Caste Question

Diluting the SC/ST act: Only Working Class Unity Can Truly Fight the Acts of Atrocities

Abhijit A. M.

March 2018 witnessed widespread protests on the issue of the dilution of the “Scheduled Castes, Scheduled Tribes: Prevention of Atrocities (PoA) Act”, popularly known as SC/ST act or Atrocities act. The Supreme Court, delivering a judgement in Subhash Kashinath Mahajan v The State of Maharashtra ruled on 20th March 2018 that the act is being misused and did away with the provisions related to automatic arrest of the accused. The ruling also allowed for an anticipatory bail for the accused. The court ruled that public servants cannot be prosecuted without the approval of their appointing authority and private employees without the approval of Senior Superintendent of Police.

The ruling shows a poor defence of the case by the Modi government as well as the institutional biases that permeate all sections of Indian state. After the strong protests all over the country, the Modi government was forced to claim that they have no intention of diluting the law. It was forced to file a review petition in the court. It is obvious that the government is shedding crocodile tears fearing a loss of significant Dalit votes.

Commenting on the review petition, the Supreme Court on 2nd April said that it has not diluted the provisions of the act and “if the complaint is genuine (emphasis ours), arrest the accused”. Further on 3rd May the Supreme Court denied a stay on its own judgement and has effectively put the ball in the legislature’s court now. The Supreme Court has put the onus of deciding genuineness in the hands of the police and bureaucracy, thus opening a very wide opportunity for the real misuse of the law by the executive machinery.

History of the SC/ST Act

Many instances of massacres of Dalits can be cited in independent India. The 1957 Ramnad riots in Tamilnadu, Killing of 72 Dalits in Kizhavenmani in Tamilnadu in 1968, killing of Kotesu at Kanchikacharla in Andhra Pradesh in 1969, killing of 10 members of other backward castes on a land issue by the police in Andhrapradesh in 1978, Bodhgaya and Belchi massacres in 1979 and Pipra massacre in 1980 in Bihar, Mandsaur massacre in 1982 in Madhya Pradesh, massacre of 5 SCs at Karamchedu in Andhra Pradesh in 1984, massacre of 8 SCs at Chundur in Andhra Pradesh in 1991 are some examples of the same. Atrocities against Dalits always continued, however the decade of 70s and 80s was replete with increased atrocities against Dalits and saw some major movements against the same.  The rise of ‘Dalit Panthers’, a militant movement in Maharashtra in 1972, on the lines of the ‘Black Panthers’ of the USA was a result of the growing atrocities against Dalits. Due to its ideological weaknesses this movement dissipated, despite its initial promise and potential.

Thus, the demand for an effective law against atrocities was a long pending demand. The ‘Untouchability (Offences) Act, 1955’ which was later renamed as the ‘Protection of Civil Rights Act (PCR act) 1955’ was enacted after independence, but it proved quite ineffective in stopping the atrocities. As a result of the growing popular pressure, the PoA act was enacted on September 9, 1989. The rules for the act were notified on March 31, 1995. The law was amended in 2015 and made effective from 1 Jan 2016 with some better provisions like provisions to complete the inquiry and trial in 2 months each.

Contrary to many other laws where the acts of crime are often described in general terms like torture or harm, the SC/ST act lists down with precise details the acts of atrocities covered. The very fact that acts like “putting inedible or obnoxious substance into the mouth; dumping excreta, sewage, etc. in the premises of house; garlanding with footwear; forcing to remove cloths; fouling the water of a source of water; denying right to passage; prohibiting using common property; prohibiting mounting bicycle or horse or wearing footwear or entering place of worship; physical harm; dedicating woman to deity; intentionally touching a woman; forcing begar; forcing manual scavenging; forcing dispossession of land; forcing not to vote or vote for a particular person; forcing social boycott; insulting in public” are listed in the act is a testimony in itself to the fact that such crimes have been happening against the SC/ST. The act categorically states that the law is applicable only if the crime is committed against a member of SC/ST by a person who is not a member of SC/ST. The very nature of some of these acts by people from upper castes against people from SC/ST, like putting inedible substance in the mouth, garlanding with footwear, etc., puts them in the category of hate crimes in the name of caste without any doubt.

