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Secularism, the State and Muslim Personal Law

Nandagopal R Menon ( is a research fellow at the Centre for Modern Indian Studies, University of Göttingen, Germany.

Governing Islam: Law, Empire, and Secularism in Modern South Asia by Julia Stephens, Cambridge: Cambridge University Press (South Asian Edition), 2019; pp xiv + 220, price not indicated.

Divorcing Traditions: Islamic Marriage Law and the Making of Indian Secularism by Katherine Lemons, Ithaca: Cornell University Press, 2019; pp x + 232, price not indicated.

Studies on secularism have burgeoned in the recent past. Moving away from understanding it as the principle of separation between state and religion, influential scholarship has proffered a twofold analytical differentiation between political secularism and the secular. Political secularism denotes the modern nation state’s sovereign power to reconfigure religion in particular forms, with religion itself being modelled on Protestant Christianity privileging the concept of belief (Asad 1993, 2003). The secular is a “particular configuration of the human sensorium” (Hirschkind 2011: 633) that produces a secular society and is presupposed by the doctrine of political secularism.

History as an inquiry into the “positivity of events” (Mahmood 2016: 206), for example, has become indispensable for verifying and interpreting religious truths. In fact, it is important to underscore that the contemporary surge in thinking on secularism has its roots in a particular historical and political conjuncture in postcolonial India in the 1990s, often termed the “crisis of secularism” (Needham and Rajan 2007). The threat posed by an aggressive, xenophobic and Islamophobic Hindu nationalism required urgent and detailed reassessment of secularism.

Debates about secularism’s goals, subjects and agents, colonial roots, distinctiveness from or isomorphism between comparable categories in other national contexts, suitability or necessity—all these have and continue to shape the contours of debates in popular and academic discourses in contemporary India (Bhargava 1998). However, despite these origins, scholarship on secularism often works with an implicit binary that pits general, abstract theorising on the topic (secularism) against specific examples from countries, including India (secularisms). Putting the condition of postcoloniality back at the centre of the thinking about secularism necessitates acknow­ledging the continued disparity in power between the West and the non-West, that secularism is intimately entangled with these inequa­lities and its effects. All of this undermines assumptions that the study of secularism in a non-Western place like India has nothing to contribute to theoretical thinking on secularism as a historical phenomenon (Agrama 2013a).

The two books under review are important interventions because they bring together the two broad themes outlined above. They think about personal law—Muslim personal law to be precise—in India by drawing on and contributing to accounts of secularism that stress its disciplinary, boundary-defining/undermining powers. Based on different disciplinary approaches, history and anthropology, there are nevertheless points where they converge. Both stress the centrality of the colonial and postcolonial Indian state to secularism—important continuities and discontinuities bet­ween the two forms of governance are evident when the two volumes are read together—but hasten to add that non-state actors are equally involved in this project.

As Katherine Lemons observes, the focus in the anthropological research on secularism has been on the secularisms of Egypt and France, which are primarily “project[s] designed and carried out by a rigorously centralised state” (p 24). It is in highlighting, to cite Julia Stephens, the “dynamic tension” between state and non-state legalities in India and how they produce “religion as a distinct field” (pp 13–14) that the two volumes provide insightful commentaries on secularism.

Colonial Origins and Development

Stephens’ is an archive-driven approach to investigate the origins and development of Muslim personal law in colonial India. She elaborates on how the British colonial state, in its two avatars as rule by the East India Company and subsequent direct rule by the Crown, through protracted and interrelated legal reforms repeatedly marked and made illegible the divide between religion, family and the economy. In Chapter 1, Stephens brings out the constellation of ideas that paved the way for the evolution of personal law in colonial India. She notes how territoriality, historicism and evangelical Christianity enabled this process.

These ideas, which assume an inequality between the colonisers and the colonised on multiple registers, enabled the British to govern not despite but through ambiguities. Hence, while territoriality stipulated “jurisdictional monopoly [of the state] within a bounded geographical space” (p 34) and encouraged the company rulers to initiate legal reforms (ban sati, for example) in the early 19th century, historicism, which emphasised the organic links between law and volksgeist (national spirit), exercised a restraining influence in preventing the colonisers from going the whole hog and in imposing British law on Indian subjects.

