MOB LYNCHING: THE VITRIOLIC SOCIAL EVIL By- Ms. Rashi Sood (Assistant Professor) & Mr. Pranav Kumar Kaushal

MOB LYNCHING: THE VITRIOLIC SOCIAL EVIL
Authored By- Ms. Rashi Sood (Assistant Professor) & Mr. Pranav Kumar Kaushal
 
 
 
ABSTRACT
“All human beings are born free and equal in dignity and rights. They are endowed with the reason and conscience and should act towards one another in spirit of brotherhood.” – United Nations Charter 1945
 
The Constitution of India being the social and majestic document provides country with the status of being Sovereign, Socialist, Secular, Democratic and Republic. In a democratic country like India people have fundamental Rights, but in spite of all these Fundamental Rights and penal provisions, crime against certain religious minority is at its peak. The Hindus, The Muslims, The Christians, The Sikhs, The Parses, The Jews and the population belonging to the different economic and social strata which add to the secular and diverse culture of India are now under the constant threat of mob lynching. They being under the fear of beaten up or killed in the name of the religion or what they eat or trade in. The principle of Unity and Integrity incorporated in the Preamble of the Indian Constitution just seems to have been vanished with crime of mob lynching in the recent scenario. The social fabric of the Indian culture is under the threat of rupture increasing incidents of mob lynching and rising vigilantism. Because of the lack of central legislation specific to mob lynching, these incidents go un recorded and the hate element behind them goes unaddressed. The present article aims to understand the underlying cause of mob lynching and the criminal threat arising out from such incidents. Such incidents have given a rise to the unwanted issue not only at the National level but in the global level as it is threat towards humanity, religion, culture and nationality. Based upon such analysis the present article attempts to address broader issues pertaining to the need of separate legislation to curb the crime of mob lynching.
 
KEYWORDS: FUNADMENTAL RIGHTS, MOB LYNCHING, INTOLERANCE RELIGION, SECULARISM AND UNITY
 
 *ASSISTANT PROFESSOR, SCHOOL OF LAW, BAHRA UNIVERSITY AND LLM 2ND SEMESTER, SCHOOL OF LAW, BAHRA UNIVERSITY, SHIMLA HILLS
 
 
I.                 INTRODUCTION
Mob lynching is a blatant and vitriolic practice in violation of rule of law which cannot become the order of the day in the name of cow protection and killing an innocent person in the name of religion. These incidents of mob lynching clearly reflect intolerance in a democratic society due to the dogmatic thoughts of certain group of people. The constant increase in such incidents have weaken the pillars of the Indian Constitution. The expression enshrined in the Indian Constitution i.e. ‘We the People of India’ is being questioned as the lynching of mob connotes the absence of ‘We’ feeling among people. Similarly, the expression such as Sovereignty, Secularism, Fraternity, Unity and Integrity are widely criticized whenever the issue of mob lynching comes into light. Thus, the State is under the Constitutional mandate to maintain law and order among citizens. The state also holds the responsibility to protect the life and property of the citizens. The alarming rise in the incidents of mob lynching and failure of the state to prevent the victims has forced the apex court of the country to term it as a “Horrendous of Mobocracy”. The Apex Court has issued notice to the Central Government, State Governments and National Human Rights Commission on dated 26th July 2019 on a plea seeking implementation of the Supreme Court’s judgment in Tehseen S. Poonawalla v Union of India where court has given directions to the aforementioned authorities to take preventive, remedial and punitive measures in order to curb this grievous incident of mob lynching. The Honourable Supreme Court in the landmark case of Tehseen S. Poonawalla v Union of India[1] observed that,
 
18. “Lynching is an affront to the rule of law and to the exalted values of the Constitution itself. We may say without any fear of contradiction that lynching by unruly mobs and barbaric violence arising out of incitement and instigation cannot be allowed to become the order of the day.  Such vigilantism, be it for whatever purpose or borne out of whatever cause, has the effect of undermining the legal and formal institutions of the State and altering the constitutional order. These extrajudicial attempts under the guise of protection of the law have to be nipped in the bud; lest it would lead to rise of anarchy and lawlessness which would plague and corrode the nation like an epidemic. The tumultuous dark clouds of vigilantism have the effect of shrouding the glorious ways of democracy and justice leading to tragic breakdown of the law and transgressing all forms of civility and humanity. Unless these incidents are controlled, the day is not far when such monstrosity in the name of self-professed morality is likely to assume the shape of a huge cataclysm. It is in direct violation of the quintessential spirit of the rule of law and of the exalted faiths of tolerance and humanity.”
 