Reality of implementation of the SC/ST Act

The law could not stop the brutal massacres. The 1996 Bathani Tola massacre and 1997 Laxmanpur Bathe massacre in Bihar, Ramabai Ambedkar Nagar killings by Police in Mumbai in 1998, Manjolai labourers massacre in 1999 in Tamilnadu, Mianpur massacre in 2000 in Bihar, Khairlanji murders in 2006 in Maharashtra, Lakshmipeta killings in 2002 in Andhra Pradesh, Mirchpur murders in Hariyana in April 2010 are just some often cited examples.

Implementation of the law has been extremely poor everywhere in the country, owing to casteist and class prejudices of the state machinery. The reasons for the poor implementation are quite obvious.

(1) The bourgeois law is always out of reach for the working class, and the caste adds an additional barrier. This can be seen in the confession of a police officer that rate of filing of charge sheets in a court of law is inversely proportional to the income of the accused (Saini 2000). Most of the victims, being from the lower classes, find the access to police and judiciary out of their reach and do not even reach the police station to file a complaint. If they try, filing a First Information Report (FIR) under SC/ST act itself is a challenge. The police often refuse to register a case under SC/ST PoA act to avoid the political pressure of the upper castes and only after sufficient political pressure is built on behalf of the accused, a case gets registered. For example, a Dalit student named Dilip Saroj was beaten to death in Alahabad in February 2018. A CCTV footage of the same is also available. Despite of the gruelling evidence, the police registered a FIR only after public pressure was created. This is the case of a student in a big city. Consider what would be the case of poor, landless labourers in villages!

(2) The law mandates the government to provide a government lawyer to argue the case, but an effort to provide a good lawyer is seldom made. The inquiry by the police is often shoddy. There are instances where the court directed filing of cases against the police commissioner and district collector for negligence of duties. A study published in the Economic & Political Weekly, has noted that nearly 50% of cases filed under the PoA act do not go to court and are closed by the police. The Bombay High Court in 2017 noted that “there has been a failure on the part of the authorities in complying with the provisions of the Act and Rules….The abundant material on record proves that the authorities concerned are guilty of not enforcing the provisions of the Act.”

(3) When, finally, the case goes to court, there is no guarantee of an unbiased result. Instance of judges reflecting their casteist bias are not rare.  In the Bhanwari Devi case, the judges opined that upper caste people cannot rape a Dalit woman.  In Kailas vs. State of Maharashtra, even the Supreme court opined that “We are surprised that the punishment under atrocities act has been cancelled citing a hyper technical reason”.

Enough statistics are available to prove the poor implementation of the act. The law mandates speedy trial and delivery of justice. Section 14 of the requires setting up a special court in every district to try cases under the act. However, in 2015, there were only 194 such courts and only 14 states have set up these special courts. The reality is massive and increasing pendency of cases under PoA act. The number of pending cases grew from 31,932 in 2010 to 41,191 in 2016. Total number of cases up for trial in 2016 were 45,286. Each year from 2010 to 2016 has seen only 4,040 to maximum 8,406 trials complete per year. This shows that the state has little interest setting up special courts and speedy disposal of PoA cases and delivery of justice.

The average conviction rate in the cases of crimes against SCs is around 29 percent since 2006 and for STs, it is around 26 percent. This is quite low compared to the conviction rate for all Indian Penal Code (IPC) crimes which stands at nearly 42.1 percent. By 2016, there was a 10% increase in the number of cases of crimes against SCs, and a 6% increase in crimes against STs in comparison to the year 2010. As per NCRB in 2016, the national rate of conviction for cases filed under the SC/ST Act stood at 15.4%. In contrast, conviction rate under the Unlawful Activities (Prevention) Act stood at 33.3% and the Electricity Act was 89.8%. The figures are sufficient to show poor inquiries and defence of the cases by the state in PoA cases.

