Remembering to Forget the 2002 Gujarat Pogrom, 23 Years After: Heba Ahmed reviews 'Ways of Remembering'
- Socio-Legal Review
- May 6
- 21 min read
Heba Ahmed
Introduction
Coming twenty-two years after the pogrom of Muslims in Gujarat, Oishik Sircar’s latest book is about how “New India” has remembered and moved on from the events of 2002. Sircar explains, in eye-opening detail, how collective memory of the violence perpetrated against Indian Muslims has been superimposed with a “state-making and state-preserving rationality” (3) that exculpates those who carried it out. This ‘ordering’ of memory even treats violence as a justified retaliation in a ‘natural’ sequence of cause-and-effect, instead of a pre-planned programme of killing. By using a novel ‘jurisprudential-aesthetic’ or J-A approach, which reads the emotive content of law and the judgment-driven fervour of three films featuring the pogrom, Sircar illuminates how memories and meanings of violence are embedded in public discourse. The eruption of anti-Muslim hate is resolved through secular law, which acts as a panacea to the crisis. The law ‘fixes’ the problem of violence by offering a putative justice, which pronounces the correct words of condemnation, but also exonerates the state from being held complicit. The killing of Muslims in the Gujarat pogrom is thus narrativised through the credentials of secular law: it cleanses the stains of killing and allows Indian democracy to congratulate itself about speedy trials; it provides a happy ending, as it were, to the story of inter-communal divisions (à la older Bollywood films that displayed ‘THE END’ in the concluding scene); and it triumphs as the unbiased adjudicator, standing above the irritant of religion-driven hate. As Sircar writes, this way of remembering the events of 2002 both critiques and normalises violence against Muslims. As for Muslims themselves, they are exhorted to submit to the majesty of the law and to place trust in the telos of justice.
Narrative and the Original Cause
A personal memory of living in the shadow of 2002 is from my final year as an M.A. student in Kolkata. I was working on my M.Phil. research proposal on the politics of memory and violence in the pogrom. During a conversation with a senior in the same department—a male Hindu student—in which I decried the killings of Muslims in Gujarat, I was asked, “But what about the Hindus in Godhra?” This was several years before the fallacy of ‘whataboutism’ formally entered the parlance of rhetorical devices. It revealed to me, however, that there is a mainstream chronology of narrating the violence: that Godhra happened first, the original culprits were the Muslims who set fire to the train coach, and the retaliatory anti-Muslim carnage was the aftermath. Or in other words, if the “precipitating event” of arson had not taken place, no pogrom would have occurred; thus, Muslims had only themselves to blame for inflaming religious hate and violence.
Sircar’s book significantly upends this way of chronicling Gujarat 2002. The author places it alongside other episodes of anti-Muslim and anti-minority violence that have been endemic to postcolonial state-making in India. Simultaneously, he points out how the Gujarat pogrom was “distinct in certain specific ways in comparison to previous events of anti-Muslim mass violence”, inasmuch that it involved “sophisticated planning and execution”, “macabre forms of brutality and the unprecedented extent of state involvement, police inaction and judicial complicity” (Sircar, 6). The author further points out that “almost all references to the Gujarat pogrom until today continue to replay this cause-and-effect logic of ‘who cast the first stone’” (Sircar, 10).
In contradistinction with standard narratives about the pogrom that recount the violence from 27th February 2002, the day the S-6 coach of the Sabarmati Express caught fire and 58 kar sevaks were burnt to death, Sircar’s retelling begins from the 28th, the day after, when the pogrom began. In other words, the author foregrounds the pogrom-as-event instead of conventional accounts that treat it as pogrom-as-aftermath. Hence, he gives a corrective reminder to the individual reader—and to the general public who ‘remembers’ the pogrom—that there is an alternate way of reconstructing the events of 2002, one which does not acquiesce to the infamous kriya-pratikriya or action-reaction dictum. The latter was proclaimed by right-wing Hindu leaders, including Narendra Modi, the then chief minister of Gujarat, as a justificatory logic for the violence. But this logic “masks the deep and dispersed structures of Hindutva which enabled the planning of the pogrom well before the train caught fire” (Sircar, 10). It also constitutes a “moral inversion” (Sircar, 10), in which Hindus as the majority community in India, perceive themselves as the victims of Indian Muslims. Godhra is the highlight in the discourse of Hindu victimhood that serves as the leitmotif of Hindutva’s relentless attacks on Muslims in contemporary India.