The “civilisational immaturity” of the colonised meant that subjects needed a “premodern form” (especially those who followed Indian religions) like personal law (p 37), which was completely distinct from the rational and universal British law. So as economic activity came to be governed by rational, universal and secular law, there was an equation among religion, family and irrationality (the domain of personal law). Incidentally, as the Crown institutionalised religious personal law in post-1857 India, in Britain, domestic matters such as marriage and divorce were moved out of the religious domain and brought under secular law. But, as Stephens shows, this differentiation of spheres was hardly or ever accomplish­ed; instead it repeatedly threw up questions about the boundaries between them. These “deep currents of instability” “infused secular legal governance” (p 56).

Stephens traces the impact of this governance through indeterminacy by looking at case law in a host of matters—marital property, customs, Islamic ritual, relations among Hindus and Muslims, and Islamic finance. Chapter 2 on marital property traverses the realms of colonial law courts and fatawa (sing. fatawa, legal advice) production in Deoband’s Dar-ul-Uloom to reveal how, even as there were differences in the interpretation of the Islamic tradition regarding details of marriage and divorce, the two forums converged in continuously defining and redefining the boundaries bet­ween the secular and the religious.

Marital property is a particularly tricky issue because it conjoins a private, religious matter (marriage/divorce) with a public, secular concern (property). Stephens also shows how Muslim personal law was far from a static entity, though it was sought to be presented as such, as it was constantly contested within and outside the judiciary. Consider how the restitution of the husband’s conjugal rights was interpreted by various levels of the judiciary and in Deoband fatawa.

In a major precedent-setting 1867 judgment analysed by Stephens, the Privy Council endorsed the restitution of the conjugal rights of an estranged Muslim husband by drawing mainly from English legal precedents and civil law, and only marginally engaged with the Islamic tradition’s views on this matter (pp 62–64). Even as the Privy Council acknowledged that marriage was a domestic matter to be governed by Muslim personal law, what was applied was colonial civil law. In the same decision, the Privy Council also ruled on the husband’s right to his wife’s property; in this matter, however, the Privy Council rejected Muslim law and concluded that the property belonged to the wife because she was a woman observing pardah and thereby “vulnerable to economic exploitation” (p 65).

Stephens underscores the disparity in the situations between the metropole and the colony and the underlying Orientalist ideas. While British women gained property rights only a decade or more after the 1867 judgment, the Privy Council was to deal with the anomaly that Muslim women had rights that their British counterparts did not. Stephens observes that the Privy Council solved this dilemma by arguing that though women in pardah had the right to own property, “their actual capa­city to manage this property was still inferior to that of a mature male” (p 66). Turning to another case, involving the question of mahr (an obligatory payment made by a Muslim husband to his wife, which is incorporated in the marriage contract or nikah­nama), an Indian Muslim judge ruled in 1886 that once the marriage was consummated, the wife did not have the right to leave her husband even if the mahr was not paid. Syed Mahmood, the Indian judge and the son of the famous Muslim thinker and reformed Sayyid Ahmad Khan, drew extensively on Hanafi fiqh (jurisprudence), but clinched his decision by relying on the Indian Contract Act, which supposedly applied exclusively in economic and, hence, secular matters (pp 70–72).

In contrast, Deobandi alim (Islamic scholar) Aziz-ul-Rahman Usmani issued fatawa noting that if a husband failed to pay the mahr or financially support his wife, the latter was well within her rights to leave his house (p 79). Stephens clearly brings out the complex interactions between these diverse domains and their deep intertextuality, despite pronouncements to the contrary. More­over, despite differences in reasoning and decisions arrived at, both the state and non-state actors “increasingly emphasised the particular importance of religious laws in adjudicating domestic matters” (p 85).

Ambiguous Differentiations

In Chapters 4 and 5, Stephens shifts her focus to explore how secular governance exacerbated intra-religious and inter-religious conflicts through its ambiguous differentiations between state and community, and reason and religious belief. I will focus on the Rangila Rasul controversy, related to a scurrilous pamphlet about the Prophet, which brings the story to the 1920s and, in a way, is a prelude to several debates about secularism in contemporary India. Stephens writes that the British treated religious communities as a category rather than a unit of governance (pp 107–08). Unlike in the Mughal period, communities no longer, at least in theory, had the rights to their own means of legal regulation and enforcement.