Thus, mob lynching is an affront to the rule of law and to exalted values of the Constitution itself. The increase in the incidents of mob lynching is just like the tumultuous dark clouds of vigilantism that has shrouded the glorious ways of democracy and justice leading to the tragic breakdown of the law and transgressing all forms of civility and humanity. It is direct violation of quintessential spirit of the rule of law and exalted faith of tolerance and humanity. Therefore, the incidents of mob lynching clearly slam upon the Constitutional objectives and principles enshrined under the Indian Constitution. If no strict penalties to be inflicted with regard to the incidents of mob lynching the time will come where people do not approach to the courts but prefer to be happy in mob justice and the time will come when India would be called rather to a republic state to be as state of lynching.
 
II.            MEANING OF MOB LYNCHING
The term lynch means, “bringing life of a person to an end for an alleged offence without abiding by the legal trial.” The Oxford English Dictionary defined lynching, “as the act of killing done by a mob without any legal authority involved.” Black Law Dictionary has defined lynching as, “A descriptive of action of unofficial person, organized bands, or mob, who seizes persons charged with or suspected of crime or take them out of the custody of the law and inflict summary punishment upon them, without legal trial and without the warrantor authority of law.” Lynching is a form of violence in which a mob under the pretext of administering justice without a trial executes a presumed offender with a corporeal and incorporeal punishment. In common parlance lynching occurs when a group of people has preconceived notion that a person has committed a crime and punishes such person without any judicial trial or conviction. The term mob lynching is used to describe the acts of targeted violence by a massive group of people. The said violence tantamount to be an offence against human body and property. Mob lynching unlike riots are not acts of mass killing rather a decentralized violence to a large extent which involves two primary forces in order to commit such crimes. First one is the intent of the majority to align minorities behaviour with their expectation and the second is the constantly growing distrust in the promptness and efficiency of judicial system. Thus, it can be either a group of people perturbed by bad governance or lack of access of justice who take law in their hands or it may be group of disillusioned citizens who identify themselves with the cause and initiate parallel justice delivery mechanism based on what they perceive as morally right or wrong.  Mob lynching and vigilantism need to be prevented and same can be done by taking strict action against the wrongdoers. Mob lynching is a reflection of intolerance in a democratic society due to the dogmatic thoughts of certain group of people. In recent years the unfortunate increase in the incidents of mob lynching have led us to think if our country has lost its ability to sustain diverse culture. These incidents have raised questions on our Constitution being Secular which is considered as the basic structure of the Indian Constitution. Every individual has a right to live with dignity, humanness and unity in a civilized society and crimes like mob lynching violates the inherent right to life protected under Article 21 of the Indian Constitution. The heinous act of mob lynching is an encroachment to the personal liberty and constitutional goals enshrined in the Preamble of the Constitution of India.
 
III.       MOB LYNCHING: THE HATE ELEMENT
Hate Crimes like mob lynching is a product of intolerance, ideological dominance and prejudice ought not be tolerated which has resulted in the reign of terror.  Non- State actors and extra judicial elements cannot be allowed to take place of law or the law enforcing agency. A bigoted approach with fabricated identity always results in proactive sentiments and display of reactionary retributive attitude transforming itself into dehumanization of human beings. One’s man freedom of thought, expression, belief, faith, worship, conscience and personal choice if not being tolerated by the other person in the civilized society is due to the lack of objective rationalization of acts and situations. In this regard Benjamin Franklin aptly said that, “Freedom of speech is the principal pillar of a free government, when this support is taken away, the Constitution of free society is dissolved and tyranny is erected on its ruins.”  Freedom of speech and expression in different form is vital for sustenance of all other rights and is very seed for germinating the growth of democratic views. Plurality of views and voices support and celebrate the constitutional idea of liberal democracy which ought not be suppressed. Thus, pluralism and tolerance are essential virtues which constitute the building blocks of a truly free and democratic society which cannot be broken up into fragments by narrow domestic walls of caste, creed, colour, religion and sex. Intolerance arising out of dogmatic mindset sows the seed of upheaval and has a chilling effect on freedom of thought and expression. Hence tolerance has to be fostered and practiced and not allowed to be diluted in any manner.
 
