The Evolution of Hester’s Scarlet Letter Essay Example for Free

The Evolution of Hester’s Scarlet Letter Essay In the novel, The Scarlet Letter, the protagonist, Hester Prynne, is forced to publically wear her sin on her sleeve. She committed adultery, which was a sin that was highly chastised by the Puritan society. The Scarlet Letter that Hester wore first symbolized the burden and humiliation that accompanied the sin. Throughout the novel however, the meaning of the letter changed to parallel Hester’s own development into a strong, independent woman. The letter starts out as a symbol of shame. A public trial in the presence of her fellow New England citizens forced Hester to wear this shameful letter. As Hester was standing on the pillory, her punishment for committing adultery was to display the â€Å"mark of shame upon her bosom† for all to see (Pg 58). The Scarlet Letter diminished Hester’s image by subjecting her to public humiliation, which affected her emotionally and mentally. Puritan women at the pillory claimed that the Scarlet Letter could possibly be hidden on the outside by physically covering it, but â€Å" the pain of it will be always in [Hester’s] heart† (Pg 49). Hester had to endure belittlement and harassment at the hands the disappointed Puritan mob. Even the Puritan children, â€Å"the most intolerant brood that ever lived,† made disparaging remarks about her (Pg 83) because they â€Å"scorned [Hester and Pearl] in their hearts†(Pg 84). Hester was forced to the bottom of the social ladder if even children can get away with making fun of an elder without fear of punishment in such a rigid society. The various tragic events exacerbated the guilt that Hester felt. This is demonstrated when she told her husband, Chillingsworth, that it was her fault for committing adultery to conceal the identity of the person with whom she committed the sin. She hid the identity of Pearl’s father because the constant humiliation and rebuke that she had to endure led her to believe that her sin was completely her burden to bear. Hester knew that â€Å"her deed had been evil† (Pg 80) because Pearl acts out in a hostile and sinful manner. Pearl has grown to become a walking embodiment of the Scarlet Letter. Consequently, Hester felt overwhelming guilty. However, as the novel progresses Hester’s attitude towards the Scarlet Letter changes and the meaning of the letter goes through a metamorphosis that would help Hester wear the letter with pride. When Hester no longer saw the Scarlet Letter as a symbol of shame, it represented her freedom from the letter’s hold over her as she wore the letter with pride. Though she could have easily been defeated and sunken into despair, she persisted through the hardships. She became a productive member of society by sewing miraculous materials, which allowed the people’s perception of her to change. This can be interpreted as a change in meaning of the Scarlet Letter. Before, it had stood for adultery, but eventually people recognized it as a symbol of â€Å"her many good deeds† (Pg 142). The changes in the letter, both physically and symbolically, reflected the perception that people had of Hester. Hester transformed into a â€Å"powerful peculiar,† an individual who was â€Å"so kind to the poor, so helpful to the sick† (Pg 142). Despite her initial difficult circumstances, Hester turned around her life. As Hester experienced her transformation, she showed resentment towards her punishment. She knew that there were others in the community who committed sins, some even greater than hers, but these atrocities went unpunished. Consequently, Hester’s changing attitude revealed that while she saw her act as a sin, she felt that her punishment was unjustified due to the hypocrisy that was prevalent within the society. Hester realized that the persecution against her was unfair given the hypocritical standards of the society and that other people should perhaps wear their own Scarlet Letter for the sins that they have committed. Her path to redemption instilled the confidence in her to believe that she was not inferior to others; if others were not going to own up to their own mistakes, she was not required to do so either. She was no longer sorry for what she had done because while she faced the consequences head-on, others were cowardly concealing their sins in order to evade public humiliation and punishment. Due to the double standard in society, Hester decided that the act was not as evil as it was made out to be by society. She told Dimmesdale that â€Å"what [they] did had a consecration of its own† (Pg 170). The Scarlet Letter was supposed to remind Hester and the townspeople of her sin, but â€Å"the Scarlet Letter had not done its office† (Pg 145). The meaning of the Scarlet Letter that Hester wore changed throughout the novel to parallel Hester’s own path to enlightenment and freedom from societal pressure. The metamorphosis of Hester’s image and the change in her inner thoughts represented how she overcame the burden of the Scarlet Letter. The Scarlet Letter was an embodiment of Hester’s life.