A cursory look at some of the recent cases and statistics from Maharashtra, which caught the media’s attention, shows the brutal nature of atrocities, that the law has been ineffective as a deterrence, the pendency of cases, and the reality of implementation of the act.

• Manik Udage from Pune was lynched to death for celebrating Ambedkar Jayanti on 14th April 2014. He was taken out of his house and beaten with steel rods to death. The case continues.
• On 26th April 2007 Madhukar Ghadge from Kuzhakajai village in Satara, Maharashtra was beaten to death by a group of 12 people for digging a well on land shared by all. All the accused were acquitted by the court.
• On 16th May 2015, Sagar Shejval, a nursing student from Mahar (Buddhist) community from Ahmednagar district in Maharashtra was killed for the ringtone of his mobile phone praising Dr. Ambedkar. Seating in a hotel, he was asked by the group of 7 upper caste men to change to ringtone and on refusing he was beaten to death. The accused,  belonging to the landholding Maratha caste could be arrested only in November 2015 and the case still continues.
• On 20th October 2014, in Jawakhede (Khalsa), Taluka Pathardi, District Ahmednagar, the entire family comprising the father, Mr. Jadhav who was a mason, mother and a son, of Buddhist faith, was killed brutally. The bodies of the victims were cut into pieces by the attackers. The case continues.
• On April 30, 2009 Rohan Kakade, a Mahar boy from Satara, was murdered by five men from an upper caste community for allegedly having an affair with one of the accused’s sister. The murderers chopped off Rohan’s head, burnt his body and dumped in nearby hilly area. All the accused were acquitted by the court.
• In a much highlighted and publicised case, all the accused in Nitin Aage murder case were acquitted by the court in 2017. Nitin, 17, allegedly in love with an upper caste Maratha girl, was killed on 28 April 2014 in broad day light in front of the village school, in front of the teachers and villagers, by the relatives of the girl and then hanged to a tree. The case got lot of media attention and democratic rights organizations in Maharashtra built a serious pressure for speedy disposal of the case. However, over the period of time all the witnesses, most of them from landowning Maratha caste, turned hostile and the court acquitted all the accused.
• The conviction rate under PoA act in Maharashtra depicts the pathetic state of it’s implementation. Overall out of 8698 cases filed from 2011 to 2016, the convictions happened in only 6.6% cases. It should be noted that Maharashtra ranks eight in the number of PoA cases in the country. The situation in states with highest number of atrocity cases like Uttar Pradesh, Bihar, Rajasthan, Madhya Pradesh is much worse.

Acquittals of all accused in cases of brutal massacres are not rare. Some of the often cited cases of such crimes from all over India are listed here:

• 6th August 1991: 13 Dalits killed in Chundur, Andhrapradesh. All accused were acquitted in 2014.
• 11th November 1998: 10 Dalits killed in Nagari Bazaar, Bihar. All accused were acquitted in March 2013.
• 25th January 1999: 22 Dalits killed in Shankar Bigha Gaon, Bihar. All accused were acquitted in January 2015.
• 11th July 1996: 21 Dalits killed in Bathani Tola, Bihar. All accused were acquitted in April 2012. The court resorted to this hilarious argument that the witnesses could not have been at the site of the crime, because if they were present they would have been killed.
• 16th June 2000: 32 Dalits killed by gunmen of Ranvir Sena, private army of the landholding caste, in Mianpur, Bihar. All accused were acquitted in 2013.
• 1st December 1997: 58 Dalits killed by Ranvir Sena in Laxmanpur Bathe, Bihar. All accused were acquitted in 2013.
• 11th March 2000: seven Dalits were burnt alive at Kambalapalli village in Karnataka. After six years, the sessions court acquitted all the 32 accused, after all 40 witnesses in the case turned hostile.