Even though the incidents of mob lynching may be recorded in different penal provisions of the Indian Penal Code but still the heinousness and seriousness of the offence of mob lynching goes unnoticed. Mob lynching cannot be reduced to the offence of rioting or murder but it is an act of extrajudicial killing which involves hate towards particular religion, caste, race etc. This hate element which goes unrecorded is so immense that people taking laws in their hands to lynch other humans is often seen helpless against them. If these acts are done in furtherance of agendas of a particular organization, political party then profounder of such agendas must be charged. In order to properly define the hate element in the offence of mob lynching it is important to have separate legislation for the offence. A group of academicians has drawn a parallel line between the offence of acid attack and mob lynching. The Criminal law Amendment Act 2013 introduced Section 326A and Section 326B to the Indian Penal Code. It was reasoned by the legislative body that even though acid attacks were being addressed under the provisions of grievous hurt in the code but the nature of offence was such that it need a separate provision. Similarly, the punishment prescribed for the offence of lynching in the code are inadequate to deal with physical and mental trauma faced by the victim. 
 
IV.        HISTORICAL BACKGROUND OF MOB LYNCHING IN USA & INDIA
The historical traces of mob lynching incidents in United States of America clearly reflected that lynching took gruesome familiarity of terrorism where one community dominates over the another. Lynching by the end of 19th century become a familiar and stylized pattern. Torture, public murder and delighted crowd came to define lynching. These elements constituted a pattern which regularized the practice of lynching in black communities. The pattern reinforced lynching power to regulate black behaviour. According to many psychologists, “Children who witnesses violence in their early life would come to see the world as the dangerous and unpredictable for their survival. The problem that these children suffer can affect their ability to function normally in their home and at school. Sleep disturbances, flashbacks emotional detachment problems are routinely reported symptoms of children who have been exposed to such violence.”[2]
 
The first recorded lynching case of USA was in St. Louis in the year 1835, where a Black man named as Mcintosh who killed a deputy sheriff while being taken to jail was captured, chained to tree and burned to death on a Conor Lot Downtown in front of a crowd of 1000 people.[3] In 1862 the members of abolitionist movement who opposed slavery were the victims of mob violence. This lynching was perhaps the largest lynching in the History of USA in which 41 men were lynched to death without any trial.[4] On May 19, 1918 a mob of several hundred people brought Mary Turner to Folsom Bridge tied Mary’s ankle hung her upside down from a tree doused her in gasoline and motor oil and set her fire. She was still alive when a member of the mob split her abdomen open with a knife. Her unborn child fell on the ground was stomped and crushed. The mob did not stop here, Mary’s body was riddled with hundreds of bullets.[5] In another incident Jim Mclherron was an African American man who was tortured and executed by a lynch mob in retaliation for shooting and killing two white men after a fight broke out. The mob took Mclherron chained him to a tree and used hot irons to force a confession as well as to implicate another African American in the crime. Mclherron was never due process of law but the lynch mob decided to have some fun and they poked his eyes out. No effort was made to stop lynching.[6] In another incident Jesse Washington, a 17-year-old African American youth was lynched in the country seat of Waco. Jesse Washington was charged for raping and murdering Lucy Fryer the wife of white employer in Texas. He was chained by his neck and dragged out of the country by the mob. He was then paraded through the street all while being stabbed and beaten before being held down and castrated. Over 10,000 spectators gathered to watch the attack. Members of the mob cut off his finger and hung him over a bonfire after saturating him with coal oil.  He was repeatedly lowered and raised over the fire for about two hours. After the fire was extinguished, a professional photographer took pictures and printed and sold as postcards in Waco.[7] On 28th August 1955 Emmett Louis Till a 14-year-old African American was lynched in Mississippi after being accused of offending white woman in her family grocery store. The brutality of murder and the fact that his killers were acquitted drew attention to the long history of violent persecution of African Americans in United States.[8] In another incident on dated 7th June 1998 James Byrd an African American was murdered by three white Supremacists in Texas. The three men took James Byrd out of the town beat him severely, spray painted his face, urinated and defecated on him and chained him from his ankle to their pick-up truck dragging him for 5 Kms. The autopsy report suggested that Byrd throat had been slashed, ribs were fractured and he died about halfway while dragging.[9] On February 23rd 2020 Ahmaud Marquez Arbery a 25- year- old black man was murdered in Georgia by three white residents. These accused chased him and falsely imprisoned him and finally assaulted Arbery with a shotgun three times in his head. The family of deceased claimed the event of lynching which was performed in the middle of the day which showed the pattern of unfair treatment based on his skin colour.[10] In another incident on May 25, 2020, George Floyd a 46-year- old black man was murdered in the U.S City by a white police officer. Floyd had been arrested on suspicion of using a counterfeit 20$ US Bill. The police officer knelt on Floyd’s neck over nine minutes while Floyd was handcuffed and lying face down in a street. Prior to being placed on the ground Floyd exhibited signs of anxiety, complaining about claustrophobia and being unable to breathe. Thus, lynching of Floyd murder led to worldwide protest against police brutality, police racism and lack of police accountability.[11]
 