Analysis of Two In The Campagna by Robert Browning Essay -- Robert Bro

Analysis of "Two In The Campagna" by Robert Browning "Two In The Campagna" is essentially a love poem, written by Browning to capture the tragic and dark aspects of a relationship. The poem commences with romantic images of the couple sitting in the fields of Rome in spring. The first line, starting with 'I wonder' sets the contemplative tone of the piece, and the poet follows one particular trail of thought for several stanzas. Clearly, the poet is trying to capture what cannot be easily confined; he is attempting to articulate a sentiment of fleeting love that perhaps can only be felt. Browning describes the thought floating away over the picturesque scenery: ?Help me to hold it! First it left The yellowing fennel, run to seed There, branching from the brickwork?s cleft?? The flowing lines and use of enjambment represent his thoughts spilling over, almost frolicking through the fields of Rome. This style of poetry is used by Browning regularly: for example in ?Love Among The Ruins? his thoughts flow over from one line to the next ? however the message of this poem is the opposite from ?Two In The Campagna?, as the former depicts the enduring power of passionate love, and the latter describes the natural diminution of feelings after the passionate climax of sex. The poem becomes increasingly vibrant and passionate as the couple evidently become sexually aroused together. In my opinion, the imagery of the beetles inside a flower is incredibly vivid and is one of my personal favourite images in all of Browning?s love poetry: ??Where one small orange cup amassed Five beetles,--blind and green they grope Among the honey-meal?? The images are abundantly fertile, with an intense evocation... ...uch illogically violent ways. However, it does capture the essence of jealousy, possessiveness and the yearning for eternal unity that many people do feel. Browning has evidently taken this to the extreme effectively, as it is his style to shock the reader. In conclusion, Browning uses many different techniques of conveying the complexities of human passion, and does this effectively from many points of view on love. However, it does seem that Browning usually has a slightly subdued, possibly even warped view of love and romance ? and this could be because his own love life was publicly perceived to be ultimately perfect but retrospectively it appears his marriage with Elizabeth Browning was full of doubt and possessiveness, as seen in ?Any Wife To Any Husband? which most critics believe to be based on the troubled relationship between the Browning?s.

Was Dollarization a Success in Zimbabwe

CHAPTER ONE [pic] 1. Introduction At independence in 1980 the Zimbabwe dollar replaced the Rhodesian dollar at par at a rate which was higher than the American dollar. Although this quickly deteriorated, it was not until the late nineties that a series of events led to the demise of the Zimbabwean dollar. In 2008 in an 18-month ‘experiment’, foreign currency was accepted as legal tender for transactions with a set number of retailers. Honorable Members will be aware that in the hyper-inflationary environment characterizing the economy at present, our people are now using multiple currencies for day to day business transactions, alongside the Zimbabwe dollar. These currencies include the South African Rand (ZAR), United States Dollar (USD), Botswana Pula (BWP), Euro, and British Pound Sterling, among others. In line with the prevailing practices by the general public, Government is, therefore, allowing the use of multiple foreign currencies for business transactions, alon gside the Zimbabwe dollar. †[1]However, months later, in March of 2009, the newly instated Finance Minister, Tendai Biti, announced that the Zimbabwe dollar would be suspended indefinitely. [2] The main argument in this piece is that the Zimbabwean crisis in the 2000s and the subsequent stabilization of the economy were made possible by the dollarization of the Zimbabwean economy in 2009. This article investigates the recent monetary experience of Zimbabwe with dollarization. It shows how dollarization has allowed Zimbabwe to quash hyper-inflation[3], restore stability, increase budgetary discipline, and re-establish monetary credibility.This paper analyses the effects of the dollarization of the Zimbabwean economy in 2009, in the wake of devastating hyper-inflation and a political crisis that reached its zenith with the electoral crisis of 2008. Though there is a direct nexus between the two processes, the former cannot be exclusively ascribed to the latter; there are a host of other issues that have contributed to the economic and financial breakdown in Zimbabwe. 1. 