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ON BLOOD, POWER, AND PUBLIC INTEREST: THE CONCEALMENT OF HINDU SACRIFICIAL RITES UNDER INDIAN LAW

Published online by Cambridge University Press:  14 August 2019

Deonnie Moodie
Deonnie Moodie*
Affiliation:
Assistant Professor of Religious Studies, University of Oklahoma
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Abstract

Critiques of animal sacrifice in India have become increasingly strident over the past fifteen years. In the state of West Bengal, many of these critiques center on Kālīghāṭ, a landmark Hindu pilgrimage site in Kolkata where goats are sacrificed daily to the goddess Kālī. However, while similar critiques of this practice have resulted in many Indian states pushing to ban it—or enforce previous bans of it—no such legal action has been issued in West Bengal. Instead, in 2006, the Calcutta High Court ruled that this practice must be visually concealed at Kālīghāṭ. Drawing on modernist notions of cleanliness and public space, the bench argued that the blood and offal produced by this practice creates an inappropriate visual experience for visitors at a major pilgrimage and tourist site in this city. In the act of concealing sacrifice, the Calcutta High Court follows suit with courts across India in deeming the practice unmodern. Yet the Court's orders are defied daily by practitioners at Kālīghāṭ who seek physical and visual access to sacrificed animals and their blood. They believe Kālī desires that blood, and bestows her power and blessings through it. Fault lines in Hindu conceptions of power are dramatized here. The power of the courts is pitted against the power of the gods as Hindus debate the potency, necessity, and modernity of this practice.

Keywords

Hinduismanimal sacrificeIndiasecularismKaliCalcuttaKolkatajudicial activismpublic spacetourism
Type
Research Article
Information
Journal of Law and Religion , Volume 34 , Issue 2 , August 2019 , pp. 165 - 182
Copyright
Copyright © Center for the Study of Law and Religion at Emory University 2019

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References

1 Calcutta's name was changed to Kolkata in 2001 to reflect the indigenous rather than British pronunciation. Throughout the article, I use the new spelling when referring to the city after 2001. However, where institutions have retained the former spelling (the Calcutta High Court, for example), I have also.

2 Estimates vary widely. This figure is based on conversations I had with pāṇḍās (Brahmin pilgrim guides) and purohits (priests) at Kālīghāṭ, as well as my own observations over a year of fieldwork. Suchitra Samanta's estimates, based on conversations with the same groups of people, are higher: Samanta, Suchitra, “The ‘Self-Animal’ and Divine Digestion: Goat Sacrifice to the Goddess Kali in Bengal,” Journal of Asian Studies 53, no. 3 (1994): 779–803, at 782CrossRefGoogle Scholar. The number of goats sacrificed also depends on the day. Tuesdays and Saturdays are particularly auspicious to Kālī, so numbers are greater on those days.

3 Caṭṭopādhyāy, Sūrjyakumār, Kālīkṣetra Dīpikā [A commentary on the land of Kālī] (Bhavānīpur: Pārthiva Jantra, 1891), 80Google Scholar.

4 Prahlad Roy Goenka v. Union of India & Ors. (2006) Cal W.P. 24928 W (India).

5 I provide here a short description of the practice at Kālīghāṭ from my observations gathered periodically from 2002 until 2009, and then over a nine-month research period from 2011 until 2012.

6 An 1891 source indicates that there has not always been a wall surrounding the sacrificial enclosure. Due to a municipal order, which cited the durgandhamay (bad smell) and bhīṣaṇ dṛśya (horrible scene) of sacrificed goats and sheep, sacrifice was tirohit (made to disappear), presumably by a low wall prior to that year. See Caṭṭopādhyāy, Kālīkṣetra Dīpikā, 93. Ironically, as my experience at Kālīghāṭ prior to 2012 reveals, a low wall does not successfully conceal any of these things, except perhaps from children.

7 Samanta, “The ‘Self-Animal’ and Divine Digestion,” 789.

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11 Śatapatha Brāhmaṇa 3.8.1.15, cited in Tull, 226.

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25 McDermott, Revelry, Rivalry, and Longing for the Goddesses of Bengal, 208. The practice continues throughout rural Bengal today, though not in major urban areas, except at Kālīghāṭ.

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36 The Indo-Asian News Service reported on November 30, 2007, that the People for Animal Rights persuaded Dakṣiṇeśvar, a Kālī temple in northern Kolkata made famous by its former priest, Ramakrishna, to cease the practice through their protests in 2000. See Indo-Asian News Services, “India: Ex-Royals Stop Animal Sacrifice after Campaign,” Religioscope, November 30, 2007, http://religion.info/english/articles/article_351.shtml#.V7dgMJMrK4g. The same article reported that the former royal family of Nabadwip also ceased sacrifice for religious festivals. At another major Kālī temple in the city, Karunamoyee, sacrifice was stopped in 2003. A priest of that temple relayed to me that in that year, three separate sacrifices were botched, indicating the goddess's displeasure with the practice. On one occasion, the knife bent, and on another two occasions, it took more than one stroke of the knife to perform the sacrifice. (Unless otherwise attributed, all interviews were conducted in confidentiality, and the names of the interviewees are withheld by mutual consent.)