On Faith in the Law
What about the culprits that were apprehended for taking part in the pogrom? Individuals like Babu Bajrangi and Maya Kodnani, who acquired infamy during the pogrom, were treated with kid gloves by the law. Kodnani, a former BJP MLA, who was made an accused in 2008 by the Supreme Court-appointed Special Investigation Team (SIT), was acquitted in 2018 for her involvement in the Naroda Patiya massacre case and then in 2023 for the Naroda Gam case. After Kodnani’s acquittal, BJP leaders in Gujarat said that if she wanted to make a comeback in active politics, the party would welcome her. Babu Bajrangi, another offender convicted in both the cases, was granted frequent bail while serving a sentence for life imprisonment, before being acquitted as well in 2019.
In August 2022, the Supreme Court dismissed several pleas that sought its intervention in cases pertaining to the 2002 pogrom, on the grounds that they had become “infructuous with the passage of time”. According to reports, the cases included “those filed by the NHRC, special writ leave petitions by families of riot victims and the Citizens for Justice and Peace, an NGO, seeking transfer of investigation from the Gujarat police to the Central Bureau of Investigation (CBI).” A terse re-wording of the Court's jargon is: move on, twenty years have gone by. Another contemporaneous judgment offered a shocking denouement to the protracted battles for legal justice for the pogrom’s victims. In June 2022, the Supreme Court dismissed a plea filed by Zakia Jafri, the wife of former MP Ehsan Jafri, who had been brutally murdered in the Gulbarg Society massacre, saying that the appeal was “devoid of merits and deserves to be dismissed.” Zakia Jafri had filed a petition against the SIT’s closure report that had exonerated high-ranking state officials including Modi. But in rejecting her allegations, the apex court accused the petitioners of “fabricating” a case. This set the stage for the arrest of human rights activist Teesta Setalvad and retired Additional DGP of Gujarat R.B. Sreekumar, and further charges against former police officer Sanjiv Bhatt, all three of whom had been a bulwark of support and legal assistance for survivors of the pogrom. As one report states, “the arrest of the three crusaders sends a chilling message: those seeking accountability will not be tolerated.”
Two other cases require mention in this brief recap. On 15 August 2022, the Gujarat government ordered the remission of eleven men who had been convicted for the gangrape of Bilkis Bano and the murder of her family members. After Bilkis appealed against this order, the Supreme Court quashed it and ordered the men to surrender to the jail authorities within a fortnight. Secondly, on 21 March 2025, the Supreme Court ordered the acquittal of accused persons in a lesser known case related to the pogrom. In Dhirubhai Bhailalbhai Chauhan vs The State of Gujarat, the court acquitted six men who had been charged for offences punishable under Sections 143, 147, 153(A), 295, 436 and 332 of the IPC, on the grounds that mere presence in an unlawful assembly is not incontrovertible proof of offence. The case was from an incident of riot at Vadod village, where a mob had surrounded a graveyard and a mosque on 28 February, 2002. The court reasoned, “In that melee, even an innocent person may be mistaken for a miscreant. Thus, appellants’ arrest from the spot is not a guarantee of their culpability. In our view, therefore, mere presence of the appellants at the spot, or their arrest therefrom, was not sufficient to prove that they were a part of the unlawful assembly comprising of more than a thousand people.”
This trope of the mob or the “unlawful assembly” as an alibi for individual miscreants has featured repeatedly in court judgments that acquit those accused for participating in the 2002 pogrom. Sircar refers to it as “the trope of the crowd” (60), invoked by the Gujarat High Court, “to cast a shadow of concern, if not doubt, about whether the witnesses could have at all identified the 21 accused from a huge mob” (60) that carried out the Best Bakery massacre. The court’s scepticism and its shadow of doubt is rebutted by the clear-sighted testimony of survivors. As Zara Chowdhary writes in her memoir,
When Farida Abdulkadar Khalifa, one of the witnesses to and survivors of the Naroda Patiya massacre in 2002, is questioned in court about her ability to identify members of the mob in fading daylight, she says, ‘Ujaale mein khada insaan dekh nahin sakta; jo andherey mein khada hai, usko dikh jaata hai sab.’A person standing in broad daylight is often blinded. It’s when you’re standing in the dark that you really begin to see (293).