11 The Background to the ProblemThe Reserve Bank of Zimbabwe (RBZ) was forced to revalue the Zimbabwean dollar, three times in a space of less than three years, because of rampant hyper-inflation in the country. In August 2006, in an operation called ‘Sunrise 1’, the RBZ removed 3 zeroes from Zimbabwe’s currency and promised to introduce a new currency in the near future. In August 2008, exactly two years after the first revaluation, the RBZ slashed a further 10 zeroes from Zimbabwe’s currency, calling this ‘Sunrise II’. Rampaging hyper-inflation forced the government to erase another 12 zeroes in early February 2009.This was ‘Sunrise III’. Thus, a staggering 25 zeroes had been slashed from the Zimbabwean currency within a space of only three years. The hyper-inflation was just unsustainable, and when the Zimbabwean dollar was officially shelved in March 2009, the highest single denomination was a 100 trillion dollar note. When the 100 trillion dollar note was introduced on 16 January 2009, it was worth the equivalent of US$ 30 on the parallel market. The establishment of the Government of National Unity (GNU) saw the dollarization of the Zimbabwean economy and the shelving of the Zimbabwean dollar in March 2009.Dollarization is a portfolio shift away from domestic currency to foreign currency, to fulfil the main functions of money – store of value, unit of account, and medium of exchange. It is typically a result of unstable macroeconomic conditions and is a rational response of people seeking to diversify their assets in the face of heightened domestic currency risk. Efforts to revive the battered Zimbabwean economy, largely through the dollarization of the Zimbabwean economy are assessed through the lens of the banking sector.The banking sector thrived during the peak of the Zimbabwean crisis, as most bank s became key players in highly speculative activities in areas such as Zimbabwe’s bullish stock exchange and real estate. The profits that were being realized in the banking sector trickled down to their workers who became the best remunerated workers amongst all the sectors in Zimbabwe. With dollarization of the economy in 2009, the once vibrant banking sector was suddenly facing the grim prospect of disintegration, which had plagued sectors such as teaching during the peak of the Zimbabwean crisis.The banking sector was adversely affected by the dollarization of the economy, as the speculative activities that were reaping huge rewards for the banks were wiped out overnight by the adoption of more stable currencies at the expense of the precarious Zimbabwean dollar. This spelt disaster for the banking fraternity, as most banks in the first few months of dollarization struggled to pay their workers in hard currency and instead were forced to downsize their operations and lay- off some of their employees.The paper argues that in complete contrast to most sectors in the economy, the banking sector boomed during the crisis, and the Zimbabwe Congress of Trade Unions (ZCTU) monthly remuneration lists in 2008 saw the banking workers consistently topping the lists. However, the dollarization of the Zimbabwean economy turned the tables on this once prosperous sector, as bank workers like the bank tellers and other clerical workers found themselves being laid-off, as most banks struggled to remunerate their workers in hard currency. 1. 12 Objectives ? To assess the performance of the banking sector before and after dollarization. To investigate the effects of dollarization of the Zimbabwean economy on the banking sector. ? To investigate the advantages and disadvantages of dollarization on the banking sector. 1. 13 The Research Problem The effects of dollarization on the banking sector after the dollarization of the Zimbabwean economy. 1. 14 The Research Question What effect does the dollarization of the Zimbabwean economy have on the banking sector? 1. 15 Sub Questions 1. What is dollarization? 2. What are the forms of dollarization? 3. What are the costs of dollarization? 4.What are the benefits of dollarization? 5. What impact does dollarization have on the banking sector? 6. Was dollarization a success in Zimbabwe? 1. 17 Significance of the study To the researcher The research is in partial fulfillment of the requirements of a Bachelor of Commerce Honours Degree in Accounting at the National University of Science and Technology. It will allow the researcher to have a deeper understanding and both theoretical and practical knowledge in the area of research and encourage a practical application of theoretical concepts on the area under study.To the banking sector The research is set to provide enlightment on the impact of dollarization of the Zimbabwean economy to the banking sector. To the university The research project will assist the university in coming up with a curriculum on the study of the dollarization of the Zimbabwean economy and the impact that it had on the banking sector. 1. 18 Assumptions ? All respondents have adequate knowledge of the developments in their particular organizations. ? Respondents will give truthful responses adequate to make reasonable inferences. The researcher assumes that respondents will respond within a reasonable time period to enable the timetable to be adhered to. ? The researcher assumes that he will have enough financial resources to meet all the expenses. ? There will not be institutional disturbances that could delay completion of the project. ? Secondary data will be available. 1. 19 Literature Review Data will be collected from the textbooks, libraries, newspapers, journals and the internet. 1. 20 Theoretical Framework Was the dollarization of the Zimbabwean economy a success to the banking sector?The research intends to use both primary and secondary sources of data. These sources of data will help to explore an analysis of what past researchers have brought to light in relation to the impact of the dollarization of the Zimbabwean economy on the banking sector. It is under this section that the researcher intends to explain various forms of dollarization. The benefits and costs of dollarization shall be explored through exclusive use of the internet and various text books and journals. 1. 