37 An Address to Sri-Kanchi-Kama-Kotipithadhisha-Srijagatguru-Sri 1008 Sankaracharrya Srimachchandrashekharendra-Sarasvati (Calcutta: Shevait Community of Kalighat, 1935) (This pamphlet was given to me by Dilip Haldar in 2009); Sastri, S. Sambamurthy, Paramacharya: Life of Sri Chandrasekharendra Saraswathi of Sri Kanchi Kamakoti Peetam, trans. Sundarajan, P. G. (Madras: Jana Kalyan, 1991), 106Google Scholar.

38 Shanti Bhattacharya, head priest of Kālīghāṭ, interview with the author, June 22, 2009, Kolkata.

39 See Mukherjea, B. K., The Hindu Law of Religious and Charitable Trusts: Tagore Law Lectures, 5th ed., ed.Sen, A. C. (1983 repr., Calcutta: Eastern Law House, 2010)Google Scholar; Derrett, J. Duncan M., Religion, Law and the State in India (Calcutta: Oxford University Press, 1999)Google Scholar.

40 “Activists Call for Ban on Animal Slaughter for Religious Sacrifice,” Agence France-Presse, November 14, 2001.

41 Some claim that this was the wish of Kālī herself. See, for example, Upendranāth Mukhopādhyāy, Kālīghāṭ Itivṛtta [The history of Kālīghāṭ] (Bhāvanīpur: Hitaiṣī Jantra, 1925), 59.

42 To see the Vaiṣṇava accommodations that have been made at Kālīghāṭ since that time, see Sanjukta Gupta, “The Domestication of a Goddess: Caraṇa-Tīrtha Kālīghāṭ, the Mahāpīṭha of Kālī,” in McDermott and Kripal, Encountering Kālī, 60–79.

43 On the annual festival of Kālī Pūjā, Kālī is worshipped as a form of the goddess Lakṣmī, the consort of Viṣṇu. At that time, goats are sacrificed not in direct line with Kālī’s inner sanctum, but off to the side. Devotees offer hundreds of goats on that night.

44 Interview with the author, October 15, 2011.

45 Interview with the author, September 26, 2011.

46 State of West Bengal v. Ashutosh Lahiri (1995) AIR 464, 1995 SCC (1) 189 (India); Abhijit Das & Ors. v. State of West Bengal and Ors. W.P. No. 1378 of 2010 with Enamul Haque & Anr. v. State of West Bengal & Ors., (2010) W.P. No. 21591(W) (India). For an analysis of similar rulings elsewhere, see Derrett, J. Duncan M., “India,” International and Comparative Law Quarterly 8, no. 1 (1959): 221–24CrossRefGoogle Scholar.

47 While most Hindus do not consume beef because many believe cow slaughter to be prohibited according to their religion, Muslims regularly do so. On beef bans, see Jaffrelot, Christophe, “India's Democracy at 70: Toward a Hindu State?” Journal of Democracy 28, no. 3 (2017): 52–63CrossRefGoogle Scholar; Sarkar, Radha and Sarkar, Amar, “Sacred Slaughter: An Analysis of Historical, Communal, and Constitutional Aspects of Beef Bans in India,” Politics, Religion and Ideology 17, no. 4 (2016): 329–51CrossRefGoogle Scholar.

48 Ravik Bhattacharya, “Kolkata to Organise Beef Festival to Protest against Ban,” Hindustan Times, March 27, 2015, http://www.hindustantimes.com/kolkata/kolkata-to-organise-beef-festival-to-protest-against-ban/story-wDJVMh4mxrETrYTSTUTmDK.html. Notable officials who supported the festival included the former Lok Sabha speaker Somnath Chatterjee, former mayor Bikash Ranjan Bhattacharya, Congress leader Abdul Mannam, and former Communist Party of India (Marxist) councilor of the Kolkata Municipal Corporation, Faiyaz Ahmed Khan. Nongovernmental organizations, including the Subhas Chakraborty Foundation and Paschim Banga Pratibondhi Sammelani, were slated to organize the event. It was canceled by the venue at the last minute, citing concerns that the event had become politicized. Organizers suspected a Trinamool conspiracy. Ravik Bhattacharya, “Kolkata: Meat Festival Called off as Politics Plays Spoiler,” Hindustan Times, March 31, 2015, http://www.hindustantimes.com/india/kolkata-meat-festival-called-off-as-politics-plays-spoiler/story-UpbHdY6x6hr4CF6naVsiFL.html. The beef festival would indeed endear many Bengalis to the left-wing Communist Party of India (Marxist)—a party that had been in power in the state for thirty years running until Trinamool ousted them in 2001 under West Bengal's current chief minister, Mamata Banerjee (who, notably, resides in the Kālīghāṭ neighborhood).

49 “Kolkata High Court Bans Open Cow Slaughter on Bakrid,” IBTL, November 6, 2011, http://www.ibtl.in/news/states/1551/kolkata-high-court-bans-open-cow-slaughter-on-bakrid/.

