The prejudice against the ‘out-groups’ or ‘others’ is an age-old phenomena, probably existing since human beings started banding together for survival. In ancient times, this served an important function of ensuring a group’s existence in the face of limited resources. Modern society received this as an inheritance, and it continues to fuel our social norms and values. The prejudice-motivated violence also boasts of a long history and is in no way a modern phenomenon. However, due to globalization, increasingly multicultural and diverse societies are becoming a norm, where this violence, if unchecked, can damage the social fabric. Prejudice and violence against a certain group, ideology, etc. have always been a part of society. Research indicates that hate and aggression have been a continuing feature of human behavior. Violence has always been used by the dominant social structure. State uses violence to maintain cultural statis. The term ‘hate crime’ has a short history, having been adopted by the US civil rights movement but a long tradition, as it sheds light on violent acts and harassment motivated by hatred and bias against the minority groups which were hidden, ignored, and sometimes even justified.
Hate crimes are targeted against persons due to their demographic and cultural status and perpetrator’s bias motivation. A hate crime is essentially a conventional infraction that is supplemented by the biases of the perpetrator. Hate crime may also be operationally defined as a “criminal offense against a person or property motivated in whole or in part by an offender’s bias against a race, religion, disability, ethnic origin, or sexual orientation”. Both definitions do not criminalize hate (as the critics of hate crime laws opine that by criminalizing a belief; as in this case hatred; these laws obstruct freedom of speech and other civil liberties) but criminalize traditionally criminal acts motivated by a bias or hate against a group.
The concept of ‘hate crime’ describes acts which doesn’t only affect the direct victim, but which also lead to fear and trauma in communities and damage the social and national integrity.
The adoption and implementation of hate crime related legislation across the world exists along a continuum. Many nation-states have institutionalized hate crime within their criminal penal provisions, but it suffers from under-reporting, laxity in investigation and sentencing, and lack of proper recording of incidents. In the Indian context, there has recently been an increase in focus on hate crime within the academia, legal fraternity, and civil society partners. This, however, has received disproportionately low engagement and interest from the government of the country.
Across the world the incidence of hate crimes has gone up. Hate crimes are ubiquitous in nature, present across the world. Across a wide range of sociocultural traditions, socio political histories, political systems, and economies, the incidence of hate crime prevails. The context of the crimes, type of violence, and target group may differ from society to society, but these crimes are a universal phenomenon. Throughout history, the incidence of hate violence has fluctuated, there have been periods and places characterized by cohesive and peaceful intergroup relationships rather than strife. The opposite is also true, where hatred and violence have primarily characterized intergroup relationships. Increasing prevalence of this hate-based violence and initiatives to curb it has necessitated an informed approach to hate based violence.
Anhad’s Report shows that from 2014-22, 878 cases of hate crime (46%) and hate speech (54%) have occurred in India. Like the multi headed Hydra, hate based crime manifests itself in many forms for instance murders to lynching in the name of cow protection, attacking minorities for imagined or real slights against the majority’s religion, violent attacks against interfaith couples, vandalizing of minorities’ places of worship and business, cyber hate speech, flouting modesty of women via trolling, simulated online auctions etc., the list keeps evolving with new ways to express hatred. The report also highlights the role of Hindutva groups affiliated to the ruling party as the main facilitators of hate-based crime and speech. The recent international diplomatic crisis faced by Indian government owing to remarks by ruling parties’ members against Muslims should be a wakeup call for the government. These hatred filled diatribes against minorities by the politicians, national media and civil servants is once again not a new trend. A report by NDTV shows a 500% increase in incitement of communal hatred by politicians from 2014 to 2019. Another worrisome trend is the increase in proportion of hate crime over hate speech in the recent years. ???
After incidents of attacks and intimidation of students from Kashmir in different parts of the country after Pakistan’s win over Indian cricket team in the T20 World cup, the J&K Students’ Association demanded blacklisting colleges with a history of hate crime. This leads to undoing of Indian government’s efforts to attract J&K youth to pursue higher education through scholarships etc.