21 Definitions of TermsFor the purpose of this study the following abbreviations and definitions will be used. Hyper-inflation – Ruinously  high  increase (50  percent  or more per month) in  prices  due  to the near total  collapse  of a  country's  monetary system, rendering its  currency  almost worthless as a  medium of exchange. Although hyperinflation is caused mainly by excessive  deficit spending  (financed by  printing  more  money) by a  government, some  economists  believe that social  breakdown  leads  to hyperinflation (not vice versa), and that its roots lie in political rather than economic  causes. 4] Dollarization – occurs when the inhabitants of a country use foreign  currency  in parallel to or instead of the domestic currency as a store of value, unit of account, and/or medium of exchange within the domestic economy. The term is not only applied to usage of the  United States dollar, but generally to the use of any foreign currency as the national currency. [5] BWP – Botswana Pula GNU – Government of National Unity USD – United States Dollar RBZ – Reserve Bank of Zimbabwe ZAR – South African Rand ZCTU- Zimbabwe Congress of Trade Unions 2. 00 Research DesignSample of people to send questionnaire is going to be based on knowledge, accessibility and convenience. 2. 11 Instruments for Data Collection The research will be based on both primary and secondary methods of collecting data which include surveys, interviews, questionnaires and published information and journals. The researcher will use a number of methods in the collection of primary and secondary information. The following methods will be used to gather primary information: ? Questionnaires- these will be designed and hand posted to the selected respondents.Sample of people to send questionnaire is going to be based on knowledge, accessibility and convenience. ? Interviews- interviews will be conducted to collect some of the information required in the research. The following sources will be used to tap all secondary data available about the subject: ? Use of textbooks ? The researcher in the course of the research will access newspapers, financial reports, business journals and the Internet. Information will also be attained through discussions with classmates and fellow researchers. 2. 2 Data Presentation and Analysis There will be use of tables, graphs and statistical tools/methods including pie charts in data presentation and anal ysis. These will be used first to present the data obtained through the questionnaires in the interviews, which will then make possible the analysis of the data in a more objective and quantitative manner as well as less subjective and qualitative way. A report shall then be compiled and presented on the final outcome of the findings and analysis. 2. 13 Research Timetable and Budget (Project Scheduling)Research Time Table SectionChapterMonth/Period Introduction1Two weeks Literature Review2Two weeks Research Method3Four Weeks Data Presentation ; Analysis4Four Weeks Conclusion and Recommendation5Two weeks Research Budget Cost CenterCost Amount (USD) Typing and Printing$20 Photocopying$20 Internet$30 Traveling costs$50 Food Costs$30 Total$150 2. 14 Research Limitations ? The research is going to be limited due to the studies that will be going on concurrently with the research project and the time committed to the research project will be reduced. Time, unforeseen institutional disturb ances at N. U. S. T. may delay timely completion of the research project. ? Lack of cooperation – there could be unexpected lack of cooperation from respondents, if any are to be involved in the project. ? Possible limited access to confidential information, which might be useful for the purposes of the research. ? Financial constraints – The research could be affected by the writer’s limited funds to fully meet all due costs to be incurred during the research 2. 15 Source ReferencingThe â€Å"According to â€Å"Kararach G, Kadenge P, and Guvheya G, (2010). CURRENCY REFORMS IN ZIMBABWE: AN ANALYSIS OF POSSIBLE CURRENCY REGIMES,† will be used. 2. 16 Bibliography (a) Books The Harvard way of referencing shall be employed (b) Journals The â€Å"According to â€Å"Kararach G, Kadenge P, and Guvheya G, (2010). CURRENCY REFORMS IN ZIMBABWE: AN ANALYSIS OF POSSIBLE CURRENCY REGIMES,† will be used. ——————— – [1] (Acting Minister of Finance, Cde Patrick Chinamasa on Budget Presentation to Parliament on 29 January 2009. ) [2] Ibid. ; Biti, T. ‘Statement on the 2009 Budget’, Presented to the Parliament of Zimbabwe by the Minister of Finance, 17 March 2009, http://www. zimtreasury. org [3] Hyper-inflation is defined by Hanke (2008) as a situation where the year- on- year rate of inflation breaches the 12,875 percent mark. Zimbabwe began to hyper-inflate in 2007 and hyper-inflation was officially reported by the Zimbabwe Central Statistical Office to have peaked at 231 million percent in July 2008. [4] http://www. businessdictionary. com/definition/hyperinflation. html [5] http://www. answers. com/topic/dollarization#ixzz2BXaOhuVJ ———————– 1

Judicial killings by the Police - Free Essay Example