50 “Won't Let BJP Play Hindutva Card: Mamata Banerjee,” Indian Express, April 14, 2016, http://indianexpress.com/article/elections-2016/india/india-news-india/bjp-playing-hindutva-card-vitiating-environment-in-west-bengal-mamata-banerjee/.

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59 This is the same logic as that employed by the City Council in Hialeah, Florida, in the famous American case dealing with practitioners of Santería: Church of the Lukumi Babalu Aye, Inc. v. Hialeah, 508 U.S. 520 (1993). See Wise, Steven, “Animal Law and Animal Sacrifice: Analysis of the U.S. Supreme Court Ruling on Santería Animal Sacrifice in Hialeah,” in A Communion of Subjects: Animals in Religion, Science and Ethics, ed. Waldau, Paul and Patton, Kimberley (New York: Columbia University Press, 2006), 585–87Google Scholar. The Hialeah City Council banned the practice because they deemed the killing of any animal without the explicit intention of consuming it as unnecessarily cruel, even if the animal were consumed after being ritually killed. They were not seeking to do away with animal consumption but to decouple that practice from that of religious worship. Thus, as Jonathan Klawans argues, “The elimination of sacrifice is not an ethical development, but an aesthetic one,” and as such, animals are not necessarily better off. Klawans, “Sacrifice in Ancient Israel,” 65. The Hialeah City Council's ban was later overturned by the Supreme Court on the grounds that the order unfairly singled out the Santería community on the basis of their religion. In the United States, as in India, the Constitution does not guarantee the right of religious communities to practice animal sacrifice under all circumstances.

60 Prahlad Roy Goenka, interview with the author, November 23, 2011, Kolkata.

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65 See Moodie, Deonnie, “Kālīghāṭ and the Fashioning of Middle Class Modernities,” in “Where Class Meets Religion: Examining Middle-Class Religiosity in India,” ed. Waghorne, Joanne, special issue, International Journal of Hindu Studies 23, no. 1 (2019): 11–26CrossRefGoogle Scholar.

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67 Kālīghāṭ was officially declared a public temple through a series of lawsuits that ended in the Supreme Court of India in 1961. See Moodie, Deonnie, The Making of a Modern Temple and a Hindu City: Kālīghāṭ and Kolkata (New York: Oxford University Press, 2018), 67–98CrossRefGoogle Scholar. The court's use of the term public justifies its intervention in temple affairs at Kālīghāṭ, as at most other temples in India. On Indian law regarding public religious and charitable institutions, see Mukherjea, The Hindu Law. On the legal regulation of Indian publics, particularly as they relate to religion, see Scott, J. Barton and Ingram, Brannon D., “What is a Public? Notes from South Asia,” South Asia: Journal of South Asian Studies 38, no. 3 (2015): 357–70CrossRefGoogle Scholar. On legal interventions into religious matters, see Berti, Daniela and Voix, Raphaël, eds., Filing Religion: State, Hinduism, and Courts of Law (New Delhi: Oxford University Press, 2015)Google Scholar.

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71 Note that the court left the decision about the means of concealing sacrifice and skinning to the Temple Committee and the police (who are presumably then charged with enforcing this court order). The suggestion of the High Court to keep Gate No. 5 open may have been a suggestion to skin animals outside the walls of the temple.

72 “Court Ruling on Animal Sacrifice Bolsters Activists,” Hindustan Times, September 21, 2006, http://www.hindustantimes.com/india/court-ruling-on-animal-sacrifice-bolsters-activists/story-aOWUX1ajguzQVirmEJba0O.html.

73 “Court Ruling on Animal Sacrifice Bolsters Activists.”

74 Prahlad Roy Goenka v. Union of India & Ors. (2006) Cal W.P. 24928 W (India). In the same judgment, the Court ordered the Temple Committee to allow the building of a tourist facility that was proposed and funded by a nongovernmental organization in conjunction with the West Bengal Tourism Development Corporation. International Foundation for Sustainable Development, “Kalighat Redevelopment Project,” International Foundation for Sustainable Development, accessed August 15, 2013, http://ifsdindia.com/enterprise.html.

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76 See “Attractions,” Lonely Planet, accessed November 7, 2018, http://www.lonelyplanet.com/india/kolkata-calcutta/sights, and “Kolkata Tour,” Incredible India, accessed July 18, 2019, http://www.incredibleindia-tourism.org/pilgrimage-tours/kolkata.html

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87 Good, “Animal Sacrifice and the Law in Tamil Nadu,” (presentation, “Animal Sacrifice on Trial: Cases from South Asia” (workshop, Centre national de la recherche scientifique, Paris, June 22, 2015)).

88 Urban, Hugh, The Economics of Ecstasy: Tantra, Secrecy, and Power in Colonial Bengal (Oxford: Oxford University Press, 2001)CrossRefGoogle Scholar. I am grateful to Raphaël Voix for this suggestion.

89 Urban, The Economics of Ecstasy, 213–14.