‘BulliBai app’ and ‘Sulli Deals” cases have also highlighted the increasing levels of bigotry towards Muslim women perpetuated by alt-right traditionalist group promoting genocide against minorities. These are in no way isolated incidents; they highlight how hate is permeating Indian society at all levels. Though hate crime has always been a part of society but in the recent times it has become far more prevalent and more disturbingly it has gained mainstream acceptance amongst the governing as well as the governed. Historically, there are analogous situations where these upward trends in hate crime and speech have led to more widespread violence and in some cases extermination of minorities.
The situation demands an institutional response from the government, enacting laws to sanction hate crimes is becoming need of the hour. Hate crime laws are fundamentally severe than non-prejudiced crime as these crimes are more likely to provoke reactionary crimes, are more emotionally harmful and create unrest in the community. Due to this, hate crime laws are critiqued on grounds of being a source reinforcement of divisions and conflict in the society. From the psychological perspective too, hate crime laws need to first understand the hate crime along the parameters invoked in the following discussion and secondly formulate well informed laws and statutes that will command greater compliance.
The paradigm of hate crime includes both crimes against person as well as against property, and hate speech also is one aspect. Overall, the concept is very wide, the present paper focuses only on hate crime against persons and laws for such crimes. This paper aims to establish and cement the need of an institutional response to hate crime separate from the existing paradigms by pointing out the salient differences between hate crime and normal crime as informed by psychological research. The paper also reviews the international conventions pertaining to hate crime that bind India and establish that in absence of a national legislative framework, it is very difficult to ensure accountability of the government.
Origin of the Term
The term ‘hate crime’ came into existence in the mid-1980s. The term was coined by John Conyers, Barbara Kennelly, and Mario Biaggi, when they co-sponsored the bill titled ‘Hate Crime Statistics Act’ in the United States House of Representatives. The bill sought to require the US Department of Justice to collect and publish statistics on the quality and quantity of crimes motivated by various racial, religious, and ethnic prejudices. The concept came into being as a result of increased consciousness about extending rights to various disadvantaged groups (on the basis of race, ethnicity, gender, sexual orientation etc.). The recognition of the concept was furthered by United States’ Hate Crime Statistics Act of 1990, which recognized hate crime as a bona fide category of crime.
Within the legal academia, the term gained popularity in the early 1990’s. The hate crime statutes were one of the ways that the society was beginning to condemn the inequalities based on race, ethnicity, gender, sexual orientation etc. These statutes take the initiatives against prejudice to the ambit of crime as well. These laws do not benefit the disadvantaged groups by way of lesser punishments but aim to punish the offenders motivated by prejudice more severely.
It is unfair to assume that the current attention towards hate-crime is due to intolerance reaching epidemic levels only but it is also due to increased sensitivity towards prejudice and condemnation of resultant actions.
Hate crime v/s Traditional crime.
A major critique of hate crime laws is that hate, or prejudice is “no more morally reprehensible than other criminal motivations like greed, power, lust, etc.”, hence, such laws may be deemed as unfair, unnecessary, and unconstitutional. It may also be argued that such laws may be against the fundamental ideal of equal protection under law, as it creates a special class of victims given a differential treatment. However, the research suggests that hate based crime and non-biased crime differ on parameters like perpetrators, violence and trauma caused to the victim as well as the community.
Hate crimes are more likely to be crimes against persons rather than property. As compared to non-biased crime, hate crime are more likely to involve multiple offenders, to cause injury and to require hospitalization.
Type of perpetrator
Offenders may be classified on the basis of type of violence committed i.e., instrumental violence and reactive violence. Instrumental violence is goal oriented, purposeful, and more likely to be targeted at strangers whereas reactive violence as the name suggests occurs as a reaction to perceived or actual threat or aggravation. A cold blooded murder is an example of instrumental violence while a murder under grave and sudden provocation is an example of reactive violence.
On the surface, hate crimes may be classified as a type of reactive violence motivated by the perceived threat, the victim and/or victim’s group may represent. On this ground the offender may seek relief under provisions for self-defense. But the research shows a nexus between bias motivation and instrumental nature of violence. Dunbar, Quinones & Crevecoer found a positive correlation between bias motivation in 58 criminals convicted of hate crimes and instrumental violence. 79% of the hate crime murderers also showed instrumental violence. Higher the bias motivation in the homicide, higher were the chances of premeditation of the crime. Dunbar reports significant component of premeditation and goal orientation in hate motivated crime. Explicit bias motivation was found to be strongly correlated to instrumental hate violence. Hate crime contributes to enhancement of aggressor’s self-esteem and improves their status within their subgroup.
