In March 2026, a special court in Veraval, Gujarat, delivered its verdict in the Una atrocity case — ten years after a mob stripped four Dalit men, tied them to a vehicle, and beat them through town with iron pipes and wooden sticks while cameras rolled. Of the forty adults tried, thirty-five were acquitted. The five who were convicted had already served their sentences. They walked out of the courtroom as free as the thirty-five who had been cleared.
Justice, the court effectively ruled, had been done. It had not. What had been done — and what has been done again and again across India's judicial history — was something more precise: a caste atrocity had been reclassified as a lesser affair. The Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act — India's primary legal instrument for naming and punishing caste violence — was rendered largely beside the point. The pattern has a name. It is impunity. And its most instructive case study remains not Una but a village in Bhandara district, Maharashtra, where, on the night of 29 September 2006, four members of a family named Bhotmange were murdered.
Surekha Bhotmange was not passive. That was, in the logic of caste, her offense. She owned agricultural land. She had built a permanent house. When upper-caste men destroyed her crops and intimidated her family, she filed police complaints. When she witnessed a wage dispute that ended in violence, she and her daughter Priyanka testified at the police station, helping secure the detention of an upper-caste accused man. On the evening of September 29 — the same day that man was released on bail — a mob of approximately forty descended on the Bhotmange home. Surekha, Priyanka, and her sons Roshan and Sudhir were dragged into the street, stripped, and paraded naked through Khairlanji village. Surekha and Priyanka were gang-raped and killed. The boys were murdered when they tried to defend their mother and sister. Bhaiyalal Bhotmange, hiding in the fields, survived to testify. "The entire village was involved, sir," he told investigators. "Entire village."
What followed in the courts was almost as devastating as what happened that night. The Bhandara Sessions Court convicted eight men in 2008 — but declined to invoke the PoA Act. The killings, the court reasoned, were an act of "revenge" over a personal dispute, not a caste atrocity. The Bombay High Court upheld the convictions in 2010 and again refused the Act. The Supreme Court confirmed this position in 2019. Three tiers of India's judiciary, confronted with a case involving a Dalit woman murdered after testifying against upper-caste men — with her teenage daughter raped and killed beside her, their bodies dumped in a canal — found no caste motive sufficient to trigger the one law Parliament had specifically written for exactly this kind of crime.
Anand Teltumbde, in his 2010 study The Persistence of Caste: The Khairlanji Murders and India's Hidden Apartheid, named this mechanism with precision: caste atrocities are not random violence. They are punishment administered to Dalits who have stepped outside the social boundaries caste assigns them. Surekha's land, her legal testimony, her refusal of subordination — these were not background to the crime. They were the crime's cause. Courts that read the killing as a neighbor dispute did not misunderstand the case. They understood it exactly as the dominant community had framed it: a personal matter, resolved violently. The word "caste" was therefore not needed, and the Act could not apply.
B.R. Ambedkar had diagnosed the structure decades earlier. In Annihilation of Caste, he argued that law alone could not dismantle caste because caste operated through a thousand informal sanctions enforced by social consensus before any court was ever reached. The protections, the enumerated prohibitions, the constitutional guarantees — these were necessary but insufficient against a system that had embedded hierarchy into the ordinary arrangements of village life, labor, land, and marriage. In Castes in India, he traced how endogamy was the mechanism through which caste reproduced itself across generations, impervious to formal reform. What Ambedkar predicted — that constitutional promises would be systematically hollowed from within — is precisely what the Khairlanji massacre's judicial history documents.
The data keeps confirming the argument. The NCRB's 2024 atrocity figures, released in May 2026, counted 55,698 cases of crimes against Scheduled Castes — a 3.6 percent decline from the previous year that the government has treated as a favorable sign. A significant portion of that statistical drop, however, is a legislative artifact: when Parliament replaced the Indian Penal Code with the Bharatiya Nyaya Sanhita in 2023, "simple hurt" was reclassified as non-cognizable, mechanically reducing cognizable case counts by approximately 30 percent nationwide. In Jaipur, the conviction rate on completed SC atrocity cases was zero. The India Human Development Survey-II untouchability module, the most comprehensive survey of its kind, found that 27 percent of households admitted to practicing untouchability — this in a study asking people to self-report a practice they already knew to be illegal. The honest number is almost certainly higher.
There is a version of the counterargument that deserves a serious hearing. India has made institutional effort that cannot simply be dismissed: the PoA Act exists, has been amended twice, and carries provisions no other democracy has felt compelled to write. The 103rd Constitutional Amendment, extending reservations to the economically weaker sections beyond caste lines, is presented by its proponents as evidence that the state is moving toward a post-caste politics — class, not community, as the salient category of disadvantage. The headline data, on this reading, is improving. Decades of reservation policy have created a Dalit professional class. Progress is real, if slow and incomplete.
But this is precisely where Khairlanji bites hardest. The Act did not fail there because it was absent from the statute book. It failed because three successive courts refused to use it. India did not need new legislation after Khairlanji — it needed its existing law applied. The 2015 and 2018 amendments to the PoA Act were themselves responses to judicial and executive evasion: courts demanding proof of "sole" caste motive as a prior condition; police refusing to register FIRs; magistrates extending anticipatory bail to accused perpetrators. Parliament kept writing the same law because institutions kept undoing it. As for the shift toward class: the 103rd Amendment expanded benefit to the upper-caste poor while leaving untouched the social logic that makes untouchability operate independently of income. The Bhotmange family had land. Their economic mobility did not protect them — it made them a target. In a caste society, assertion without protection does not produce safety. It produces Khairlanji.
Teltumbde himself became an illustration of the dynamic he had spent decades documenting. In 2020, he was arrested under India's counterterrorism statute — the Unlawful Activities Prevention Act — and held as an undertrial for thirty-one months at Taloja Central Jail. The charges alleged links to a Maoist conspiracy. More than 600 international scholars signed statements calling the prosecution a suppression of anti-caste scholarship. The Bombay High Court granted bail in 2022, finding no prima facie evidence to sustain the charges. That the scholar who wrote the most rigorous account of the Khairlanji massacre could spend nearly three years in prison before trial — while the judiciary continued to decline to name the Bhotmange murders as caste crimes — is not incidental context. It is the argument made flesh.
The Una acquittal is ten years removed from the flogging that provoked it and almost twenty years removed from the night in Khairlanji. Together they trace a stable line. Courts do not simply fail to apply the PoA Act — they actively reconstitute the facts of a case until the Act is inapplicable. What arrives as a caste atrocity leaves as a personal dispute. Motive disappears. Community disappears. The word "caste" disappears. The law, which exists precisely to prevent this disappearance, stands by. Ambedkar argued in the end not that bad laws were the central problem, but that the social order producing those laws — and producing the courts that interpret them — had to be annihilated. The judiciary of independent India has had nearly eight decades to prove him wrong. The families of Khairlanji and Una are still waiting for a court that will say what everyone in both villages already knew.