Instead, the British administered personal laws, included religion as a census category and implemented separate electorates for religious communities. Indian religious laws, particularly its Muslim version, were neither rational nor universally applicable, were distinct from the rational codes of the Raj and had to be neutrally administered by the colonial courts themselves rather than be left to the respective communities. Stephens points out a noteworthy feature of the Rangila Rasul controversy—Muslim protests against the pamphlet and its Hindu author reached its peak not immediately after its publication in 1924, but following his acquittal by a colonial court in 1927 from charges of promoting enmity and hatred among religious communities (p 141).

Hence, the Muslim sentiments were not visceral or natural (and therefore irrational) but intertwined with and produced by how the colonial state responded to the injury caused by the pamphlet. The Hindu reaction to Muslim protests is especially relevant to understand the eventual development of secularism in postcolonial India. Following the Muslim dissatisfaction with the 1927 verdict, the colonial government amended the Indian Penal Code to include a new Section 295A that criminalised expressions made with “deliberate and malicious intentions of outraging the religious feelings of any class” (p 147). Hindu politicians took to the press and the podium to condemn “Muslim fanaticism.”

Lala Lajpat Rai was perhaps one of the earliest nationalist politicians to use the word secularism in opposition to and a solution to what he termed “religionism,” which he identified as a distinctly “Muslim problem” (pp 149–50). Stephens writes that Rai’s thoughts points to the “intimate relationship between calls for secularism and a majoritarian discourse of Hindu nationalism that demonised ­Islam” (p 150). Even as the law recognised that religious feelings ought to be protected, the nascent discourse of secularism did not see all religious sentiments (especially Muslim) as equal.

The Current Conjuncture

But, is the demonisation of Muslims and Islam a feature peculiar to Indian secularism? Lemons argues otherwise in her book. She writes that “like minorities in other modern states, Indian Muslims must perform both their difference from the majority and their loyalty to it” (p 37). The situation of Indian Muslims is an example of the “constitutive bind” faced by religious minorities in a secular state, Lemons writes (p 64) citing the anthropologist Mayanthi Fernando’s work on French Muslims. Indian Muslim women bear the bulk of this dynamic’s burden with “their inequality [being taken] as a sign of the pathology of Muslim kinship and consequently of the community’s failure to be fully modern and fully Indian” (p 37).

In Chapter 2, Lemons lays out this argument through the analysis of the 2016 Supreme Court judgment outlawing triple talaq (talaq ul-ba’in) and the work of a Muslim woman’s arbitration centre called mahila panchayat in Delhi. The 2016 judgment was hailed as a victory for Muslim women in their battle for equality, though, as Lemons notes, instant/irrevocable divorce, or triple talaq, had already become legally untenable in practice (p 41). The Muslim Women (Protection of Rights on Marriage) Act, 2019 passed by Parliament, following the court’s directive in the 2016 judgment, criminalised triple talaq.

The point about the judgment and the law that Lemons highlights is important—while both stress the need for gender equality and equality between Muslim and non-Muslim women, the solution for that is to rectify defective kinship practices among Muslims based on a correct interpretation of Islamic law. The non-state body of the mahila panchayat is, in theory, committed to the secular idea of a similarity in economic precarity of women across religions and often draws on secular legislation against domestic violence in adjudicating marital disputes mainly aimed at reconciling feuding couples (p 57). But Muslim women and families were marked out as particularly religious, and the mahila panchayat the author studied in a Muslim-dominated neighbourhood in Delhi also occasionally relied on Islamic precepts in their adjudication practice (pp 60–64). Lemons concludes that for both state and non-state bodies, “religion is the instrument for regulating the family” (p 64). Hence, secularism produces Muslims, particularly Muslim women, as religious and peg their emancipation to freedom from their religious tradition.

Lemons’ ethnography moves on to study other Islamic fora where marriage and divorce matters are adjudicated. In the second part of the book, she looks closely at the activities of the Dar ul-Qaza (inappropriately translated as shari‘a courts) presided over by a qazi (judge) at the All India Muslim Personal Law Board offices in Delhi and its intersections with state courts. Dar ul-Qazas participate in the secularism project in two ways.