According to McDevitt et al, classification of hate crime offenders, most common types i.e., the mission offenders use some form of weapon which again relates to some degree of premeditation on the part of the offender.perpetrators are linked with higher violence and psychopathy. Psychopathy levels are correlated with higher violence, higher chances of recidivism and lower chances of rehabilitation.
The victim of any crime suffers from both physical as well as psychological trauma. The following section deals with the question: “Whether the victims of hate crime and non-hate crime differ in the trauma experienced?”
Alexander et al shows that the psychological impact of victimization is more adverse in hate crimes as compared to non-biased crimes. Victims of hate motivated anti-gay crimes reported greater distress than gay victims of non-hate crimes. Victims of hate crimes reported significantly higher depression, trauma-induced stress, anxiety, psychosomatic complaints, and anger than victims of other crimes. These victims also reported a longer recovery time. Ruggiero and Taylor also found that victims of hate crimes report significantly higher levels of nervousness, anger, thought intrusions and difficulty in concentrating as compared to non-hate crime victims after one year of crime incidence. Hate crime victims also reported the feelings of being unsafe, ‘trying to be less visible’, and relocation to ‘safer’ location.
Drawing on Janoff-Bulman’s work, victims of hate crime suffer from characterological self-blame as opposed to behavioral self-blame. Here the victim blames certain aspects of their character as one’s race, gender, religion etc. as a reason for them being chosen as a victim. Characterological self-blame is a predictor of depression and poorer adjustment to crime. Characterological self-blame leads to a loss of controllability on future victimization as one can’t change or alter their character traits like race, gender, ethnicity, sexual orientation etc., making one feel helpless and susceptible to greater psychological trauma.
Hate crimes tend to be qualitatively different from non-bias motivated crimes on the physical trauma dimension as well. It has been found that hate crimes are positively associated with serious physical injury. Some types of hate crimes have a greater likelihood of being physically violent. Crimes against LGBTQ+ communities tend to be more violent. Crimes against disabled have high levels of sexual violence. Trigger events (like terrorist attacks, hate speeches etc.) lead to more violent anti-religious hate crime. It has been found that hate crimes are positively associated with serious physical injury.
Violent crimes do not just impact the individual victim but also their family, friends, community, and society in general. A hate-motivated assault against an individual not only harms the person or their family but also serves as a message to ‘others’ like them. Wagner opines that “Hate crime also has a much broader impact within communities than many other types of violent crimes or property crimes.” Because they are motivated by bias, hate crimes are often intended to and send a broader message of violent intolerance toward a broad class of persons. Like terrorist incidents, the “message” aspect of the offender’s motive can be profoundly threatening to people far removed from the actual scene of the crime, creating collective victimization and a shared trauma.”. The assault is not just carried out against the single victim but is symbolic of an attack against the entire community. This community, if it feels being targeted, starts to feel unsafe in their surroundings.
Hate crimes, on a community level, may be motivated by factors such as to curb inward migration of an ethnic group, or to control the neighborhood by existing criminal gangs, or to protect the community from ‘threatening’ out-groups. Such crimes also may initiate a series of retaliatory crimes, further harming the standing and perception of the community and also erodes social order. This leads to increase in crime rates, an atmosphere of unease and suspicion of ‘other’ and lowering of social cohesion. Incidence of such crimes also lowers the respect and faith in government agencies.
India’s response to International conventions
Hate crime, on a global level, is gaining traction and securing support to firmly secure its place within the human rights context, but it still lacks a comprehensive standard backing it.
Article 4 of the International Convention on the Elimination of Racial Discrimination (ICERD), passed in 1965, was the first mechanism relating to hate crime. It obliges that the signatory states adopt ‘immediate and positive measures’ aligned with the principles embodied in the Universal Declaration of the Human Rights to eradicate incitement and discrimination on racial grounds. It also obliges the parties to criminalize hate speech, hate crimes and activities that finance such organizations or actions. India signed ICERD on 2nd March 1967 and ratified it on 3rd December 1968. However, India has expressed reservations on two grounds. Firstly, on Article 22 with reference to submission of disputes to the International Court of Justice, India asserted that in order to do so explicit consent of all parties involved must be obtained. Secondly, on Article 1, equating caste with race or its inclusion under the category of ‘descent’ which would lead to inclusion of crimes against oppressed castes in the periodic reports to CERD.