These cases all show the judiciary tilting towards the attenuation of justice, using the chaos of the pogrom and the passage of time as ways to justify its actions of acquittals, remission of gang-rapists, dismissal of survivors’ petitions and the brusque ending of a closure report. Can the judiciary be regarded as the repository of faith by those who await justice, and what do these terms mean in the context of Gujarat? Sircar, citing Moyukh Chatterjee, refers to the “impunity effect” which explains “how a majoritarian regime conducts farcical legal proceedings that allow it to acknowledge, yet benefit from, state-backed violence against minorities” (8). The aura and majesty of the courts in India lends verisimilitude to the travesty of legal justice. As the author writes, “Despite the failures in investigation and prosecution related to criminal trials arising out of the pogrom, the judiciary continues to be considered an able and willing neutral arbiter of justice that is not complicit with the deep structures of Hindutva’s anti-Muslim prejudice” (Sircar, 7). The courts of India profess to embody justice and fairness and therein demand that the citizenry repose trust in them, because trust is the basis for judicial legitimacy.
An empirical essay by Sudhir Krishnaswamy and Siddharth Swaminathan argues that "Indians have remarkably high levels of trust and confidence in the Indian judiciary across socio-demographic factors and...standard explanations based on caste and religious identity do not find purchase when explaining trust in the judiciary.” Be that as it may, accounts of Gujarat 2002 and judicial proceedings in the aftermath make clear that Muslim victims’ desperate faith is oft-betrayed by the law of the land and its ultimate failure to deliver the justice they seek. This faith is that the law will bring to book the perpetrators of the unspeakable acts of brutality witnessed during the Gujarat pogrom. Here, faith stands for an expectation of justice. But the faith that is imperiously claimed by the courts calls attention not to justice per se, but to adherence to legality and submission to the authority and supremacy of law. Here, faith in law stands for obedience and it may not be in tandem with the former ideation of justice. This nuanced distinction is explained below with reference to judgements in the Best Bakery case.
In chapter 3 of his book, Sircar reads four judgements related to the Best Bakery massacre case and presents a valuable commentary on the aesthetic tropes of law that frame collective memory of violence. The first judgment is that of the Vadodara Sessions Court which acquitted all the accused for want of evidence. As Sircar reports, “the court stated that while the Best Bakery incident had been ‘undoubtedly proved’, the prosecution, however, ‘[had] not led any least evidence or acceptable legal evidence to prove that the accused or any of them before the Court had committed any such offenses’” (49). Furthermore, the court selected a set of eyewitnesses, whose testimonies to the police had served as the basis for the prosecution’s case, and who denied seeing any of the 21 accused carry out the Best Bakery massacre. As a result, it could not be established who the “real offender” was; neither did the court admit that it had any duty to ascertain it, since “‘it is not within the jurisdiction of the court’ to find that out because ‘[t]he court of law or judiciary in the true meaning and sense, is not the court of justice but the court of evidence’” (Sircar, 50). The author notes that the trope of “evidence” is inserted into the trope of “justice” in a manner that it supplants the latter as the content of truth. In other words, the “teleological connection between justice and truth that the judgment had referred to is now qualified in a way where justice is replaced by evidence, which equals truth” (Sircar, 50).
The second judgment is that of the Gujarat High Court which upheld the former verdict of acquittal. The High Court dismissed any possibility of miscarriage of justice in the sessions court. It insisted that the “star witness”, Zahira Sheikh, who had turned hostile at the trial and failed to identify any of the accused, and had later said in a press statement that she had been threatened into silence, should have spoken the truth in court, because the courtroom is the sanctuary of truth. In essence, the court proclaimed that it was above any conspiracy, machination or threat of intimidation, and it alone was the guardian of the truth of testimony, rather than the purportedly anti-national agents such as human rights activists and the English language media that had assisted in Zahira’s press statement. Therefore, Zahira should have had faith in the supremacy of the judiciary, instead of expressing that her own faith in justice being done had been shattered by intimidation.