The division between the family and economy allegedly fixed by secularism is repeatedly called into question in divorce proceedings at the Dar ul-Qaza. Divorce is granted by a qazi when he is convinced that a marriage failed to “replace relations of exchange and distribution with relations of care and shelter” (p 78). In adjudicating such matters by relying on Islamic principles, the Dar ul-Qaza not only marks out the family as distinct from the economy, but also underscores that it is to be governed by religious norms (p 97). Engaging with a 2017 Supreme Court judgment on the legality of Dar ul-Qazas, which termed them as “Alternate Dispute Resolution mechanism” (p 100), Lemons argues that they, in practice, “intersect with, rather than run parallel to, the state courts” (p 101).

By implementing the same laws as the state, Dar ul-Qazas, despite operating beyond the purview of the state, “enforces and produces the very construction of the private sphere of the family [also the domain of religion], that the state itself is invested in maintaining” (p 107). The last section of the book turns to the work of a mufti (jurist) who, through his fatawa and spiritual healing, engage in adjudicating talaq ul-ba’in and marital problems. In Chapter 5, Lemons writes that the contradictory approaches of fatawa and state courts to talaq ul-ba’in—one mostly authorising it, while the other seldom endorsing though still sustaining it (p 152)—nevertheless works to reproduce secularism.

The contradiction in the interpretation should not obscure the fact that the mufti works within the domain of personal law and the courts concern themselves mainly with the economics of divorce. Both, importantly, do not see a space for Muslim women beyond family. The penultimate chapter turns to healing practices such as amulets (ta‘wiz) or ingestion of Qur’anic verses to solve marital difficulties. This is quite a distinct adjudication method unlike any other encountered in the book so far. One reason for this is that spiritual healing is not a directive like a fatawa or a court judgment because the former “transform[s] both people and the broader cosmological relationships that afflict them and produce their problems” (p 190).

Hence, certain Qur’anic verses are considered to be particularly effective in combating black magic (pp 179–80). Varying assumptions about what language is or can do underlie these different forms of directives. However, Lemons underscores that because its practitioners (like the mufti), its critics (certain currents of reformist Islam) and those who are indifferent to it (courts, for example) see it as a religious matter, spiritual healing “captures the secular work of co-constituting religion and ­secularism” (p 172).

State–Society Disjunct

There is plenty of food for thought in these two important volumes, though I will reflect only on a few morsels here. As pointed out at the outset, it is necessary for empirical studies of secularism from places like India to engage in a dialogue with path-breaking theoretical interventions in the subject. And that is something that both these volumes do. Agrama (2013b) has observed that secularism is a “questioning power … a form of power crucially involved in questioning the norms it establishes” (p 33, emphasis in the original). Secularism simultaneously defines and challenges the boundaries that separate religion from other spheres of social life. Stephens and Lemons show how across its history Muslim personal law has been used to constitute and reconstitute religion along with domains, such as family (private), while distinguishing it from others, such as economy and politics (public).

Stephens, in particular, shows the divergences in the evolution of personal law in the metropole and the colony; moves that were undergirded by Orientalist ideas about the irrationality and inferiority of the colonised masses. The legacy of colonial rule, which saw the beginnings of the problematisation of Muslims and Islam, has become the norm in postcolonial India.

Lemons, on the other hand, underscores that the “constitutive bind” of religious minority is a structural effect of secularism rather than something peculiar to Indian secularism. The simultaneous and incessant demanding/troubling of religious minorities’ belonging to the nation is integral to the operation of secularism. But where the authors depart or add to literature like that of Agrama (2013b) and Asad (2003) is when they stress the role of non-state actors in the project of secularism.

Secularism in India, according to Lemons, is thus “particular but not exceptional” (p 28), which can help nuance arguments like that of Bhargava’s (2007), which overstress the “distinctiveness of Indian secularism.” Drawing on Foucault’s idea of governmentality, Stephens writes about “rubber-band-like control” of the colonial state, which allowed them to govern religion that was “simultaneously wide in scope, and flexible and fragmented in application” (p 14). In a way, these books can also be read against and with scholars who have identified a vicious circle—the lack of fit between the statist secular project and a traditional Indian society leads to pathologies of communal violence, which is then battled by the state in the name of defending secular and nationalist ideals (Nandy 1998; Madan 1998).