India is also a signatory of International Covenant on Civil and Political Rights (ICCPR) which came into force in 1976 and was ratified by India on 10th April 1979. Article 20(2) also directs that “Any advocacy of national, racial or religious hatred that constitutes incitement to discrimination, hostility or violence shall be prohibited by law.” Article 26 of ICCPR also directs the member states to ensure equal protection under law and prohibit discrimination on “any ground such as race, color, sex, language, religion, political or other opinion, national or social origin, property, birth or other status”.
As a part of India’s obligation under these conventions, India has to report information to Committee on the Elimination of Racial Discrimination (CERD) regarding its efforts on implementation of ICERD as well as current hate crime related statistics. India also has similar obligation, as a party to the ICCPR, to report about its progress on the human rights front to the Human Rights Committee. India has failed to keep up with regular reporting to both these committees. India submitted its last report to CERD in the year 2010. The last review for India under ICCPR was conducted in 1997 and the fourth and fifth periodic report (due 2001 and 2006 respectively) are still awaited. Though the global conversation around hate crime has intensified, there is a lack of binding frameworks, and it becomes easier for governments to contravene these obligations, as seen in the case of India.
INDIAN JUDICIAL APPROACH
In the landmark case of Tehseen Poonawalla v. Union of India and others, a bench led by former CJI Deepak Mishra including A.M. Khanwilkar and Dr. D.Y. Chandrachud, JJ issued a resolution to address the current situation in the country. The judgment strongly criticized the incidents of mob lynching and has caused a major shift in the manner in which this crime was handled before the passing of this judgment. The court was so determined to prevent such acts that the court along with the preventive measures suggested a special team to provide intelligence reports on those subjects that may have committed such acts. The court also ordered that the Director-General of Police and the Secretary of State for Home Affairs hold a meeting on the issue of cattle monitoring at least once a quarter with nodal officers and intelligence officers of the state police. The court emphasized the principle of unity in diversity. The court drew out several cases that highlight the unity of the nation. The court was of the opinion that in a nation like India where unity is given greater importance, such acts of cowardice should not be tolerated. Mass killing in the name of cattle protection cannot be excused in any way. India is a large nation with a much larger population. Certain states such as Rajasthan, Uttar Pradesh, Maharashtra, Gujarat, Jharkhand and Karnataka have put in place animal protection measures. The actions of these states have somehow protected cow vigilantes. The Supreme Court of India did not comment on the legality of the Act. Although the court expressed the cow vigilantism as a crime and laid down guidelines and several preventive, punitive and remedial measures, the court did not consider the constitutionality of the rules enacted by few states like Karnataka, Gujarat etc., which protects these cow vigilantes. This has a negative impact on preventing such illegal act. The court has also emphasized that police are to register FIR under section 153 of IPC and/or relevant provisions of the law against individuals who spread the hateful message on social media which is likely to provoke mob violence and lynching cases. The court agreed with the proposal to deploy police in critical areas. The court also recommended to the parliament to create a special offence of mob lynching and provide appropriate punishment for perpetrators.
In the case of Amish Devgan v. Union of India & others. A news anchor was accused of hurting religious sentiments and inciting religious hatred. The court explained the philosophy of freedom of speech and expression and hate crime with the help of the `philosophy of other developed countries like USA and France. The court observed that “The State guarantees equality to all citizens regardless of their philosophical or religious conviction as all persons are born and remain free and equal in right. Everyone is free to express their own particular convictions and adhere to it. Laïcité confederates and reinforces the unity of the nation by bringing citizens together by adhering to values of the republic which includes the right to accept differences. In accordance with the Declaration for Laïcité – Observatoire de la laicite (Republique Francaise) above principle, the French recognize and accept the right to offend as an essential corollary to freedom of expression which should be defended or upheld by other means, than by causing an offence. France does have hate speech laws against racism and xenophobia, which includes anti-religious hate crimes, to protect groups and individuals from being defamed or insulted on the ground of nationality, race, religion, ethnicity, sex, sexual orientation, gender identity or because they have a handicap.”