The question of ‘if the accused did not commit the mass murders, then who did?’, is perhaps the most irrelevant question for the Indian state!

To understand the caste bias of the state, the Nitin Aage case in Maharashtra can be contrasted with the Kopardi case, also from Ahmednagar, the verdict of which was announced in the same district court just a week after. In the Kopardi case a high caste Maratha girl was raped and murdered and the accused were from Dalit community. The incident sparked massive protests by the Maratha community. One of the demands in these protests was to dilute the PoA act. In the Nitin Aage the state never considered the demand for a reputed public prosecutor, while the Kopardi case was run by one of the most prominent public prosecutors. In Kopardi case the court sentenced all the three accused to death and in the Nitin Age case all accused were released free after all the witnesses turned hostile.

The Alleged Misuse of the Act

Every law gets misused, sometimes by the executive, sometimes by the people and sometimes by both. The SC/ST act need not be an exception. However, the demands for repealing only few such laws reflects the biases prevalent in the society. The huge hue and cry on the SC/ST act is a manifestation of the hatred that upper caste groups have for the rights of the SCs and STs.

The cry over misuse of the SC/ST act is not new. It has existed ever since the law came to life. Various upper caste pressure groups, political parties and right-wing organizations have been demanding dilution of the provisions, and at times scrapping of the law altogether. Recently the Maratha Kranti Morcha in Maharashtra, which organized around 60 rallies of the Maratha community demanding reservations also raised the cry that the act is being misused and ‘some’ of it’s provisions should be modified.

Some police officers have argued that according to section 4 of the act, if a police officer is prosecuted of negligence then he/she can be punished with jail for upto 1 year, so the act creates a pressure on police to take immediate action even if the case if false. However this particular provision is a non-cognisable offence. Not a single police officer has been punished under this provision so far.

As far as the cases of misuse of SC/ST act are concerned, it can be seen that in many cases the misuse was done on instigation by some upper caste members against their own rivals, by fleecing or subjugating members of SC/ST in filing a complaint. Cases have also been found where some upper-class or middle class members of SC/ST have filed cases to settle personal scores or to get undue advantages. Obviously, the poor, landless labourers who have no power to even use the law, definitely cannot misuse the law.

The act already provides for punishment to the complainant if the case is false, under section 182 of the IPC. Therefore, there was no need to redefine the meaning of false complaints by the Supreme Court. Further, contrary to the perception being created, in a case study conducted by the Home Department of Maharashtra in 2018, the investigators concluded that there is no evidence of the large-scale misuse of the act.

The Supreme court ruling does not cite any statistical evidence for the misuse of this act. The court has wrongly counted upon the large number of acquittals as false cases being registered instead of looking at the fact of lopsided police inquiry and other reasons like intimidation of witnesses, survivors, for large number of acquittals or false cases etc.

The supreme court judgement diluting the provisions of PoA act relies on National Crime Records Bureau’s (NCRB) Crime in India 2016 report. The report cites 6,256 ‘false cases’ under the PoA act. A recent study done in one of the states, published in Economic and Political Weekly (Khora 2018) shows the bias of the police machinery in recording the false cases. A comparison of crimes under Indian Penal Code (IPC) and PoA shows that ‘false cases’ and ‘true but insufficient evidence’ cases under IPC and PoA are inversely proportional. Under IPC, the ‘false cases’ figure is at 3.67% while under PoA the number is 13.58%. The proportion of ‘true but insufficient evidence cases’ under IPC is 19.86% while that under the PoA is 4.92%. Obviously Since the PoA does not allow the police to give a benefit of doubt to the accused using ‘true but insufficient evidence’ route, the cases are being closed as ‘false cases’. It should be noted that PoA provides for penal action under IPC for filing false cases, but the statistics show that the police did not push charges in 90% of the so called ‘false cases’. This clearly indicates that bias of the police in providing an escape route to the accused.

