In 2017, the National Crime Records Bureau (NCRB) revised how it collected data. Amongst the new categories it recorded was hate crimes against persons belonging to the Northeast, mob lynching, murders committed for religious reasons, and crimes against activists, journalists and whistle blowers. The data was collected, but none of it was published in bureau’s annual report, Crime in India.
Northeastern Indians therefore hold full formal citizenship while being positioned outside the informational infrastructure through which the state recognises collective harm. They are citizens in law and aggregates nowhere.
When the home ministry was asked why, the junior home minister told Parliament in 2021 that the collection of hate crimes and mob lynchings had been discontinued and gave the reason plainly: the data was unreliable because these crimes had not been defined.
This sequence deserves close attention for its circularity. The state declines to publish data on crimes against Northeastern persons on the ground that the category is undefined. Yet, it is the state itself which has not acted on its own power to define the category. The absence of a definition becomes the standing justification for the absence of data, and the absence of data becomes the standing justification for treating each incident as isolated. The loop closes in a way that requires no further decision by anyone. Nobody has to refuse to count—the impossibility of counting is embedded in the definitional gap.
The question this article pursues, then, is not what the state should do. It is why the state does not do it, and what the shape of its inaction reveals. These questions acquire particular urgency in the context of recent incidents involving people from the Northeast in mainland cities. In February 2026, three women from Arunachal Pradesh were allegedly subjected to racial and sexist abuse in Delhi, with the incident prompting an FIR and the invocation of the SC/ST (Prevention of Atrocities) Act. More recently, also in Delhi in September 2026, Chongtham Vikram Singh, a 55-year-old musician from Manipur, was beaten to death, following an altercation outside his home. While the police have not established a racial motive, the killing nevertheless renewed concerns among Northeastern communities about safety and discrimination in the capital.
Our question leads through a Supreme Court judgment on hate crimes and mob lynchings, whose directions are binding but whose compliance has required repeated judicial follow-up, through a pattern in which remedial machinery appears only after mobilisation and lapses once mobilisation subsides, and finally to what this arrangement suggests about how the Indian state understands diversity, and about who is recognised as belonging, beyond the formal guarantee of citizenship.
Built and Withdrawn
The home ministry’s stated reason for not having a record of crimes against people from the Northeast, that the crimes were undefined, is worth examining rather than dismissing. It is not a trivial claim. Crime statistics require legal categories, and a category with no statutory definition produces returns that state police forces will fill inconsistently. The ministry's objection has real force as a technical matter. Its force as a justification, however, depends entirely on treating the definitional gap as a fact of nature rather than as a policy choice.
A remedial apparatus that responds to mobilisation rather than to evidence has a predictable consequence. It converts the protection of citizens into something that must be demanded, and demanded repeatedly, by the people requiring protection.
In his reply to Parliament in 2021, the junior home minister evaded a question on whether the government had made any effort to define hate crime within the criminal law framework. Rather he described an intention to create a legal structure that is citizen-centric. What was asked of the government was hardly unusual. The NCRB has over its 34 years of existence produced definitions for dozens of categories that did not previously exist in statute, including acid attacks and cyber offences. These were added precisely because social conditions changed and the state chose to make them legible.
The pattern that emerges is therefore selective legibility. The events of 2017, excluding certain heads of crime while retaining others, were not random. They clustered around categories whose publication would have produced a measurable, comparable, year on year account of who in India is being harmed on the basis of who they are. This reframes the problem for Northeastern communities specifically. The claim is not that the state has never seen them. In 2017 it saw them clearly enough to draft a crime head in their name. The claim is that having seen them, it chose not to look.
The Limits of Legal Compulsion
If administrative reluctance were the whole explanation, judicial intervention should have resolved it. It has not, and the reason why is instructive.
In July 2018, in Tehseen S. Poonawalla v. Union of India, a bench comprising Chief Justice Dipak Misra and Justices A. M. Khanwilkar and D. Y. Chandrachud addressed mob lynching, vigilantism and hate crime. The court held that states had a duty to ensure that no individual or group took the law into their own hands. Its directions to the states included nodal officers in every district, fast track courts, and a victim compensation scheme. Officials who failed to act were to be held accountable. The court recommended that Parliament create a separate offence for lynching, reasoning that a dedicated law would instil fear of law among those who engage in such acts. These directions were subsequently affirmed as binding on all authorities under Article 141 of the Constitution.
Northeastern people carry the burden of producing sufficient public disruption to trigger a state response that the documented scale of harm should have triggered on its own.
Five years after the judgment, the matter returned to the Supreme Court because compliance remained incomplete. A bench of Justices Sanjiv Khanna and Bela Trivedi in 2023 directed the home ministry to convene a meeting of state department heads and to gather and consolidate data on compliance with the 2018 judgement. In the same period, the National Federation of Indian Women approached the court seeking enforcement, with counsel arguing that incidents had continued despite the Poonawalla directions and asking what remedy remained available. When the court later disposed of a related petition, it observed that monitoring incidents across states from Delhi would be impractical.
Three features of this sequence bear on the argument. First, a binding direction from the highest court did not by itself produce a data collection mechanism. Second, the court’s own eventual position, that centralised monitoring from Delhi is impractical, converges with the executive’s position that public order is a state subject. The jurisdictional argument that the union government offered to Parliament acquired a measure of judicial endorsement. Third, and most tellingly, the mechanism the court did direct in 2023 was itself a response to a petition. The state did not consolidate compliance data because the 2018 judgment required it. It was directed to do so because litigants returned to court and asked again.