During formulation of hate crime statutes major concern expressed is whether or not hate is the only condition under which these offenses occur. Is the presence of extreme prejudice or hate the only driving force behind such offenses? Jacob & Potter put forward that most of the crimes have an element of hate and conceptualizing a different category of crime on basis of hate motive is vague and hence leads to redundancy. Analysis of many hate crimes also reveal that these crimes are not always motivated by hatred only but like any other crime may be caused by a multitude of motivations. Also punishing hate or prejudice (an emotion, a belief), may be understood as against freedom of speech and expression and against an individual’s right to belief. This confusion may be addressed by looking at definition of prejudice given by Allport in his seminal work, On the Nature of Prejudice. He classified prejudice along a continuum of minor to major behavioral component:
- Antilocution is defined as negative verbal discourse directed against the target group like verbal denigration, off-colored jokes, verbal abuse etc.
- Avoidance is defined as a deliberate attempt to not interact with the target group like not maintaining any form of social contact.
- Discrimination defined as systemic exclusion from social institutions leading to socio-economic disparities like not giving equal opportunity with respect to education and employment.
- Physical Attack defined as violence directed against members of the target group.
- Extermination is defined as a systematic effort to wipe out the target group.
This continuum makes it easier to answer the concerns addressed above. While the first two forms of behavior may be protected under various civil liberties, the last three cannot be in any way linked to an individual’s freedom of expression and/or belief.
Major criticism of having separate hate crime legislation is that it will further divide the society and increase tension between groups. However, no statistical association between enactment of hate crime laws and increase in intergroup tensions has been reported.
This statistical observation can be understood using the Intergroup Contact Theory. The theory posits that increased contact between groups leads to reduction of prejudice, in presence of situational factors: equal status, common goals, no intergroup competition and support from influential social institutions. If hate crime laws are considered as authority sanction then it will lead to lessening of prejudices and consequently lower intergroup tensions.
Currently there is no specific legislation to address hate crime, although there are certain sections of IPC like section 153, 153A, 295,295A etc. which address the issues pertaining to hate crime. Chapter XV (Sections. 295 to 298) deals with offences and punishment of offences relating to religion are also relevant chapter in this respect. There is one exception i.e. the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 which criminalizes violence against Dalists, Adivasis/Indigenous groups. As per the latest NCRB Report 0f 2020, “a total of 50,291 cases were registered for committing crime against Scheduled Castes (SCs), showing an increase of 9.4% over 2019 (45,961 cases). Crime rate registered showed an increase from 22.8 in 2019 to 25.0 in 2020. Crime head-wise cases revealed that simple hurt with 32.9% (16,543 cases) formed the largest chunk of cases of crimes/atrocities against Scheduled Castes (SCs) during 2020. It was followed by cases under SC/ST (Prevention of Atrocities) Act with 8.5% (4,273 cases) and cases under Criminal Intimidation with 7.5% (3,788 cases)”. The report of NCRB of 2020 mentioned above reveals the rise of hate crime in India.
Suggestions for formulation of hate crime law in India.
Hate crime laws prevail mainly in the US and UK, however a major drawback of these statutes is lack of agreement in covering the categories to be protected under such laws. Crime like any other behavior is determined by individual characteristics as well as the situational and environmental factors. In the context of hate crime, legal and political context may encourage, discourage or be neutral towards this violence. For example, state mandated racial segregation provides an encouragement to hate violence targeted towards the segregated groups. Lack of policy towards LGBTQ+ rights, criminalization of alternative sexual orientation may provide a moral backing to hate crimes against these groups. Similarly, the presence of hate crime laws might not completely deter all categories of bias motivated offenders, but it does have a powerful symbolic meaning of communicating the state and society’s stance on such crimes. This may also deter the criminal who resorts to these activities not due to a strong bias but for seeking thrill. Also, it takes away the illusion of these offenders working for social welfare and makes it clear that the state is considerate of the civil liberties of all the citizens and committed to their protection.
The Authors of this manuscript are Afkar Ahmad, Associate Professor of Law, School of Law, GDGU Goenka University, Haryana and Priyanka Sharma Khanduja, Faculty Psychology, Department of Psychology, Doon University, Dehradun.
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