Sample details Pages: 11 Words: 3180 Downloads: 1 Date added: 2017/06/26 Category Law Essay Type Narrative essay Level High school Topics: Police Essay Did you like this example? In India, à ¢Ã¢â€š ¬Ã…“encounter killingsà ¢Ã¢â€š ¬Ã‚  are tragically common. Encounter killing is now a euphemism to indicate extrajudicial execution by the police in staged à ¢Ã¢â€š ¬Ã…“encounterà ¢Ã¢â€š ¬Ã‚  scenarios where persons are killed apparently in exercise of the policeà ¢Ã¢â€š ¬Ã¢â€ž ¢s right to self-defence. Incidents of encounter killings are widely reported in news media and are even glorified. Don’t waste time! Our writers will create an original "Judicial killings by the Police" essay for you Create order Perpetrators of this brand of violence enjoy impunity and immunity from the criminal justice system. Further, police personnel with special à ¢Ã¢â€š ¬Ã…“expertiseà ¢Ã¢â€š ¬Ã‚  in extrajudicial killings are hailed as à ¢Ã¢â€š ¬Ã…“encounter specialistsà ¢Ã¢â€š ¬Ã‚ , enjoy key positions in the system and are revered in the State institution and in civil society. This widespread support of encounter killing is also attributable to the fact that, most commonly, victims are those considered anti-social elements with criminal antecedents. The wide prevalence of encounter deaths or extra-judicial killings by the Police and the Armed Forces post independent period has been documented by various human rights organizations. A study conducted by the Asia Pacific Human Rights Network noted that encounter killings were not isolated incidents but occurred throughout India. They are part of a deliberate and conscious state administrative practice for which successive Indian governments must bear responsibility.[1] Indeed, successive Indian governments have adopted a de facto policy sanctioning extra-judicial killings by members of the police forces, army and security personnel. Definitions: Extra judicial killings, as defined in the United Nations Congress on the Prevention of Crime and the Treatment of Offenders, refers to the à ¢Ã¢â€š ¬Ã…“the practice of killing and executing political opponents or suspected offenders carried out by armed forces, law enforcement or other governmental agencies or by paramilitary or political groups acting with the support, tacit or otherwise, of official forces or agencies.à ¢Ã¢â€š ¬Ã‚ [2] According to Oxford Advanced Learners Dictionary à ¢Ã¢â€š ¬Ã‹Å"encounterà ¢Ã¢â€š ¬Ã¢â€ž ¢ in general means à ¢Ã¢â€š ¬Ã…“unexpectedly be faced with or experience (something hostile or difficult)à ¢Ã¢â€š ¬Ã‚ , it can be defined in the context for the present purpose as à ¢Ã¢â€š ¬Ã…“an incident in which police shoot dead a suspected criminalà ¢Ã¢â€š ¬Ã‚ .[3] Sir Nigel Rodley, UN Commission on Human Rights Special Rapporteur on Torture (1993-2003),extra-judicial executions as à ¢Ã¢â€š ¬Ã…“killings committed outside the judicial process by or with the consent of, public officials, other than as necessary measures of law enforcement to protect life or as acts of armed conflict carried out in conformity with the rules of international humanitarian law.[4] Amnesty International in a 2003 report characterised an extra-judicial execution as à ¢Ã¢â€š ¬Ã…“an unlawful and deliberate killing carried out by order of a government or with its acquiescenceà ¢Ã¢â€š ¬Ã‚ . The report further says that à ¢Ã¢â€š ¬Ã…“Extra-judicial killings are killings which can reasonably be assumed to be the result of a policy at any level of government to eliminate specific individuals as an alternative to arresting them and bringing them to justice. These killings take place outside any judicial framework.à ¢Ã¢â€š ¬Ã‚ [5] The phrase à ¢Ã¢â€š ¬Ã‹Å"encounter killingà ¢Ã¢â€š ¬Ã¢â€ž ¢ is derived from the term à ¢Ã¢â€š ¬Ã‹Å"encounterà ¢Ã¢â€š ¬Ã¢â€ž ¢ as employed by the Indian Police Service, along with the Indian Military and Paramilitary, to describe a specific kind of contact whereby an alleged criminal or person of interest is killed in à ¢Ã¢â€š ¬Ã‹Å"spontaneous, unplanned à ¢Ã¢â€š ¬Ã…“shootoutà ¢Ã¢â€š ¬Ã‚ Ãƒ ¢Ã¢â€š ¬Ã¢â€ž ¢.[6] According to Manisha Sethi, a police à ¢Ã¢â€š ¬Ã…“encounter killingà ¢Ã¢â€š ¬Ã‚ , or, simply, à ¢Ã¢â€š ¬Ã…“encounterà ¢Ã¢â€š ¬Ã‚  is a term with no legal validity but which has seeped via the media into Indian English so surely that it has acquired a life of its own. It refers to a face-to-face interaction between the police and suspects leading to the killing of the suspects.[7] Encounter killings are one element of a broader category called extra-judicial executions. Note that these custodial deaths generally exclude à ¢Ã¢â€š ¬Ã…“ encoun terà ¢Ã¢â€š ¬Ã‚  killings. The police typically claim they killed in self-defence outside police custody.[8] Encounter and Fake encounter à ¢Ã¢â€š ¬Ã¢â‚¬Å" the Difference: The real encounters means state-owned force or police opens fire on armed criminals, indigenous armed people groups or non-state actors as a retaliatory measure to defend civilians or themselves or safeguard public life or Institutions of public importance like Mumbai attack or 9/11 US attack or Indian parliament attack or attack on police /armed forces convoy. Fake encounter is a murder under the colour of performance of official duty. A fake encounter is where a person has been killed in cold blood, and not in self-defence, whereas a genuine encounter is that in which a person has been killed in self-defence. If somebody is firing at you, and the only way to stop him from killing or grievously injuring you is to shoot back, in that case youà ¢Ã¢â€š ¬Ã¢â€ž ¢re a part of a genuine encounter Where as a fake encounter is when you catch hold of somebody and kill him in cold blood. There is absolutely no threat to you.[9] In afake encounter, the police or armed forces kill the suspects, when they are either incustodyor are unarmed, and then claim to have shot them in self-defence. In such cases, the police may plant weapons on or near the corpses to provide a justification for killing the individual. To explain the discrepancy between records that show that the individual was in police custody at the time of his encounter, the police may say that the suspect had escaped.