One question which I was left wondering as I read through the books, especially Lemons, was how the authors underscore the difference between the state and the non-state to advance their core argument of secularism as a project jointly advanced by state and non-state actors. This differentiation has been troubled by scholars to ask how the “state effect” is produced, or the ability of the state to appear “as an apparatus that stands apart from the rest of the world” (Mitchell 2006: 180). In fact, Sharma and Gupta (2006) argue that we ought to

conceptualise “the state” within (and not automatically distinct from) other institutional forms through which social relations are lived, such as the family, civil society, and the economy [and, if I may add, religious life]. (p 9, emphasis in the original)

If these scholars’ reflections about the modern state are endorsed, does the proposed difference between Indian secularism and those in France, Egypt or Turkey, which are state-centric projects, stand up to scrutiny? Maybe one way to read Lemons and Stephens is that, since fora like the Dar ul-Qaza work within and reproduce the Indian state’s conceptualisation of what counts essentially as religious and the latter’s scope in social life, these fora instantiate the state’s ultimate authority in this matter.

Then we are close to Agrama’s (2013b) observation that the “active principle of secularism [of deciding the role of religion in social life] is a principle of sovereign state power” (p 97, emphasis in the original). In other words, the centrality of the state to secularism. Seen from a different angle—that of effects, or the kind of subjects produced by state and non-state actors—both the state and practices like fatawa (notwithstanding differences between them) occupy the same secular space and confine Indian Muslims to the space of religion and render precarious their belonging to the nation.

Hence, it is not really clear what and how the distinction between the state and the non-state contributes to the ­debate on secularism, or how it can advance a comparative study of secularisms across national contexts. Perhaps, there is another question to pose. If Mitchell (2006) and Sharma and Gupta (2006) are observations on the modern state, what does the adjective secular add to it? How do we understand secular power if, inter alia, it is produced through the “state effect,” or the apparent distinction between state and non-state?

Another striking feature that requires commentary is the totalising character of secularism in the two books. That secularism generates and operates through indeterminacies is something proved beyond dispute in both Stephens and Lemons. But they are sceptical about the existence of a space beyond the state or law, as is assumed by Madan and Nandy, that can solve the pathologies incessantly generated by secularism.

One cannot transcend the secular and secularism as they are defining elements of the condition of our modern being, and they also shape our thought, its forms and its modes of production (Agrama 2013a). Both the works under review are acknowledgements of these fundamental realities. Yet, Stephens especially is not dismissive of the law as an instrument to engage with secularism’s failings. She rejects the “deep pessimism” of Agrama (2013b) who seeks “possibilities outside of secular, liberal law to foster alternative ‘cultural and ethical sensibilities’ or methods of ‘care of the self’” (p 18). There is no freedom or escape from these constraining and enabling powers of secular law, but Stephens cites Judith Butler who advocates strategies “to work with the trap that one is inevitably in” (p 18).

One such instance is found by her in the Rangila Rasul controversy. Rajpal, the publisher of the pamphlet, was murdered by a man called Ilmuddin, who was subsequently executed. Defending Ilmuddin in court, Muhammad Ali ­Jinnah, even while not condoning the murder, pleaded for mercy because it stemmed from feelings of anger at the person who ridiculed a religious figure the accused venerated. Stephens adds that the courtroom turned out to be “a potent space for fusing feelings of injury and calls for mercy with protests against injustice” (p 151). That is, though Jinnah could not save Ilmuddin, colonial law that rendered religious (particularly Muslim) sentiments irrational nonetheless provided the space to articulate affects that could not be easily grasped by it in the first place.

Lemons is not persuaded by Agrama’s (2013b) identification of the “asecular” (p 187) practices and spaces that are indifferent to or disentangled from the central question of secularism to draw the line between religion and other realms of life. Agrama (2013b) writes that fatawa issued by the Fatawa Council of Egypt’s Al-Azhar does not partake in the labour of secularism and is a “practice by which a self, in the multiplicity of its affairs, is connected to and advanced as part of the Islamic tradition” (p 184). Lemons, however, states that positing the “asecular” requires the acceptance of the secular premise of differentiation. First, one has to assume that “divorce and reconciliation are private matters that can be separated from the state’s interest in family,” and second, one has to accept that since “the fatawa council does not explicitly debate questions of public order and the family, it can be neatly separated from the political work of delineating the relation between religion and law/politics” (p 151). Both of these claims do not hold in the Indian case and fatawa are “touched by, and help to make, the secular present” (p 152). They are “a matter of public debate” and their primary subject (talaq ul-ba’in) is “the object of even more vociferous ­debate” (p 152).

