The Garland and the Lawbook: Hindutva, the BJP, and the Making of a Rape Culture

On the morning of August 15, 2022, the seventy-fifth anniversary of India's independence, Prime Minister Narendra Modi stood at the ramparts of the Red Fort and asked the nation to pledge respect for its women. Hours later, eleven men walked out of the Godhra sub-jail in Gujarat. They had been serving life sentences for gang raping Bilkis Bano, then twenty-one years old and five months pregnant, and for murdering seven members of her family, among them her three-year-old daughter Saleha, whose head was smashed against a rock as her mother watched. Outside the jail, the men were garlanded. They were fed sweets. Their feet were touched. The Gujarat government had granted them remission under a policy it had no jurisdiction to apply, a fact the Supreme Court would confirm in January 2024 when it quashed the release, ruling that the state had usurped powers belonging to Maharashtra. By then the men had lived free for seventeen months. One of them had shared a stage at a government event with a sitting BJP Member of Parliament and his MLA brother.

I have spent much of the last decade documenting how Hindutva manufactures its enemies, and I keep returning to that image of the garlands. A garland in the Indian imagination is an act of veneration. You garland a deity, a martyr, a returning hero. When the machinery of a ruling party produces garlands for the rapists of a Muslim woman and the murderers of her child, we are being told something precise about the moral order that party is building. C.K. Raulji, the BJP MLA from Godhra who sat on the government committee that unanimously recommended the release, said the quiet part aloud. The convicts, he told an interviewer, were Brahmins, men of good sanskar, and it was possible they had been framed. He added that he did not know whether they had committed any crime at all, as though the trial court, the Bombay High Court, and fifteen years of judicial process were rumours. Months later the BJP rewarded him with the party ticket from Godhra. He won.

The temptation, always, is to treat each of these episodes as an aberration, a rogue legislator, an unfortunate remark, a lapse in vetting. The evidence will not permit that reading. In August 2024, the Association for Democratic Reforms analysed the sworn affidavits of 4,693 sitting MPs and MLAs and found 151 legislators with declared cases of crimes against women, sixteen of them facing rape charges. The party with the largest share of these lawmakers, fifty-four of them, was the BJP. This is the party of gau mata and Bharat Mata, the party that campaigns on beti bachao, and it leads the nation's legislatures in men charged with harming the daughters it promises to save. ADR's earlier analyses found the same pattern in ticket distribution: among major parties, the BJP gave the most tickets to candidates with declared cases of crimes against women. A party reveals its values in whom it punishes. It reveals them more completely in whom it protects, promotes, and garlands.

Consider what protection has looked like. In Unnao, Uttar Pradesh, a seventeen-year-old girl went to the home of her MLA, Kuldeep Singh Sengar, seeking a job in 2017. He raped her. When she pursued a complaint, her father was beaten by the MLA's men, jailed on fabricated arms charges, and died in custody. When she still refused to be silent, she attempted to set herself on fire outside the Chief Minister's residence. When she still refused to be silent, a truck with blackened number plates rammed the car carrying her, killing two of her aunts and critically injuring her and her lawyer. Through all of this, Sengar remained a BJP MLA. The party expelled him only in August 2019, after the crash, after the Supreme Court transferred the cases out of Uttar Pradesh, after the national outrage became unmanageable. His party colleague Sakshi Maharaj visited him in jail. Another BJP MLA, Surendra Singh, defended him with the observation that no one could rape a mother of three children. Sengar was convicted in December 2019 and sentenced to imprisonment for the remainder of his natural life. In December 2025, the Delhi High Court suspended his sentence in the custodial death case on a technical reading of who counts as a public servant. The girl's father is still dead. Her aunts are still dead. The structure that produced her suffering remains intact, and its beneficiaries are patient.

Consider Brij Bhushan Sharan Singh, six-time MP and long-time chief of the Wrestling Federation of India. When India's most decorated women wrestlers, Olympic and world medallists, accused him of years of sexual harassment, including of a minor, they sat in protest at Jantar Mantar and were dragged through the streets of Delhi by police on the day the new Parliament was inaugurated. A Delhi court found sufficient evidence to frame charges of sexual harassment, intimidation, and outraging the modesty of women. The BJP's response to this reckoning was to deny him renomination from Kaiserganj and to hand the ticket to his son Karan, who campaigned alongside his father and won. Sakshi Malik, an Olympic medallist, put the arithmetic plainly: the wrestlers risked their careers and slept on roads, the accused was never arrested, and his family kept the seat. The party asks for votes in the name of Lord Ram, she said, while abandoning the path the Lord showed.

And consider Kathua, because Kathua is where the communal architecture of this rape culture becomes impossible to unsee. In 2018, an eight-year-old girl of the Bakarwal Muslim nomad community in Jammu was abducted, held in a temple, drugged, gang raped over days, and murdered. The crime, the investigators found, was designed to terrorise her community into leaving the area. When the accused were arrested, a formation calling itself the Hindu Ekta Manch marched with the national flag in their support, and two BJP ministers in the state government, Choudhary Lal Singh and Chander Prakash Ganga, attended and addressed the rally. They resigned only under coalition pressure, and Lal Singh went on to lead further marches questioning the investigation. The tricolour, raised for men accused of raping a Muslim child. This is what it means to say that in the Hindutva imagination the Muslim woman's body is a territory. Her violation is a message delivered to her community, and those who deliver it can expect the movement's solidarity.