[10] It is alleged that police typically take a suspected militant into custody without filing an arrest report. If the suspect died during interrogation, security forces would deny ever taking the person into custody and instead claim that they were killed during an armed encounter.[11]It is alleged that police would add weapons to the dead body to demonstrate cause for killing the individual, stage-managing t he encounter, leading to the popular phrase à ¢Ã¢â€š ¬Ã…“fake encounter killing.à ¢Ã¢â€š ¬Ã‚ [12]Other similar occasions were that militants were staging an attack, or the suspect attempted to escape to recover militant arms while being escorted. At times, the police applied for and received production warrants, which allowed them to remove individuals accused in terrorism cases from jail. They often killed the detainees in fake encounters outside the jail.[13] The Modus operandi of encounter killings reveals whether it is fake or not. There are certain incidents associated with encounters such as the time and place of occurrence and the arms recovered gives a lead that the encounter was a staged or fake. Most of the staged encounter killings occured in middle of night, large vehicles such as Maruti gypsies, TATA Sumo and van were used for transportation. The place of occurrence was far from human settlement or habitation. Forensic/ballistic examinations of exhibits were mos tly avoided or unduly delayed, and the investigation ultimately fizzled out. There was police patrolling in the crime areas prior to and after, but not during the killings. The Central and State governments generally interpret the word, encounter, to mean genuine encounters, with fake encounters being an exception rather than the rule. Those fighting for civil liberties, however, say that the dividing line between genuine and fake encounters is rather tenuous and argued that most of the cases considered by the police as genuine are indeed fake.[14] Historical Background Killing people in cold-blood and describing the incident as à ¢Ã¢â€š ¬Ã…“an encounter where an exchange of fire took place at the end of which the police discovered some dead bodiesà ¢Ã¢â€š ¬Ã‚  dates back to the early part of the last century. Perhaps this devious method of killing was invented by the British.[15] A notorious instance of an encounter took place in 1924 when Alluri Sitarama Raju, who le d a tribal upheaval against the British, was killed. However, recent research explored the reality that he was caught and killed in cold-blood without any exchange of fire.[16] à ¢Ã¢â€š ¬Ã‹Å"Encounter has been a dirty word in India for decades, especially since the Punjab insurgency ofthe 1980s and 1990s.[17] Since independence encounter killings have been prevalent in the unstable regions such as Jammu and Kashmir, Punjab, areas with Maoist presence, the North East, and crime flooded areas of Mumbai.[18] Though today encounter is considered as an operation against terrorism, insurgency and left wing extremism, anti-dacoit, each state in India has its own cause and reason, own story behind the birth of encounters killings. The history of encounters in some of the major states are as follows. Maharashtra Maharashtra was among the first States to introduce à ¢Ã¢â€š ¬Ã…“encounter killingsà ¢Ã¢â€š ¬Ã‚  as a method of policing and has perfected it over time.[19] Encounters fall into two categories in the State à ¢Ã¢â€š ¬Ã¢â‚¬Å" shootouts that take place in Mumbai, which are largely underworld-related, and those that take place in the districts, particularly in the naxalite corridor that borders Andhra Pradesh.[20] Police documents say that encounters began in the early 1980s, when the underworld started exercising control over the city, when Gang rivalries were at their peak, the police began to eliminate key gangsters in order to curb crime or even to settle scores and such encounters eventually became a means to break the underworld in the city.[21] But by the early 1990s the after serial bomb blasts of 1993, a special force trained in automatic weaponry was created in the police to combat the underworld terror and finish off gangsters thereby virtually given the licence to kill which later came to be known as the Encounter Specialists. Jammu and Kashmir Encounters have been a regular feature in Jammu and Kashmir for the past 15 years to counter insurgency-related violence. The intensive campaign of encounter killings of civilians by Kashmiri militant groups, started in 1998, continued, and included several political killings. Separatist militants committed numerous, serious abuses, including killing of armed forces personnel, police, government officials, and civilians; torture; rape; and brutality. They also were responsible for kidnaping and extortion in the state.[22] The first encounter that attracted attention was the killing of five people by the police and 7 Rashtriya Rifles in the Pathribal area of south Kashmir on March 25, 2000. This came five days after the massacre of 35 Sikhs by unidentified gunmen in Chhatisinghpora in the valley obviously to invite the attention of visiting United States President Bill Clinton towards Kashmir.[23] The US Department of State estimated the Indian Security forces killed 1520 alleged militants in 2000 and 1082 in 1999, all in encounters, in Jammu and Kashmir.[24 ] North Eastern States For years, security forces inManipurhave faced allegations of human rights violations and extrajudicial killings committed under cover of the Armed Forces Special Powers Act (AFSPA). Irom Sharmila, started a hunger fast in protest against the AFSPA in 2000.