The same study mentions Rajinama or statements of withdrawal of the cases by the victims. The statements like “I did the rajinama on being told to do so by the villagers” or “The Deputy Superintendent of Police came to appraise of the situation and got me to sign on the rajinama paper.” or “The rajinama in my case was not justice in my eyes but I signed on it because the village people suggested that I do so”  show that the upper caste hegemony in the villages and the collusion of the police are forcing the underprivileged Dalits to withdraw cases.

Immediately after the supreme court ruling, on 29th March a Dalit youth was hacked to death in Gujarat for the reason of riding a horse. The flawed judgement of the supreme court will prove to be a curse for the landless Dalit masses who are subject to such atrocities every day.

Dilution of the SC/ST Act: Part of the Larger Anti-people Agenda of the Modi Government

The attack on SC/ST act must be seen as the part of the larger agenda of diluting all acts protecting civil and democratic rights of the people. On the one hand, the laws giving draconian powers to police and military are being strengthened and, on the other, not only the SC/ST act, but many other laws made for protection of rights of the people are being diluted by the fascist state now. Some laws are being changed in the parliament, while others are being changed by obtaining orders from the courts.

The labour laws are under increased attack and the government now plans to legalise contract labour hiring by the corporates. By changing the rules under Industrial Disputes Act and Model Standing Orders, the government plans to allow ‘Fixed Term Appointments’ in industry. This is nothing but legalisation of contract labour. In many states decisions have been taken to allow companies with less than 300 employees to fire employees without any notice, or to close the company. Some states have reduced this limit down to 100. The shameless governments are openly proclaiming that this is done to ‘attract foreign investment’. Indeed, the only way to invite foreign investors is by letting them suck the blood out of Indian labourers. The Code of Wages Bill, 2017 in Loksabha plans to merge the four existing laws related to workers and their wages, namely the (1) Payment of Wages Act, 1936 (2) Minimum Wages Act, 1948 (3) Payment of Bonus Act, 1936 and (4) Equal Remuneration Act, 1976. The new law will do away with the classification of workers into skilled, semi-skilled and non-skilled workers, thus affecting the wages of the skilled and semi-skilled workers. The minimum wages will be decided based on time, quantity of work, distance of workplace, etc disregarding the provisions related to nutrition, shelter, education, health, etc. The new law will allow employers to cut wages citing unsatisfactory work and disallow a criminal case on violation of the minimum wages. Children, too, are not spared. The BJP government, immediately after coming to power, in 2016 amended the Child Labour Act and allowed children to work in “family or family enterprises” and reducing the list of hazardous occupations for children.

It must not be forgotten that it is the need of the neoliberal and fascist regimes like the one in India, facing an economic crisis, that the civil, democratic and labour rights to be curbed as that is the only way to keep the discontent of the masses under control, while giving free hand to the multinational corporations for a free plunder of natural resources and labour power. The dilution of SC/ST act which deals directly with the rights of the working class communities, should be seen in this light.

Class Character of the Atrocities

The hereditary labour division among different castes started withering away rapidly as capitalism made inroads in Indian agriculture through the Prussian path. The development of capitalist mode in agriculture lead to development of class antagonisms between the land holding and landless classes. The caste tensions, already existing between the land-owning kulak upper castes and landless lower castes, now developed into a class contradiction. The land holding upper castes have been using their caste identity as a weapon in the acts of oppression against the landless people, mostly from the lower castes. Using their money and muscle power the land-owning kulaks are in a position to control and manipulate the state machinery and terrorise the landless labourers.