The historical database of India clearly states that there have been number of factors behind increasing incidents of mob lynching in India. Factors like Hindu-Muslim conflict, Cow Vigilante Religious vendetta, Communal Politics, Caste based discrimination, non- tolerance for an opinion towards politics, religion, sexual orientation, abuse of technology, Fake news etc., are some of the contributory factors behind the mob lynching history India. Some of the incidents of mob lynching that took place in India are discussed below: -
 
1.                  LYCHING OF 5 DALITS AT JHAJJAR HARYANA 2002: “In an incident that occurred on 17th October 2002 in Jhajjar District of Haryana five Dalits all in their twenties were beaten to death on 15th October 2002. The victims were reported to have been dragged by a mob out of the police post where they had taken refuge and lynched in the presence of city magistrate, block development officer and Deputy Superintendent of Police. It was stated by police that five persons named as Tota ram, Raju, Daya Chand, Kailash and Virender carrying animal hides and a cow in a vehicle. They stopped near Dhulina and started removing the skin of cows on the roadside. About 40-50 persons who have gathered there however thinking that the cow was being slaughtered by five persons gave them a severe beating. The five persons were taken to the police station and case was registered. In the meantime, the mob which had grown in the size to about 400-500 became extremely violent and threw brickbats and stones at the police personnel who were present injuring many of them. The mob entered the police station and lynched all the five- person beaten to death.”[12] 
 
2.                  KHERLANJI LYNCHING 2006: “The massacre refers to the murder of four Schedule Caste Citizen by the villagers of Kherlanji. The incident took place in a small village in India named as Kherlanji located in the Bhandara district of the state of Maharashtra. It was on 29th September 2006 when four members of the Bhotmage family belonging to Schedule Caste were murdered. The women of the family Surekha and Priyanka were paraded naked in the public before being murdered. Enraged by a police complaint lodged on 28th September 2006 by Surekha over a land dispute the accused dragged out Surekha two of his sons and daughter out of their house and paraded naked in the village and then hanged to death.  The verdict in the Kherlanji case was pronounced on 15th September 2008 by the Bhandara Session Court and has held eight people guilty of murder and acquitted three.  On 24th September 2008 six people were awarded the death sentence while the other two were given life imprisonment. The ruling of the Session Court was appealed in the High Court where the Nagpur Bench commuted the death penalty and awarded to six convicts to a 25-year rigorous imprisonment.”[13]
 
3.                  TABREZ ANSARI LYNCHING CASE: A 24-year-old Tabrez Ansari was brutally thrashed by a Hindu Mob for several hours on June 17, 2019 in Jharkhand. After being asked to disclose his name, he was tied to a pole and thrashed and made to chant “Jai Shri Ram.” The next morning instead of ensuring immediate medical care for Ansari, the police locked him up on the charges of theft. His relatives requested the police officers to take Ansari to the hospital. Police reportedly told them that they would break his bone and lock him up too if he did not go away. Four days later Ansari succumbed to his injuries and it was only then that the file police filed a case against the assaulters.[14]
 