[25] In July 2004, the nation was rocked by the protests of a group of Manipuri women who marched to an Assam Rifles base in Imphal, stripped naked and raised a searing banner: à ¢Ã¢â€š ¬Ã…“Indian Army Rape Usà ¢Ã¢â€š ¬Ã‚ . A fortnight earlier they were protesting the rape, torture and murder of Thangjam Manorama, 32, who was picked up from her home at night by the Assam Rifles.[26] other notable encounters include Azad Khan, Khumbongmayum Orsonjit, Nameirakpam Gobin Meitei, Nameirakpam Nobo Meitei, Elangbam Kiranjit Singh, ChongthamUmakanta and Akoijam Priyobroto.[27] Punjab Most of the police encounters in Punjab were disguised under counter-insurgency between 1984 and 1995. The victim usu ally was a person believed to be a militant or involved in the militant separatist movement. These encounters were reported to local newspapers and to the family members of those killed. Andhra Pradesh Andhra Pradesh, probably the worst affected state with hundreds of such encounters that snatched away the lives of about 4,000 people during the last four decades. It was during the 1940s, more than 3,000 cadres and other persons who participated in the Telangana peasant armed struggle (1946-51) were killed in à ¢Ã¢â€š ¬Ã…“encountersà ¢Ã¢â€š ¬Ã‚ , most of them being fake.[28] While it was the Nizamà ¢Ã¢â€š ¬Ã¢â€ž ¢s police that used the liquidat ­ing method during 1946-48, two-thirds of these encounter killings took place under military rule and subsequent civil rule of the government of India between 1948 and 1951.[29] Thus, the then Hyderabad state has the dubious distinction of the first state to kill its own people in the name of encounters in post-1947 India.[3 0] Tamil Nadu Nearly 60 per cent of all cases on extrajudicial deaths are received from the state of Uttar Pradesh (UP), where the victims are usually individuals with criminal backgrounds. In Uttar Pradesh, Bihar and TamilNadu, all the anti-dacoit operations are disguised in the form of encounters. In Tamilnadu the trend of encounter started since 1980à ¢Ã¢â€š ¬Ã¢â€ž ¢s. Some of the famous encounter killings in Tamilnadu are that of Veerappan, the notorious forest brigand who was killed by the Special Task Force (STF) in 2004, Al-Umma activist Imam Aliand his associates in Bangalore, Venkatesa Pannaiyar, local rowdies like à ¢Ã¢â€š ¬Ã‹Å"Punkà ¢Ã¢â€š ¬Ã¢â€ž ¢ Kumar, à ¢Ã¢â€š ¬Ã‹Å"Urundaià ¢Ã¢â€š ¬Ã¢â€ž ¢ Rajan, à ¢Ã¢â€š ¬Ã‹Å"Manal meduà ¢Ã¢â€š ¬Ã¢â€ž ¢ Shankar and the more recently the killing of five suspects involved in a bank robbery. Its interesting to note that most of encounters which involved killing of rowdies, gundas, goons and anti-social elements were fake , the people of Tamilnadu appreciate as eliminating them results in maintenance of law and order. The encounter killings of Uttar Pradesh state is discussed in the next chapter. Besides a common national agenda such as anti-terrorism, anti-naxal operations and also anti-dacoit operations encounter killings happens for various other reasons too. Infact most of the fake and staged encounter killings happens for these reasons. Personal vendetta One such factor is the personal vendetta of the police, either towards the fellow police personnel Gonda Encounter case[31] or RTI activists who acts as whistleblowerà ¢Ã¢â€š ¬Ã¢â€ž ¢s bringing out the truth and justice into limelight.[32] Contract killing Some of the officials who are trained in such encounter become à ¢Ã¢â€š ¬Ã‹Å"encounter specialistsà ¢Ã¢â€š ¬Ã¢â€ž ¢ and later for their personal benefits carry out contract killings by converting these into encounters. Some were acting against rival gangs and bumping off o nly members of a particular gang.[33] The recent judgment of a Delhi court holding guilty ten policemen for the killing of two businessmen in an encounter killing is another example for such killing.[34] To Byepass the enquiry for custodial death There are instances where in order to bypass magisterial enquiry under the amended Section 176(1-A)[35] of the CrPC the custodials death too are converted to encounter deaths. According to section 176(1 A) the Judicial Magistrate or the Metropolitan Magistrate has to enquire into the death of persons in police custody. Peopleà ¢Ã¢â€š ¬Ã¢â€ž ¢s Watch, in its independent fact-finding, found that most cases of encounter killings, were in fact, custodial deaths where the deceased was already in the custody of the police and that an encounter scenario was staged as though the deceased resisted arrest, in order to bypass the procedure established under Section 176(1-A).[36] [1] à ¢Ã¢â€š ¬Ã…“Encounter Killing, Torture and Custodial Deathà ¢Ã¢â€š ¬Ã‚  available at à ¢Ã¢â€š ¬Ã…“https://urgentquestions.blogspot.in/2010/12/sunshine-india-encounter-killings.htmlà ¢Ã¢â€š ¬Ã‚  [2] Sixth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Caracas, 25 August-5 September 1980: report prepared by the Secretariat (United Nations publication, Sales No. E.81.IV.4), chap. I, sect. B, resolution 5. [3] https://www.oxfordlearnersdictionaries.com/us/definition/english/encounter_2 (Last Accessed March 2014) [4] Nigel S. Rodley and Matt Pollard, The Treatment of Prisoners under International Law 252 (Oxford University Press, Oxford 3rd ed., 2009) [5] Amnesty International, Israel and the Occupied Territories: Israel must put an immediate end to the policy and practice of assassinations, 4 July 2003 available at : https://www.amnesty.org/en/library/asset/MDE15/056/2003/en/16f1eef4-d6bd-11dd-ab95 