It is necessary to understand that it is the class contradictions that are taking the shape of caste conflict in the name of atrocities. Be it the atrocities by landowning Maratha caste in Maharashtra against Mahars and other SC/ST castes, against Madiga by Kamma caste in Andhra Pradesh, against Adivasis and Dalits by Ranvir Sena of Thakur caste in Bihar and other states, by Reddys in Karnataka and Andhra Pradesh, by Rajputs and Jats in Hariyana and Rajasthan and elsewhere, or anywhere else in India, it is the land-owning kulaks which have been at the forefront of atrocities. The only thing which connects all the incidents across various castes and geographical regions is their class character. The perpetrators of the crimes belong to the land-owning kulak class, while the victims belong to proletarian or semi-proletarian class. The class character of the crimes takes caste character as caste identity is a very potent weapon in the political struggle to keep the victims divided.

Once again, let’s take the case of Ahmednagar district in Maharashtra. The highest number of atrocity cases have been reported from this district. Due to this many organizations have demanded that Ahmednagar be declared an ‘atrocity prone area’. Ahmednagar happens to be district with very high capitalist development in agriculture and hosts prominent cooperative sugar factories, as a result of which a section of the landowning Maratha community in the district has reached an upper class status. This geographical skew also shows that the atrocities clearly have a class character.

In Bathani Tola a Ranvir Sena sympathizer, talking to the Hindu in 2012 justified the reactionary mobilisation of the upper castes saying “The land is ours. The crops belong to us. The labourers did not want to work, and also hampered our efforts by burning our machines and imposing economic blockades. So, they had it coming.”

In Khairlanji, the family of Bhaiyalal Bhotmange was brutally murdered by upper caste men, his wife and daughter were gang-raped and brutally murdered and both sons beaten up, paraded and killed. The accused were convicted for murder, but not under the PoA act! The investigators included many people from SC/ST categories, and the very nature of the crime is a casteist hate crime, but the case under PoA could not be proved. The reality is that the middle class that has emerged from SC/ST is willing to bow down to pressures of authority, money and class is clearly evident here. Secondly, the very class character of this Dalit middle class makes it conformist and beneficiary of the system and it stubbornly clings to its own privileges, even when it means betrayal of the victims of anti-Dalit crimes. Consequently, even if it has discontent against the casteist humiliation that it faces in the corridors of power, it is not willing to support or join any radical anti-caste movement. Finally, this class is totally alienated from the vast majority of the Dalit working masses and does not have any empathy for it. All these reasons became evident in the Khairlanji and many other cases of anti-Dalit atrocities, where the Dalit police officials, investigators or members of National Commission for SC/ST have colluded with the perpetrators of the anti-Dalit atrocities as well as the State, which clearly has a high-caste bias.

Witnesses turning hostile and cases being withdrawn is quite common in PoA related cases. This has much to do with the horribly time consuming and expensive legal process, which starts burning big holes in the pockets of the daily wage-earners who are often the witnesses to such crimes. Their very class position makes them vulnerable not only to fleecing and pressure, but to their own economic miseries, forcing to withdraw from the case. That bourgeois law is always out of the reach of the poor is most strikingly seen in PoA cases.

From the list of crimes mentioned in PoA act, except the public abuse clause, all cases of atrocities that deal with physical abuse and torture can be committed and are committed against the working class among Dalits, particularly in the rural areas. It is not possible for an urban middle class-upper caste person to garland another urban middle class SC/ST person with footwear. All instances of such brutal crimes clearly have their own class character.

The study on ‘false cases’ (Khora 2018) shows that in 12.56% cases, the complainant was a pawn used in the rivalry among the upper-castes. It is obvious that the upper classes are using  lower class persons as a pawn by using bribes, pressure or other kind of inducements. This underlines the class character of even the misuse of the act.