4.                  AYUB KHAN LYNCHING CASE: “The 2017 Nowhatta mob lynching case refers to the lynching murder and mutilation of an on duty undercover Indian Police Officer in Jammu and Kashmir Muhammad Ayub Pandith on 22nd June 2017 by the mob in Nowhatta. Deputy Superintendent of Police Mohammed Ayub Pandith who worked in the security wing of Jammu and Kashmir Police was deployed in civilian security as a part of security for the devotes attending the night long prayer in Jama-Masjid. IANS quoted informed sources stating that he was on frisking duty when he was attacked. He had been posted for quite some time and many locals who regularly visited the mosque knew him. The mob on 22nd June started shouting slogans in support of Pakistan. It was reported that slogans had been recorded by Ayub Pandith. Ayub Pandith then was spotted by four miscreants when he came out checking deployment for access control duties. They called and questioned him and later demanded to show his identity card but he refused to show. He was then heckled by the mob who was present there and in response to this he fired some shots with his service rifle injuring three people. The mob continued to beat him resulting in the death of Ayub Pandith. As per the statement recorded by the police after the incident, it was stated by one of the eyewitnesses that rumours were spread that he was a non-Muslim belonging to the security agencies and had been targeted because the crowd thought him to be Kashmiri Pandit due to his surname. On 23rd June 2017 after the incident, a heavy enforcement of Jammu and Kashmir police along with the Central Reserve Police Force had to resort to fire several shots in the air to safely recover the mutilated corpse of slain Deputy Superintendent of Police who was lying naked in the vicinity of Jamia Masjid. FIR No51/2017 was immediately registered under section 302 and after a long investigation on 24th June 2017 twenty suspects were arrested. The trial of all these twenty suspects is being taken place in Srinagar Session’s Court and matter is still pending.”[15]
 
5.                  PALGHAR LYNCHING CASE 2020: The incident occurred on the night of April 16, 2020 when two ascetics, 70-year-old Mahant Kalpavruksha Giri and 35-year-old Sushilgiri Maharaj who stayed in Ashram in Kandivali decided to go Surat to attend a funeral. The two Sadhus subsequently hired car driver Nilesh Yelgade 30-years-old to travel from Kandivali to Surat. In an attempt to avoid being stopped on their journey the three appeared to have taken back roads of Palghar district to enter Gujarat rather than use Mumbai-Gujarat Highway. The three were however stopped by a sentry of Forest Department close to Gadchinchle village. While they were speaking to the sentry the three were accosted by a vigilante group and were assaulted. Now over the past few days local villagers had formed vigilante group after rumours that organ harvesting gangs, children’s lifters and thieves were operating in these areas at night. Thus, this was the reason why villager vigilante group attacked them. As per the official account a team of four police officer have reached the spot and tried to pacify the mob. By then mob had overturned the car in which the three were travelling and even threatened the police officials. Subsequently another police contingent reached on the spot. The 12 policemen managed to rescue the three men and made them to sit in two separate vehicles. However, the frenzied mob of round 400 people attacked the police vehicle and managed to pull out the three persons and they were subsequently lynched. However, the videos emerged out on social media platforms showed that police officials were standing mutely when the mob attacked the three. The police so far in this incident has arrested more than 101 people and trial of all these have not been completed yet.  At present, 251 adults were arrested and 15 juveniles held. Among those arrested 75 who allegedly who played a major role are still behind the bars. The CID has issued 52 Lookout notices as they are still absconding and are being searched by the police.”[16]
 
 
V.             CONCLUSION
Mob lynching unlike riots are not acts of mass killing rather a decentralized violence to a large extent which involves two primary forces in order to commit such crimes. First one is the intent of the majority to align minorities behaviour with their expectation and the second is the constantly growing distrust in the promptness and efficiency of judicial system. Thus, it can be either a group of people perturbed by bad governance or lack of access of justice who take law in their hands or it may be group of disillusioned citizens who identify themselves with the cause and initiate parallel justice delivery mechanism based on what they perceive as morally right or wrong.  Mob lynching and vigilantism need to be prevented and same can be done by taking strict action against the wrongdoers. In recent years the unfortunate increase in the incidents of mob lynching have led us to think if our country has lost its ability to sustain diverse culture. These incidents have raised questions on our Constitution being Secular which is considered as the basic structure of the Indian Constitution. Every individual has a right to live with dignity, humanness and unity in a civilized society and crimes like mob lynching violates the inherent right to life protected under Article 21 of the Indian Constitution. The heinous act of mob lynching is an encroachment to the personal liberty and constitutional goals enshrined in the Preamble of the Constitution of India.  India being a secular nation cannot tell non-Hindus as what to eat and what not to. Crime has no religion and neither the preparator nor the victim can be viewed through the lens of caste, creed, colour, religion, sex or place of birth. In an approach based upon Constitutional legitimacy the right to life and personal liberty has been considered paramount so as to ensure sustenance of higher values of democracy thereby paving the path for spontaneous Constitutional order. The state has the primary responsibility to foster secularism, pluralistic and multiculturalist social order so as to allow free play of ideas and beliefs and co-existence of mutually contradictory perspectives. Mob lynching is a creeping threat that has gradually taken the shape of typhon like monster as evidenced from rising wave of incidents and recurring patterns instigated by intolerance by circulation of fake news and false stories. Thus, in such situation it is important to preserve and maintain unity amongst the citizens of the country who belong from different strata of the society. It is important that our country should sustain, exalt and celebrate the feeling of solidarity and harmony so that the spirit of oneness is entrenched in the collective character. Unity in the context implies unity amongst the citizens whereby citizens embrace the feeling of ‘We’ with the sense of bonding with fellow citizens which would definitely go a long way in holding the Indian society together. Thus, for a nation to survive without being whittled down by the incidents of mob lynching it is necessary that all must embrace the sentiment that are essential constituents of diversity that galvanizes unity and respects pluralistic perceptions in Constitutional ethos.
 