The third judgment discussed in the book is that of the Supreme Court, which ordered a re-trial of the Best Bakery case in order “to restore public trust in the judiciary, despite the performance of the courts in Gujarat” (Sircar, 68). Sircar writes, “The objective of taking on this role, as per the Supreme Court, was to uphold the majesty of the law—which is being equated with the achievement of justice” (67) While the Supreme Court-ordered retrial in the Bombay High Court convicted 9 of the 17 accused and gave them a life sentence, the apex court brought to bear the full extent of the majesty of law in its subsequent judgment in which it sentenced Zahira Sheikh for perjury and contempt of court. Sircar writes, “In substantiating its decision to convict Zahira, the court offered an explanation for why it was necessary to do so to keep the integrity of the judiciary—or what it had previously called the majesty of the law—intact. The court said that if Zahira was not convicted for contempt, people’s faith in the efficacy of the judiciary would be ‘destroyed’” (75).
In substance, the court penalised Zahira for obstructing the procedural method of establishing the evidentiary record or the “truth” of the case. That sentencing Zahira, a survivor of violence, constituted a bitter irony of justice, was not considered by the rational-legal authority of the court. In fact, justice itself was not regarded “as the end of evidence”. Evidence served the ends of truth, not “justness” per se. This constituted the “legacy of legalism, which worked as a rationality that was at the foundation of the Indian Evidence Act, 1855.” Sircar’s remarks on the legality of the courts are incisive and illuminating:
the Gujarat High Court extend[ed] the work of this rationality of legalism, where instead of asking why Zahira might have recanted her statement at trial, the judgment was more concerned about why she had declared in public that she had been threatened into lying in court…[it] considered what Zahira said outside of court—that she was threatened—to be a lie, and what she had said during trial—that she could not identify the accused—to be the truth. Such a line of thinking by the Gujarat High Court judges, thus, strengthened the rationality of legalism that considers ‘judicial truth’ to carry more weight than other contested versions (80).
The apex court, despite its order for a retrial and transfer of the case to Bombay, did not inquire into or offer any corrective to the very real threat of witness intimidation that Zahira continued to face in Gujarat. Its objective was instead to ensure that the “majesty of law is rehabilitated despite the violence that the law facilitated.” This was done by “convicting a perjurer who had undermined the majesty of the law.” As Sircar writes, “Zahira as a Muslim victim of the pogrom was, thus, written out of judicial memory.”
This illustrates the tension between the two kinds of faith in law: one is the idea of a hopeful faith, a solace-giving value to the victim of violence who continues to knock at the gates of law until the path of the fight for justice has been trodden till the very end. This is the faith that was held by Bilkis Bano in her battle against gangrape and murder of her family members, a faith that was held for dear life, rudely shaken when the criminals were remitted by the Gujarat state. The second kind of faith is like the sovereign’s command, which is exacted by the court from women like Zahira Sheikh, like a currency that has to be paid to access the law, even when the first kind of faith is not realised. This ideation of faith is concerned with the “majesty” of law, as Sircar writes, which is superimposed by the courts over and above the priority to secure justice for the victim. Once the unsullied majesty of law has been proclaimed, and the perjurer punished, the triumph of secular law rescues the nation from the irritants of religious violence. That is the happy ending of the aesthetic imagination of justice in law: the chance to remember violence only to move on.
Outside the realm of judicial memory and the erasures imposed by it, however, there is no neat resolution for the families who waited for justice for decades before being silenced by the court. Zakia Jafri, who died on 3rd February, 2025, was a living testament to the faith that pushes survivors to persist in their legal struggle. Nevertheless, her successive petitions against the larger conspiracy and complicity at the highest levels of government which enabled the pogrom were rejected as a “fabrication”. She faced a summary denial of justice, a rejection of her truth-claims that she placed before the court, as well as a violation of her identity as a ‘knower’ and testifier. Miranda Fricker refers to this as “testimonial injustice”, when “prejudice causes a hearer to give a deflated level of credibility to a speaker’s word” (9).
Memory, Erasure and the Rhetoric of Development
In light of the erasures of memory imposed by judicial majesty, autobiographical interludes such as Zara Chowdhary's book hold immense significance as artefacts of memory, rebelling against the narratives of the law. Chowdhary embeds lived experience within reportage of the pogrom to provide a poignant and edifying account of the victim-survivors. While judicial statements create a public culture of rationalising and justifying violence against national minorities, and soundbites of political leaders even lend support to it, community histories create a space for mourning violence. One weeps when reading about Ehsan Jafri, “the man who saved sparrows” (Chowdhary, 33), stepping out of his home in Gulbarg Society, to face the rioters who cut him and burnt him to death, and plead with them, “Please take me, but spare those inside.” (Chowdhary, 39) Adhering to the pogrom’s dictum of action-reaction, however, the court erased this act of self-sacrifice in its insistence that the mob was provoked by Ehsan Jafri firing gunshots at it.
