INTRODUCTION
Mob violence strikes at the core of constitutional governance, making law enforcement difficult and challenging the courts’ ability to maintain legal order during times of unrest.[1] The violence in Bahraich represents a critical Constitutional rupture of great importance, where a local incident quickly transformed into a riot, threatening public order and democracy.[2] In this fraught context, the ruling of the Bahraich Sessions Court is important not only as a determination of guilt but also as a powerful judicial declaration of the imposition of constitutional discipline.[3]
The judgment refers to the doctrines of unlawful assembly and common object under the Indian Penal Code directly, while placing collective liability under the equality and due process guarantees of Articles 14 and 21 of the Constitution.[4] It has shown an adaptive evidentiary approach to modern mob violence through its careful treatment of digital and forensic evidence.[5] By requiring proportionality, accountability, and procedural fairness, the ruling strengthens the judiciary’s position as the last constitutional fortress against the acceptance of collective violence.[6]
BACKGROUND OF THE BAHRAICH VIOLENCE[8]
The Bahraich violence of October 2024 was the result of a quickly escalating communal clash over the murder of a 21-year-old man named Ramgopal Mishra, who was shot during a Durga idol immersion procession in Maharajganj’s Hardei police station area. The court held Sarfaraz responsible for the murder, which immediately turned a localised conflict into a complete breakdown of law and order throughout the district. Hardei, Maharajganj, and neighbouring areas of Bahraich city experienced unrest to the point of causing large-scale vandalism, burning of properties and the stirring up of already existing tensions between communities. The administration reacted to the situation by shutting down internet services and bringing in a large number of security forces, including the police from adjacent states, PAC, RRF, and STF, which highlighted the seriousness of the situation. At the same time, the Home Secretary and ADG (Law & Order) were among the senior officials deployed to the area for monitoring purposes. Chief Minister Yogi Adityanath also visited the family of the deceased, promising justice and announcing state support. The FIR included the names of thirteen people, and by 2025, initiation of NSA proceedings against all of them was already in place. The violent repercussions, along with the vigorous legal and administrative response, thrust the murder case into the spotlight of what was later referred to as the Bahraich Violence, thus influencing its narrative and judicial path.
THE TRIGGERS: UNREST, MISINFORMATION AND THE ROAD TO CHAOS
A chain reaction is what lies behind every act of violence. In Bahraich, this chain started with the misinformation—WhatsApp groups sharing theft, social media with exaggerated claims, and marketplaces where unverified allegations were discussed.[8] Misinformation was combined with the already existing tensions, some were political, some communal, and some were the result of decades of social mistrust.[9] One incident, through digital noise, became a spark.[10] The spark got its strength from the worried crowds, and soon the fire was spreading—both literal and metaphorical.[11]
What came next was predictable but could have been prevented: loss of control, breakdown of communication and the crowd turning into mobs.[12] The path to chaos was constructed by ignorance, anger and digital rumours, thus demonstrating once more that in the information era, falsehood is faster than truth in movement.
INSIDE THE COURTROOM: HOW THE CASE UNFOLDED?
The trial that followed the communal violence in Bahraich indeed took place in court, where facts and interpretations of the same conflicted. The prosecution introduced a very carefully and strategically devised chain of evidence to prove murder with prior planning and all participants in the crime together.[13] The testimonies of the eyewitnesses placed the accused individuals in Maharajganj during the violent episode that ended the life of Ramgopal Mishra.[14] All these testimonies got their support from forensic reports, which confirmed the death to be homicidal, matched the injuries with the weapon, and from call detail records, mobile location data, and CCTV footage, all of which pointed to coordination and unlawful assembly.[15]
The prosecution argued that the violence was not an unplanned event but rather a deliberate attack on the community, thus invoking the ‘rarest of rare’ doctrine to support their demand for the death penalty for the main perpetrator and also stressing the negative effect on public order and constitutional values in general.[16]
The witnesses’ credibility was challenged in court by the defence, which also pointed to contradictions and delays, and questioned the integrity of electronic evidence,[17] and argued that the whole incident took place in the midst of communal frenzy without any prior planning.
The verdict—the death penalty for one of the accused and life imprisonment for the others—was a manifestation of the judiciary’s reliance on evidentiary rigour, its balancing of deterrence with proportionality, and its reaffirmation of accountability in the case of communal crimes.[18]
LEGAL PRINCIPLES AND LANDMARK SIGNIFICANCE OF THE BAHRAICH VERDICT
The Bahraich judgment, a reaction to the 2024 communal violence in Maharajganj, Uttar Pradesh, has been a major development in India’s criminal justice system dealing with mass killings. The court has imposed the death penalty on the main perpetrator and life imprisonment on the rest, thereby indicating that the gravest punishment would be awarded to persons who, by their actions, endanger religious tolerance.