The speech surrounding these acts is its own body of evidence, and it runs, as the record shows, from the lowest rungs of the party to its highest offices. Babulal Gaur, a BJP veteran and Madhya Pradesh minister, declared that rape is sometimes right and sometimes wrong. Manohar Lal Khattar, then Haryana Chief Minister, suggested most complaints were quarrels dressed up as rape, having earlier advised women who wanted freedom to go about naked. Surendra Singh, after Hathras, where a young Dalit woman was gang raped and murdered and her body burned by police in the night without her family, announced that rape could be prevented if parents taught their daughters sanskar and proper dress. During the Delhi election campaign of 2020, with Muslim women leading the historic sit-in at Shaheen Bagh, BJP MP Parvesh Verma told voters that the protesters would enter their homes and rape and kill their sisters and daughters. One hundred and seventy-five women's organisations wrote to the Prime Minister describing his party's campaign message as the fear of rape itself. He said nothing. In Sitapur in 2022, the mahant Bajrang Muni Udasin stood before a crowd, in the presence of the police, and threatened to openly abduct and rape Muslim women. He faced no meaningful consequence, and he campaigned for the BJP's winning candidate in the constituency. In 2025, former BJP MLA Raghvendra Pratap Singh promised rewards to Hindu men who would each bring him ten Muslim girls for conversion, asking the young men in his audience to raise their hands. And in the digital undergrowth that the movement has cultivated, young men steeped in Hindutva and the imported grammar of the alt-right built Sulli Deals and Bulli Bai, applications that put photographs of prominent Muslim women, journalists, pilots, students, up for mock auction. The Delhi Police, answerable to the Union Home Ministry, let the first app sit for months without an arrest. The women auctioned were the women who spoke. That was the point. The auction is the rape threat scaled by software, a technology of silencing aimed at precisely those Muslim women who refuse the script written for them.

None of this is incidental to Hindutva. It is constitutive. V.D. Savarkar, the ideology's founding theorist, devoted a section of his Six Glorious Epochs of Indian History to rebuking Shivaji and Chimaji Appa for returning captured Muslim women to their families unharmed, describing such restraint as a perverted notion of virtue and arguing that sparing the enemy's women had been a civilisational error. The founding text of the tradition treats the sexual violation of Muslim women as a legitimate instrument of historical retribution. Gujarat 2002, where Bilkis Bano's body became one such instrument among hundreds, was that doctrine enacted. The remission, the garlands, and the sanskari Brahmins comment were that doctrine administered.

And beneath Savarkar lies an older lawbook. The Manusmriti, the text B.R. Ambedkar burned publicly on December 25, 1927, holds that a woman must never be independent, that her father guards her in childhood, her husband in youth, her sons in old age. It instructs the wife to venerate her husband as a god regardless of his character. And it grades punishment by caste, prescribing that a Brahmin, whatever his crime, is never to be executed, only sent away with his property intact. Read C.K. Raulji again with Manu open beside him. They are Brahmins, men of good sanskar; their conduct in jail was good; release them. A legislator of the world's largest party, in the twenty-first century, reasoning in the exact syntax of a lawbook composed to shield upper-caste men from consequence. Dalit commentators saw it immediately, pointing to the verse and naming the release for what it was, Manusmriti reservation, eternal and unamended.

This is why I insist, following Uma Chakravarti's foundational work, that what we are watching is the maintenance of brahminical patriarchy, the ancient compact in which caste purity is secured through the control of women's bodies and sexuality. The system requires the upper-caste woman to be enclosed, which is why the same governments that free rapists pass so-called love jihad laws policing whom a Hindu woman may love, treating her adult choices as abductions in need of state rescue. It requires the Dalit woman to be violable, which is why Hathras ended with an illegal midnight cremation and a police force protecting the accused. And it requires the Muslim woman to be a territory of conquest, which is why she is auctioned in apps, threatened from stages, and raped in pogroms whose perpetrators are then garlanded. The daily assertion within RSS shakhas that the Hindu nation is a mother to be protected completes the circle: woman as symbol is worshipped precisely so that women as persons can be governed. Communicative inversion is the term I have used for this in my scholarship, the systematic deployment of the language of protection to carry out the work of violation. Beti bachao as slogan, Bilkis's rapists as free men.

The women themselves have never accepted this order, and that refusal is where whatever hope exists resides. Bilkis Bano, who lost her child, her family, and then her justice, went back to the Supreme Court and won. The wrestlers went back to the mat and to the streets. The grandmothers of Shaheen Bagh sat through a Delhi winter under the Constitution's preamble. The Muslim women auctioned online filed the complaints, gave the interviews, kept their photographs public. Each of these acts is a repudiation of Manu, of Savarkar, of the garland. After her rapists walked free, Bilkis asked a question in her public statement: how can justice for any woman end like this? The record assembled here is the honest answer. It ends like this when a political movement built on brahminical patriarchy holds state power, because for that movement this is what justice looks like. Her question stands anyway, and it will outlast them.