don’t have the power to make decisions regarding their own lives. To see that even today, people blindly commit such barbaric crimes and consider it as an act of sanctifying the impure shows that India has really not modernized. India is a developing nation and should be developed for better in curbing the crimes in India also. Development has to be from the plinth itself, the core.
 Kavita Krishnan, ‘Honour’ crimes in India: An assault on women’s autonomy, ALJAZEERA (Nov 10, 2020, 8.40 PM) https://www.aljazeera.com/amp/indepth/opinion/honour-killings-india-assault-women-autonomy-180314090856246.html#aoh=16054984699790&referrer=https%3A%2F%2Fwww.google.com&_tf=From%20%251%24s.
 Sanhati Banerjee, Honour Killing: India’s Own Pandemic Of Patriarchy, FEMINISM IN INDIA, (Nov 13,2020, 4.50 PM) https://feminisminindia.com/2020/05/06/honour-killing-indias-pandemic-patriarchy/.
 Kaushiki, Honour Killings: Are we prepared to tackle the problem, PRS LEGISLATIVE RESEARCH (Nov 12, 2020, 6.13 PM) https://www.prsindia.org/theprsblog/honour-killings-are-we-prepared-tackle-problem.
 Radhika karkhanis, Honour Killing, LEGALSERVICEINDIA (Nov 13, 2020, 10.39 AM), http://www.legalservicesindia.com/article/271/Honour-Killing.html.
 Shafin Jahan vs. Asokan K.M. & Ors. (2018) SCC 343 (India).
 Kavita Krishnan, supra note 1.
 Murders In name of dishonour, TIMES OF INDIA (Nov 13, 2020, 11.41 AM), https://images.app.goo.gl/PWyyeiGuwBiCgSut9.
 Smt. Chandrapati v. State Of Haryana And Others, Crl. Misc. No. M-42311 of 2007 (India).
 Sukhbir Siwach, Brutality of honour killing shocks court, TOI, April 2, 2010.
 Vishal Yadav v. State Of U.P, (2016) SCC SC 1088 (India).
 T. Padmaja v The State Of Telangana, Writ petition Nos.41946, 41954 and 41955 of 2018 (India).
 Sanhati Banerjee, supra note 2.
 Brinda karat, For One Of India’s Most Brazen “Honour Killings”, Justice Denied, NDTV (Nov 14, 2020, 6.17 AM) https://www.ndtv.com/opinion/for-one-of-indias-most-brazen-honour-killings-justice-denied-2252889.
 Serish Nanisetti et al., Killing love with caste pride, THE HINDU, October 10, 2020, at 7.
 Shakti Vahini v. Union of India, AIR 2018 SC1601 (India).
 INDIA CONST. arts. 14, 15, cl.1, 15, cl.3, 19, 21.
 Protection of Women from Domestic Violence Act, 2005, No. 43, Acts of Parliament,2005 (India).
 Scheduled Castes And Scheduled Tribes (Prevention of Atrocities) Act, 1989, No. 33, Acts of Parliament, 1989 (India).
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