a13b602c0642/mde1505620 03en.htm [6] Belur Jyoti, à ¢Ã¢â€š ¬Ã…“Why do the Police use Deadly Force? Explaining Police Encounters in Mumbaià ¢Ã¢â€š ¬Ã‚ , British Journal of Criminology (2009, Nov) [7] Manisha Sethi, à ¢Ã¢â€š ¬Ã…“Fake Encounters in India: Instant Justice By Police and Posthumous Trial by Mediaà ¢Ã¢â€š ¬Ã‚  available at:https://aparc.stanford.edu/events/fake_encounters_in_india_instant_justice_by_police_and_posthumous_trial_by_media/ (Last Accessed March 2014) [8]Praful Bidwai, à ¢Ã¢â€š ¬Ã…“Murder by encounterà ¢Ã¢â€š ¬Ã‚ , available at: https://www.prafulbidwai.org/index.php?post/2009/10/09/Murder-by-encounter (Last Accessed March 2014) [9] Astha Maheswari, à ¢Ã¢â€š ¬Ã…“Fake encounters in Indiaà ¢Ã¢â€š ¬Ã‚  available at https://www.ndtvmi.com/b4/dopesheets/aastha.pdf (Last Accessed March 2014) [10] https://en.wikipedia.org/wiki/Encounter_killings_by_police [11] US Department of state, India Human Rights Practices, 1993 available at: https://dosfan.lib.uic .edu/ERC/democracy/1993_hrp_report/93hrp_report_sasia/India.html [12] Pepper, DanielIndia Makes a Place for Dirty Harry available at: https://www.nytimes.com/2009/03/01/weekinreview/01pepper.html?_r=1pagewanted=all [13] Communication to Special Rhttps://www.nytimes.com/2009/03/01/weekinreview/01pepper.html?_r=1pagewanted=allepresentative on the Situation of Human Rights Defenders. Ensaaf. 05/12/2006 available at: https://www.ensaaf.org/pdf/un/Bhatti.pdf [14]Venugopal.V, à ¢Ã¢â€š ¬Ã…“Evading Guidelinesà ¢Ã¢â€š ¬Ã‚ , 27(17) FRONTLINE (2010, Aug 14-27 [15] Venugopal, N, à ¢Ã¢â€š ¬Ã…“Fake Encounters: Story from Andhra Pradesh 42(41) EPW 4106-11 (2007, Oct) [16] Ibid [17] Anil Kalhan, à ¢Ã¢â€š ¬Ã…“Human Rights: Quantifying Indias Encounter Deaths And Disappearancesà ¢Ã¢â€š ¬Ã‚ , SAJA Forum March 13, 2009à ¢Ã¢â€š ¬Ã‚ , https://www.sajaforum.org/2009/03/human-rights-quantifying-encounter-deaths-and-disappearances.html (Last Accessed March 2014) [18] R ao, P.Srikrishna Deva, à ¢Ã¢â€š ¬Ã…“Encounter Killings in Andhra Pradeshà ¢Ã¢â€š ¬Ã‚  30 EPW 2787-8 (1995, Nov) [19] Katakam Anupama, à ¢Ã¢â€š ¬Ã…“Fake justiceà ¢Ã¢â€š ¬Ã‚ , 26(20) FRONTLINE (2009, Sep. 26-Oct. 09) https://www.frontline.in/static/html/fl2620/stories/20091009262002000.htm [20] Ibid [21] Ibid [22] United States Department of State,2000 Country Reports on Human Rights Practices India, February 23, 2001 available at : https://www.state.gov/j/drl/rls/hrrpt/2000/sa/717.htm [23] Shujaat Bukhari à ¢Ã¢â€š ¬Ã…“Fake justiceà ¢Ã¢â€š ¬Ã‚ , 26(20) FRONTLINE (2009, Sep. 26-Oct. 09) [24] United States Department of State,2000 Country Reports on Human Rights Practices India, February 23, 2001 available at : https://www.state.gov/j/drl/rls/hrrpt/2000/sa/717.htm [25] Teresa Rehman, à ¢Ã¢â€š ¬Ã…“Murder In Plain Sightà ¢Ã¢â€š ¬Ã‚ , 6 (31) TEHELKA (2009, August 08) available at https://www.tehelka.com/murder-in-plain-sight/ [26] Ibid [27] https://www.hueiyenlanpao.com/headlines/item/8561-extrajudicial-killings-panel-wraps-up-hearing-report-to-be-submitted-in-a-week [28] Supra Venugopal, N, à ¢Ã¢â€š ¬Ã…“Fake Encounters: Story from Andhra Pradesh 42(41) EPW 4106-11 (2007, Oct) [29] Ibid [30]Ibid [31] The1982 Gonda Encounteris an ongoing criminal case involving the murder of 13 people including the Deputy Superintendent of police inGonda districtof the Indian state of Uttar Pradesh. A alleged group clash had occurred on the night of 12 March 1982 in Madhavpur village located within the Katrabazar police station area in Gonda district. DSP K P Singh, on getting the information about the criminals Ram Bhulawan and Arjun Pasi, went to the village with the police.KP Singh was later taken to the hospital where doctors declared him brought dead. 12 other people also died who were later declared dacoits by R B Saroj (who was head of police station) and his partners. The police later submitted a report saying the DSP was killed by dacoits in a bomb attack and the policemen killed the dacoits in an encounter. They also showed the bodies of 12 people as evidence. Later it was found that it was a killing motivated by the conduct of an honest officer in this case, Mr Singh who wanted to act against his subordinates who were hand-in-glove with local criminals. After 24 long years of investigation, the special CBI court convicted eight policemen on March 29, 2013. In the trial period of 19 policemen who were charge sheeted, 10 had died and seven had retired. On 5 April 2013, the CBI court judge Rajendra Singh announced death penalty for three policemen and life imprisonment for the five remaining accused. [32] https://blogs.timesofindia.indiatimes.com/the-real-truth/entry/encounter-killings-of-rti-activists-gujarat-tops-charts [33] à ¢Ã¢â€š ¬Ã…“Fake encounters back in closetà ¢Ã¢â€š ¬Ã‚  https://www.asianage.com/mumbai/fake-encounters-back-closet-751 [34] https://www.pucl.org/bull etins/2007/PUCLdec07.pdf [35] After 2005 Amendment of Cr.P.C Section 176(1-A) was included which reads as follows, Where,à ¢Ã¢â€š ¬Ã¢â‚¬  (a) any person dies or disappears, or (b) rape is alleged to have been committed on any woman, while such person or woman is in the custody of the police or in any other custody authorised by the Magistrate or the court, under this Code in addition to the inquiry or investigation held by the police, an inquiry shall be held by the Judicial Magistrate or the Metropolitan Magistrate, as the case may be, within whose local jurisdiction the offence has been committed [36] https://www.peopleswatch.org/dm-documents/Reports/Annual Report/Annual Report 2008-2009.pdf