It is worth noting that Agrama (2013b) who posits the “asecular” is cautious to distinguish it from the non-secular (often equated with religious) and the post-secular (a temporal marker for that which comes after secularism) and stresses that an “asecular” practice like fatawa or the fatawa council exist within and are produced by secular power (p 187). The asecular is “like a bubble within a bubble, produced by it but no longer of it, bouncing around within its confines yet otherwise largely indifferent to it” (p 187). Temporally nor spatially, it is neither outside or comes after secular power.

Agrama’s (2013b) thought opens the possibility to think about forces and processes that enable subjects to be other than what they are or should be. It is not insignificant that scholars who have made influential contributions to theorising secularism, whose work frames the outlook of Lemons and Stephens, have turned to other beings (ghosts and the post-human) and modalities (enigma, the uncanny) to trouble the “human-centric foundations of secularity” (Fernando 2017; Fernando 2020; Agrama 2018). Lemons writes about the “excess” produced by “spiritual healing’s powerful speech,” which is “anathema to secular­ism” (p 172), for it has “the capacity to bring together spirit and matter, mind and body” (p 187).

The treatments are not meant only for the body or the person, but meant to transform the entire sphere of relationships within which they are embedded, which includes other beings like jinn. Maybe Stephens “politics of grieving” (p 150) manifest during the well-attended funerals of Rajpal and Ilmuddin, in which both communities mourned their losses and subsequently strengthened the calls for inter-religious amity, could also be read as to how the law simultaneously creates inter-religious discord and enables unanticipated forms of becoming otherwise (Povinelli 2011). If we take the “excess” of the secular condition seriously, there might be possibilities for other forms of beings and relations to emerge, some of which include non-human and non-natural beings like jinns.


Agrama, Hussein Ali (2013a): “Notes on the Idea of Theorizing Secularism,” viewed on 1 April 2020,

— (2013b): Questioning Secularism: Islam, Sovereignty and the Rule of Law in Modern Egypt, Chicago: Chicago University Press.

— (2018): “Proximate Enigmas,” 21 November, viewed on 1 April 2020,

Asad, Talal (1993): Genealogies of Religion: Discipline and Reasons of Power in Christianity and Islam, Baltimore: Johns Hopkins University Press.

— (2003): Formations of the Secular: Christianity, Islam, Modernity, California: Stanford University Press.

Bhargava, Rajeev (1998): Secularism and Its Critics, New Delhi: Oxford University Press.

— (2007): “The Distinctiveness of Indian Secularism,” The Future of Secularism, T N Srinivasan (ed), New Delhi: Oxford University Press, pp 20–53.

Fernando, Mayanthi (2017): “Supernatureculture,” 11 December, viewed on 1 April 2020,

— (2020): “Human,” 13 March, viewed on 1 April 2020,

Hirschkind, Charles (2011): “Is There a Secular Body?” Cultural Anthropology, Vol 26, No 4, pp 633–47.

Madan, T N (1998): “Secularism in Its Place,” Secularism and Its Critics, Rajeev Bhargava (ed), New Delhi: Oxford University Press, pp 297–320.

Mahmood, Saba (2016): Religious Difference in a Secular Age: A Minority Report, Princeton: Princeton University Press.

Mitchell, Timothy (2006): “Society, Economy and the State Effect,” The Anthropology of the State: A Reader, Aradhana Sharma and Akhil Gupta (eds), Oxford: Blackwell.

Nandy, Ashis (1998): “The Politics of Secularism and the Recovery of Religious Toleration,” Secularism and Its Critics, Rajeev Bhargava (ed), New Delhi: Oxford University Press, pp 321–44.

Needham, Anuradha Dingwaney and Rajeswari Sunder Rajan (2007): The Crisis of Secularism in India, Durham: Duke University Press.

Povinelli, Elizabeth A (2011): “Routes/Worlds,” e-flux Journal, No 27, viewed on 1 April 2020,

Sharma, Aradhana and Akhil Gupta (2006): “Introduction: Rethinking Theories of the State in the Age of Globalisation,” The Anthropology of the State: A Reader, Aradhana Sharma and Akhil Gupta (eds), Oxford: Blackwell.


Updated On : 4th Aug, 2020


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