Another moving portrayal by Chowdhary is of Bilkis Bano and her infant daughter, Saleha, who was killed by the mob:
I will think often about Bano’s body, carrying not only the scars of the violence done to her but also that deeper hollow within where once her Saleha lived. I will think of her hands, which carry the imprint of the way Saleha’s head curved, how soft her hair felt…of her fingers, which remember the last wisp of her daughter’s dress being ripped from her arms…of her nose, which holds Saleha’s baby smell, and her ears, which will never stop hearing that last yelp for life (Chowdhary 47-48).
Contrary to the authoritative pronouncements of the court, story-tellers like Zara Chowdhary imagine victims in vulnerable flesh and mournable blood. Both tender and visceral, these stories help to create empathy for the victims and the survivors of the pogrom.
But the emotive appeal of New India comes from asmita—collective pride and nationalism— not empathy for others not in the collective. As I write elsewhere, the asmita of Gujarat is the cultural pride of belonging to it, invoked by Narendra Modi after the pogrom, and orchestrated in public rallies such as the gaurav yatra held in October 2002 that helped refurbish Modi’s image against his critics and deflected any condemnation of the killings of Muslims. Upendra Baxi refers to Modi’s “tactical manoeuvre” of appealing to asmita as a “discourse of transcendence in the worst ever days of shame and sorrow for the entire state and nation” (Baxi 3521), “a summon[ing] [of] five crores of Gujaratis to combat…collective libel” (3522) and “a political rhetoric…to betray the Gujarat violated at every turn” (3522). Baxi writes about the “hard, male message” which Modi posed to the nation, “should scores of always alleged violated women, thousands of killed Indian citizens, the countless victims of frenzied looting, mayhem and mischief be allowed to deter the ‘wholesome’ state pursuit to reap the whirlwind of globalisation?” (3523)
Modi’s fashioning of brand asmita was highly effective in showcasing Gujarat as a hub of vikas or development. It erased the stain of violence from Vibrant Gujarat and inaugurated the ‘Gujarat model of development’ which denotes, as explicated by Oishik Sircar, “violent Hindu nationalism underwritten by serious corporate money, resulting in a renewed relationship between Modi and Indian big business that propelled his prime ministerial ambitions and the current power and influence that the BJP wields drawing on the support of major industrialists and crony capitalism” (Sircar, 9). As Christophe Jaffrelot writes, while Gujarat has experienced rapid infrastructural growth, capital-intensive industrial output especially in the energy and petrochemical sectors, and the setting up of Special Economic Zones to attract big companies, its success story has benefited only a select class, while mass poverty still prevails.
The rhetoric about vikas and an investment-friendly Gujarat conceals many uncomfortable truths, such as displacement and trauma among the urban poor of Ahmedabad, who lost their homes and means of livelihood in ‘resettlement’ drives during the Sabarmati Riverfront Development Project. The project envisioned “a two-level, continuous promenade on both sides of the river…to serve only pedestrians and cyclists and to provide access to the water…to host a variety of public features: cultural and educational institutions, leisure activities, large public parks and plazas and a few areas for commercial and retail development.” As Anuj Behal writes, slum dwellers who lived near the river were relocated to “pucca housing with secure tenure.” These “pucca flats”, allocated under Gujarat’s Urban Housing Scheme soon “began falling apart, with peeling plaster, sinking floors, tilted structures, leaking roofs, and broken toilets—painting a grim picture of neglect.” The paradox of development is evident: an aspirational middle-class is provided “access” to the river for pursuits of leisure and luxury, while those who lived in slums on the land by the river were removed and condemned to a life of despair. According to Behal’s report, the victims of displacement have no means of employment and resort to “selling their blood to meet their daily needs.”
The narrative of erasure here writes itself, as it were: of slums and tenements on the riverbank, of lives displaced, of the notion of a liveable life in Vibrant Gujarat. However, not only does the idea of Gujarati asmita, pride in the collective based on the prosperity of a few, persist in modern political rhetoric, but it seeps, as Sircar shows, into other registers of the time. These narratives of pride and erasure are co-opted into the Bollywood film industry and its imagination of the law and the collective.