[1](2018) 6 SCC 72 Para 18.
[2] Sherrilyn A. Ifill, “Creating a Truth and Reconciliation Commission for Lynching” published in the Minnesota Journal of law and Inequality Volume 21 Issue 2, December 2003 Pg 291.
[3] William Hyde and Howard L. Conrad, “Encyclopedia of the History of St. Louis: A Compendium of History and Biography for Ready Reference”: Volume 4. New York: Southern History Company, 1899; pg. 1913.
[4] McCaslin, Richard B. Tainted Breeze: The Great Hanging at Gainesville, Texas 1862, Louisiana State University Press, 1994, p. 81
[5] Williams, Phillip "Mary Turner and the Lynching Rampage of 1918 Reexamined" Wiregrass Region Digital History Project, (18 May 2018), https://sites.google.com/view/wiregrassrdhp/mary-turner accessed on dated January 15, 2023 at 11: 20PM
[6] White, Walter F "Burning of Jim Mclherron: An N.A.A.C.P. Investigation". The Crisis: A Record of the Darker Races Penguin. pp. 127–128. ISBN 978-0-593-18300-7.
[7]James M (2007) "The "Waco Horror": The Lynching of Jesse Washington". In Bruce A. Glasrud; James Smallwood (eds.). The African American Experience in Texas: An Anthology. Texas Tech University Press. ISBN 978-0-89672-609-3.
[8] Wright Thompson, “His Name was Emmett Till” The Atlantic, September 2021 https://www.theatlantic.com/magazine/archive/2021/09/barn-emmett-till-murder/619493/ accessed on dated January 17, 2022 at 11:52 PM
[9] King, Joyce. Hate Crime: “The Story of a Dragging in Jasper, Texas” Random House, Inc., 2002  ISBN 0-375-42132-7 .
[11] Evan Hills, Drew Jordan, “ How George Floyd was Killed in the Police Custody”, New York Times published on 31st May 2020, https://www.nytimes.com/2020/05/31/us/george-floyd-investigation.html accessed on dated 23rd January 2023 at 10:50 PM.
[12] National Human Rights Commission of India, “Killing of Five Dalits at Jhajjar Haryana”, 19th November 2003 https://nhrc.nic.in/press-release/killing-five-dalits-jhajjar-haryana-0 accessed on dated 6th January 2023 at 12:30PM
[13] S. Viswanathan, “Khairlanji: The crime and punishment”, The Hindu, 10th November 2016 https://www.thehindu.com/opinion/Readers-Editor/Khairlanji-the-crime-and-punishment/article16149798.ece accessed on dated 7th January 2023 at 12:30PM
[14] PTI, “Jai Shri Ram: The Hindu Chant that became a murder cry” BBC Hindi (10th July 2019) https://www.bbc.com/news/world-asia-india-48882053 accessed on dated 25th January 2023 at 01:00 PM).
[15] Express Web Desk, “Ayub Pandit Lynching Case” The Indian Express 24 July 2017, https://indianexpress.com/article/india/ayub-pandit-lynching-case-20-held-so-far-one-killed-in-encounter-with-forces-says-ig-4764485/  accessed on dated 08th January 2023 at 04:00 PM
[16] Zeeshan Sheikh, “Palghar Lynching: A Recap of What Happened” The Indian Express April 24, 2020 https://indianexpress.com/article/explained/palghar-mob-lynching-mahant-kalpavruksha-giri-6370528/ accessed on dated 29th January 2023 at 09:00 AM.