The atrocities happening today are not the same as the feudal oppression. It is a capitalist phenomenon. The perpetrators of atrocities do not belong to only those castes which used to be the feudal landlords. They belong not only to the upper castes, but also to the middle caste Other Backward Caste (OBC) strata, which used to be called kshudra in the earlier days. They themselves were subject to caste oppression in the feudal days. However, the capitalist transformation of agriculture allowed a section of these castes to become owners of land. The middle and rich farmers from the OBC castes also employ the Dalit labourers in their fields, who used to perform begar in the feudal era or were small share-croppers. It is these middle caste peasants who are the backbone of bourgeois politics in rural areas now. Being numerical majority, they dominate the election results. It should be noted that only a small section of these castes has converted itself into the capitalist kulak class, however a large majority of the toiling masses, semi-proletariat and small land owners associate with this kulak class due to their caste affiliations, in the absence of a correct revolutionary left paradigm.  That is why the fight against atrocities is not possible without the class struggle.

Class politics of Dalit organizations

Most of the so-called Dalit political parties, political fronts and organizations represent the interests of the Dalit urban middle classes and have nothing to do with atrocities that happen to the poor Dalit class. Be it the likes of Ram Vilas Paswan or Ramdas Athavale or Udit Raj¯they are today silent partners in the atrocities committed on lower classes of Dalits. Except a few, no Dalit or Ambedkarite political grouping is willing to take a radical position on the issue of atrocities. Almost all of them have had their part of relationship with the fascist BJP and RSS. They play only identity politics and serve the class interests of the bourgeoisie. They will take up issues of statues and memorials and caste-based reservations, and celebrate a Dalit becoming President with full energy, but will not dare confront the property-owning classes which inflict atrocities. They will take up the issue of a cartoon depicting Dr. Ambedkar, but will not confront the contemporary judgement acquitting all in the Bathani Tola case. These organizations which take up only identity-based issues are no different from the fundamentalist groups that oppose the cartoons depicting prophet Mohammed or Jesus Christ. A section of the Dalit lower classes is behind them without realising that these leaders are serving the interests of their enemies. The inaction by the large section of the Dalit middle class leadership is nothing but their class affiliations at play. The need of the hour is for working classes from all castes to understand the true politics of so called Dalit parties from Bahujan Samaj Party to Republican Party of India and unite under the banner of working class resistance.

Caste has historically served as a tool in the hands of the oppressing classes in India. Today it serves the bourgeoisie and is a potent weapon in their hands to keep the working class divided in the name of caste.  As Marx said in Capital, “Labor in the white skin can never free itself as long as labor in the black skin is branded.”, the working classes across all castes can never free themselves as long as the labour in Dalit castes is branded. Dilution of the SC/ST act is yet another assault by the Indian state not only the right of the Dalits, but part of the attack on rights of the entire working class. Only a class based anti-class movement can be the true answer to the atrocities and the very concept of caste itself.

References

1. Supreme Court’s SC/ST Act judgement: Legislative history of India’s attempts (and failures) to protect the downtrodden
2. Two tales of two very different murder trials, a Dalit and a Maratha 
3. Data on SC/ST Atrocities Act Points to Weak Implementation, Not ‘Misuse’
4. International Human Rights Law and the Menace of Atrocities on Dalit  Communities in India, by Aniruddha Vithal Babar
5. For residents of Bathani, it is a horror they cannot forget
6. Court acquits 11 in Nagari Bazaar massacre case
7. Mirchpur: A Dog Story
8. Rising pendency, falling convictions: what data on SC/ST Act trials show
9. Interview: ‘It is against logic to say Dalits will file false cases’
10. SC’s data on SC/ST Atrocities Act points weak implementation, not ‘misuse’
11. Khora 2018:
12. Misconstruction of the Anti-atrocities Act’s Misuse
13. Saini, Kamal (2000): Police Investigations Procedural Dimensions, Law and Methods, Delhi: Deep and Deep Publications
14. No evidence that most complaints under SC, ST Atrocities Act were fake: Police tells Maha govt
15. Supreme Court’s SC/ST Act judgment: Legislative history of India’s attempts (and failures) to protect the downtrodden