Cinematic Justice, Truth and Hindu Rage
In Chapter 4 of his book, Sircar talks about a mode of “dharmic” reflectivity permeating three Bollywood films which were made with reference to the Gujarat 2002 pogrom. As the author states, the dharmic as the legal imaginary of Hindi cinema “affectively marks the Hindu-ness of the nation-state and its secular Constitution” (41) and is “directed at the spectatorial publics of a community of cinematic citizens for whom the secular nationalist language of Hindutva ideology is held up as a rationalising force to simultaneously condemn and normalise religious violence against Muslims (41).” Using the J-A approach, Sircar analyses how the films mobilise spectatorial publics, by endowing on them “the authority to pass judgment on both the cinema and the pogrom (94).”
The first film that Sircar analyses through the J-A lens is Dev (2004). Its plotline is similar to the mainstream chronology of violence discussed above, namely Godhra versus post-Godhra. The film revolves around Dev Pratap Singh, the eponymous lead, a secular, conscientious police officer who upholds the rule of law, and the tensions between him and his Islamophobic colleague, Tejinder Khosla, and a working-class Muslim student Farhaan, who is convinced by a corrupt Muslim politician to engineer violence as revenge for the killing of his Gandhian father. Farhaan attempts to assassinate Dev and also plants a bomb outside a temple which explodes and kills many Hindus. Retaliatory killings against Muslims ensue, at the behest of right-wing politicians. Dev endeavours to abide by the law, and holds a truth-telling meeting to collect testimonies of everyone hit by communal violence, but is himself killed by Tejinder. This impels Farhaan to convert to Dev’s worldview of keeping faith in the law and fighting for justice for those affected by violence. As Sircar writes, “The symbolic message, with which the film ends, is that Farhaan, having given up on the path of violence to seek justice, will now follow the path of the secular law to seek justice for the violence against his community and as a tribute to Dev’s courage and sacrifice” (109). The film establishes the triad of secularism (religious harmony), legalism (legal justice) and developmentalism (economy) as a moral corrective to communal disharmony and violence.
Parzania (2005), the second film which Sircar discusses, posits a “juridico-moral universe” permeated by Gandhian values (124). It depicts Shernaz, the female protagonist belonging to the minority Parsi community, and Asif, a Muslim, deposing before the human rights commission against the pogrom, in which Shernaz lost her young son and Asif his father. The third movie that Sircar features is Kai Po Che (2013), which has a singular, “cathartic” message, that the “developmentalist vision of private enterprise can triumph all odds…and make the nation-state unshakeable” (Sircar, 154). None of the three main characters in Kai Po Che are Muslim, but a side character called Ali Hashmi is shown as a part of the nation-state that celebrates success stories of running a business and exults in cricket nationalism. The parallels with Vibrant Gujarat and Gujarati asmita are unmistakeable. Sircar writes,
The landscape of cinematic justice that is painted rationalises the pogrom as aberrant—something that does not fit the way the Indian nation-state conducts its governance—and offers visions of reconciliation and resolution that are deeply invested in the very structures that deepen the disenfranchisement of Muslims (156).
Films like this reinforce narratives spun by the national public in politics, law, and cinema to reassure itself as to the aberrant nature of the pogrom: the myth of the original cause of violence, the spectre of Muslim terror attacking Hindu pilgrims onboard a train, the majestic and just embrace of the law which establishes communal harmony in a mode of rational legalism, the stain on Gujarati asmita in the form of accusations by human rights activists and the need to counter them, and finally the surge of development that impels the proud Gujarati to look forward, not backward, at the ghost of violence. These narratives constitute a “moral inversion”, as Sircar mentions (10), and an alteration of the “truth” of the pogrom. By inscribing these narratives in popular consciousness, the truth-claims of individuals like Zahira Sheikh, Zakia Jafri, and Ehsan Jafri are denuded of credibility. This erasure serves well the purpose of the pogrom-makers: to subject Muslims to violent hate and deny any accountability for the ensuing deaths. These narratives are contained, in part or wholly, singly or together, in judicial statements and cinematic imaginaries, two “a posteriori sites of collective memory where the contestations about the Gujarat pogrom have been most pronounced” (Sircar, 1).