Any serious inquiry should press here why binding law produces so little movement. The answer is not that the directions lack force. It is that the directions require an institution to make itself accountable by generating the evidence of its own failure. Compliance data on lynching prevention is, functionally, a record of how often prevention did not occur. Where no independent body compiles that record, the institution being measured controls whether measurement happens at all. Law that depends on self-reporting by the party it regulates will produce reporting only under sustained external pressure.
Remedy as a Function of Mobilisation
This brings the argument to its central proposition. Across the two decades covered by this record, remedial action by the Indian state has correlated not with the incidence of violence but with the intensity of mobilisation following particular deaths.
The evidence for this is the record itself. Violence against Northeastern residents of Delhi is documented from at least 2006, when Lucy Kashung, a woman from Mizoram, died in a case a Delhi court later ruled a murder. Cases follow in sequence. Kezevilie, a Naga student, was stabbed at a party in 2007. Gaipuiliu Gangmei, a minor girl from Manipur’s Naga community, was found dead after a suspected rape in 2009. That same year Langailu Pamei, a nurse from Manipur, was found with her throat slit, and Ramchanphy Hongray, a 19-year-old Tangkhul Naga woman, was found dead after an alleged sexual assault. In 2013 Reingamphi Awungshi was found dead in her rented room, in a death police recorded as suicide and which her family and Northeast student organisations disputed. Akha Salouni died in 2014 after a beating that police classified as road rage, a classification Northeast civil society organisations contested.
A harm that cannot be shown to be systematic generates no obligation beyond case by case adjudication, and case by case adjudication treats each death as the first of its kind.
None of these produced structural response. One did. Nido Tania’s death in January 2014, following an altercation in which racial remarks were reportedly made, generated sustained national protest by Northeastern students’ organisations and led to the constitution of the Bezbaruah Committee. The committee found that 86% of Northeastern respondents reported experiencing some form of racial discrimination (p.8) It recommended specialised police responses, faster judicial processes and public awareness measures (p.34). Delhi Police subsequently established a special unit and a helpline.
The distinction between Nido Tania’s case and the others is not a distinction in severity. It is a distinction in mobilisation. What the pattern indicates is that the Indian state possesses a well-developed repertoire for responding to violence against Northeastern communities, consisting of committees, helplines, nodal officers and special units, but this repertoire is activated by public pressure rather than by evidence of harm.
Ironically, this was even visible in the Bezbaruah Committee itself. The report found of widespread discrimination against Northeastern people, yet the Committee that produced it was constituted only after a death that could not be ignored. And once that storm had passed, the committee’s central recommendation, that discrimination be systematically recorded, was not implemented even as the NCRB was simultaneously drafting and then withdrawing a crime head for exactly that purpose.
A remedial apparatus that responds to mobilisation rather than to evidence has a predictable consequence. It converts the protection of citizens into something that must be demanded, and demanded repeatedly, by the people requiring protection. Northeastern students, families and civil society organisations carry the burden of producing sufficient public disruption to trigger a state response that the documented scale of harm should have triggered on its own.
The Threshold of Recognition
What does this arrangement indicate about Indian democracy, and about who belongs beyond the letter of the law? Formal citizenship for Northeastern Indians is not in question. Their rights are constitutionally identical to those of any other citizen. The record examined here suggests that formal equality and substantive recognition operate on different registers, and that the gap between them is administered rather than accidental.
The death of Chongtham Vikram Singh will be investigated as an individual case. Whatever that investigation concludes, it will not enter any national series, because no such series exists.
Substantive recognition, as the record suggests, requires that a group’s experience be institutionally counted. Counting is what converts individual suffering into a public fact that policy must address. A harm that is never aggregated cannot be shown to be systematic. A harm that cannot be shown to be systematic generates no obligation beyond case by case adjudication, and case by case adjudication treats each death as the first of its kind. Northeastern Indians therefore hold full formal citizenship while being positioned outside the informational infrastructure through which the state recognises collective harm. They are citizens in law and aggregates nowhere.
This condition also illuminates the threshold at which the Indian state extends recognition. That threshold, the record indicates, is not the occurrence of harm. It is the occurrence of harm accompanied by sufficient political disruption. This is a description of a democracy that responds to voice rather than to need, and the distinction matters enormously for numerically small and geographically dispersed populations. Northeastern communities in Indian cities are demographically minor and politically fragmented across many states, languages and ethnicities. Their capacity to generate the scale of mobilisation that produced the Bezbaruah Committee is intermittent by structural necessity. A remedial system keyed to mobilisation will therefore under serve precisely those populations whose smallness makes sustained mobilisation hardest, which is to say precisely those populations that most require institutional protection rather than political leverage.
Conclusion
The death of Chongtham Vikram Singh will be investigated as an individual case. Whatever that investigation concludes, it will not enter any national series, because no such series exists. It will not be comparable to Nido Tania’s death or to Akha Salouni’s, except by the informal labour of journalists, researchers, and community organisations who maintain the connection that the state does not.
This outcome is not a gap in the state’s knowledge. It is a product of decisions the state made and then declined to revisit. The category was created in 2017. Data was collected under it. The results were withheld as unreliable. The collection was discontinued. The stated reason was that the crimes lacked definition, and the power to define them rests with the body that cited their absence as grounds for stopping. Meanwhile, binding Supreme Court directions on preventive and remedial measures have required repeated return to court to produce even partial compliance, and the court itself has acknowledged the impracticality of central monitoring. At no point in this sequence did anyone announce that violence against Northeastern people would not be counted.
The outcome was produced by a definitional gap left open, a publication decision left unexplained, and a compliance mechanism left dependent on litigants.
Prithiraj Borah is an assistant professor of sociology in the Department of Law, NALSAR University of Law, Hyderabad.