The ruling not only clarifies individual criminal responsibility in cases of mob violence but also rejects the concept of collective guilt and insists on proof of the actor’s specific roles and intent, which is in line with the Masalti v. State of U.P. (1965)[19] case. The court’s imposition of different sentences indicates the application of the principle of proportionality, whereby different degrees of culpability are distinguished, and at the same time, the “rarest of rare” doctrine under Bachan Singh v. State of Punjab[20] (1980) is reasserted.
Besides, the ruling points out the necessity of eye-witness and forensic evidence in riot trials, which is in line with the principles laid down in State of Gujarat v. Kishanbhai (2014).[21] Most significantly, it declares that communal intention is an aggravating factor, thus enhancing public trust in the system of justice and the law.
CONCLUSION[22]
The Bahraich verdict is not just a judicial order, but it is a strong reaffirmation of the law in an age of increasing mob violence. It ensures that the courts will not give in to emotion, political pressure, or online misinformation. The judiciary, by using technological evidence like CCTV, GPS, and communication, has displayed how chaos can be legally restored into accountability. The ruling highlights that the group crimes do not lessen the responsibility but rather make it more. The judgment, besides its legal implications, acknowledges that the origin of violence is always the breaking down of trust, community, and public safety. The Bahraich decision finally serves as a reminder that the process of justice, though slow, is firm— and when it happens, it speaks with undeniable force.
Author’s Name: Ritika Pal (St. Xavier’s University, Kolkata)
[1] Tehseen S Poonawalla v Union of India (2018) 9 SCC 501
[2] State of Karnataka v Appa Balu Ingale (1995) 2 SCC 273
[3] E P Royappa v State of Tamil Nadu (1974) 4 SCC 3
[4] Masalti v State of Uttar Pradesh AIR 1965 SC 202
[5] Anvar P V v P K Basheer (2014) 10 SCC 473
[6] Modern Dental College and Research Centre v State of Madhya Pradesh (2016) 7 SCC 353; Justice K S Puttaswamy (Retd) v Union of India (2017) 10 SCC 1; Naz Foundation v Government of NCT of Delhi (2009) 160 DLT 277
[7] Bahraich communal clash: Court hands death penalty to main accused, life term to nine in Bahraich violence case,” The Indian Express (Lucknow) 11 December 2025 https://indianexpress.com/article/cities/lucknow/court-hands-death-penalty-to-main-accused-life-term-to-nine-in-bahraich-violence-case-10415643/ accessed 9 January 2026
[8] Tehseen S Poonawalla v Union of India (2018) 9 SCC 501
[9] Pravasi Bhalai Sangathan v Union of India (2014) 11 SCC 477
[10] Law Commission of India, Preventing Mob Violence (Report No 267, March 2017) 3–6
[11] Ministry of Home Affairs, Government of India, Advisory on Preventing Circulation of Fake News and Rumours on Social Media (2018).
[12] Shashi Tharoor, ‘The Perils of Social Media in India’ (2019) The Hindu https://www.thehindu.com/opinion/lead/the-perils-of-social-media/article26497818 accessed 9 January 2026.
[13] Indian Penal Code 1860, ss 302, 120B, 149
[14] State of Uttar Pradesh v Krishna Master (2010) 12 SCC 324
[15] Anvar PV v PK Basheer (2014) 10 SCC 473
[16] Bachan Singh v State of Punjab (1980) 2 SCC 684
[17] Thulia Kali v State of Tamil Nadu (1972) 3 SCC 393
Arjun Panditrao Khotkar v Kailash Kushanrao Gorantyal (2020) 7 SCC 1
[18] Shakti Vahini v Union of India (2018) 7 SCC 192
[19] Masalti v State of Uttar Pradesh AIR 1965 SC 202
[20] Bachan Singh v State of Punjab AIR 1980 SC 898
[21] State of Gujarat v Kishanbhai (2014) 5 SCC 108 (SC).
[22] Bahraich murder in 2024 ‘tore fabric of humanity’: Court says must instil fear in such ‘beasts’, cites Manusmriti; sentences accused to death The Times of India (Lucknow, 13 December 2025).