However, these contestations, especially in the realm of cinema, have not reached a satisfactory conclusion. The “truth” of Godhra as the precipitating event of the Gujarat 2002 pogrom has acquired a keener edge. Unlike the three films discussed above, which gave screen-time to anti-Muslim violence, two recent films, Accident or Conspiracy: Godhra (2024) and The Sabarmati Report (2024) are more preoccupied with invoking memories of the train-burning. The storylines of both films delve into “investigating” whether the incident at Godhra involved sinister cover-ups to hide the “truth”. The cinematic audience for both the films is mobilised to remember the “original” crime against Hindus with rage and indignation, and to demand that the “truth” be unveiled. Evidently, these films are designed to evoke Hindu rage and delineate Hindu victimhood, the fodder of Hindu nationalism.
The Sabarmati Report earned praise from PM Narendra Modi who said, “truth is coming out, and that too in a way common people can see it.” Both films are symptomatic of contemporary Bollywood, which is churning out movies that fixate on the image of the Muslim, not as a victim of anti-minority violence, but as the full-bodied jihadi and invader. Films like Padmaavat (2018), Tanhaji: The Unsung Warrior (2020), The Kashmir Files (2022), The Kerala Story (2023), Animal (2023) and Chhaava (2025) build on every negative stereotype about Muslims: meat-eating barbarians, lustful invaders, abductors of Hindu women. The discourse of Hindu victimhood has been elevated to newer heights where it overshadows persons like Dev, who believed in upholding the rule of law and securing justice for all citizens, Hindu or Muslim. The rank and file of the police in India today support mob vigilantism, justify torture and believe that killing dangerous criminals in encounters is more preferable than giving them a legal trial. These findings are from a report on the status of policing in India, released by Lokniti-CSDS and Common Cause.
The latest entry in this repertoire of films that recalls the Gujarat pogrom and “unsettles” collective memory, as it were, is L2: Empuraan (2025), a Malayalam film that has achieved significant box office success and irked the Hindu right-wing. The film’s opening scene, featuring the protagonist Zayed and his family fleeing their home to escape communal violence, draws a clear parallel to the Naroda Patiya massacre of the 2002 pogrom, which Zara Chowdhury’s interviewee Farida Abdulkadar Khalifa was a survivor of and witness to. The main villain of the story is called Baba Bajrangi, an obvious allusion to the real-life figure of Babu Bajrangi. Despite certification from the Censor Board, Empuraan was subjected to 24 “voluntary” cuts and its makers were raided by the Enforcement Directorate (ED). As one commentator notes, “the film has managed to do something that most Indian films, especially the Bollywood produce, have been shying away from for years now…the sequence that shows the brutal violence that Muslims were subjected to by right-wing Hindutva forces in 2002 holds significance beyond the film’s text…at a time when facts about that period are being erased, criminals are being whitewashed, and history is being rewritten to reverse the roles of the victim and the perpetrator.
Conclusion
Oishik Sircar’s book on ways of remembering the Gujarat pogrom studies how law and cinema present sites of collective memory where violence against Muslims is both critiqued and rationalised by positing a state-making and state-preserving rationality, demanding faith in the law as institution rather than faith in its ability to provide justice. Through a study of four judgments related to the Best Bakery massacre case and three films featuring the Gujarat pogrom, Sircar argues that the triad of secularism, legalism and developmentalism offers a route to “move on” from the paroxysms of violence. Sircar’s book is a valuable addition to a growing literature on collective memory and violence in India and promises new vistas of research in the fields of law and cinema studies, which is particularly fragile in light of new cinematic attempts to reshape and twist these memories towards Hindutva and Hindu victimhood.
Heba Ahmed is an Assistant Professor at the Department of Political Science in Swami Niswambalananda Girls' College, affiliated to the University of Calcutta. She is also writing her Ph.D. thesis at the Centre for Political Studies (CPS) at JNU. She wrote her M.Phil. dissertation at CPS on 'Remembering Gujarat 2002: Contending Memories and the Politics of Violence', parts of which have been published in The Baroda Pamphlet, in an edited volume Partition and the Practice of Memory, in India Seminar and Indian Cultural Forum. She also writes regularly on issues of Islamophobia and anti-Muslim violence in India, the latest being ‘Corona Jihad: Examining Anti-Muslim Narratives in India during the Covid-19 Pandemic’ in Anglistica AION: An Interdisciplinary Journal. She was a Research Fellow (May-June 2017) at the University of Würzburg, Germany, under the UGC-DAAD fellowship of the Indo-German Partnership in Higher Education.
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