Law & Justice · September 2026
23 Death Sentences in 5 Months.
A single sessions judge in Muzaffarnagar, Uttar Pradesh sentenced 23 people to death in approximately five months. The Supreme Court has very clear rules about how death sentences must be imposed. Less than 4% of trial court death sentences since 2022 follow those rules. This is not a small procedural problem. It is a constitutional crisis hiding in courtrooms.
A death sentence is the most irreversible act a court can perform. It ends a life. Once carried out, no appellate judgment can undo it. For this reason, the Supreme Court of India has built, over decades, a careful architecture of procedural safeguards — specific requirements that a court must satisfy before it condemns a person to death. These are not suggestions. They are binding law.
Between approximately February and July 2026, the Additional District and Sessions Judge (ADJ) in Muzaffarnagar, Uttar Pradesh handed down death sentences to 23 people across nine separate judgments. The sentences were imposed in roughly five months.
Researchers at NALSAR University of Law examined those nine judgments carefully. What they found should concern every person who believes that the law means what it says — regardless of their views on capital punishment.
What the Supreme Court Requires Before a Death Sentence
To understand what went wrong in Muzaffarnagar, you first need to understand what the law requires. Indian law on the death penalty has evolved through a series of landmark Supreme Court judgments that have progressively made the process more rigorous and individualised.
What Is the “Rarest of Rare” Doctrine?
The Legal Standard That Governs Every Death Sentence in India
In 1980, a five-judge bench of the Supreme Court decided the case of Bachan Singh v. State of Punjab. This is the foundational death penalty judgment in Indian law. The court held that the death penalty should be imposed only in the “rarest of rare” cases — meaning it should be exceptional, not routine.
More importantly, the court laid down a two-part test that must be applied every time a court considers imposing death:
1. The nature of the crime — How brutal, heinous, or shocking was the offence? This is the aggravating side of the balance.
2. The circumstances of the accused — Who is this person? What is their background, mental state, social history, possibility of reform? This is the mitigating side.
The court was explicit: a judge cannot impose death just because a crime was horrific. They must also examine the person who committed it and determine whether life imprisonment would be “unquestionably foreclosed” — meaning there is no possibility of reform or redemption. This individualised assessment is not optional. It is constitutionally required.
For decades after Bachan Singh, there was a gap between the law’s requirement and courtroom practice. Mitigation — the investigation of an accused person’s background, mental health, and social circumstances — was often reduced to the judge asking the accused at sentencing whether they had “anything to say.” The accused usually said nothing meaningful. The judge moved on. Bachan Singh’s requirement of individualised assessment became, in practice, a formality.
Manoj v. State of MP (2022): The Game-Changing Judgment
In May 2022, the Supreme Court issued a landmark judgment in Manoj v. State of Madhya Pradesh that tried to fix the gap between the Bachan Singh standard and actual practice. The court laid down a detailed, mandatory procedural framework that every trial court must follow before imposing death.
The Manoj v. State of Madhya Pradesh Framework — What a Court Must Do Before Imposing Death
The Supreme Court held in Manoj v. State of Madhya Pradesh that “meaningful consideration of mitigating circumstances” requires the court to have actual documentary material before it. This means the following reports must be sought and examined:
- Probation officer’s report — assessing the accused’s social background, family circumstances, community context
- Prison authority’s report — on the accused’s conduct and behaviour while in custody
- Psychological and psychiatric assessment — evaluating mental health, any history of trauma, cognitive functioning
- Mitigation report from the defence — a detailed report on the accused’s socio-economic history, childhood, education, employment, relationships, and personal background
The purpose of these reports is to allow the court to genuinely assess: who is this person, what formed them, can they reform, and does the death penalty serve any purpose that life imprisonment would not? Asking the accused “do you have anything to say?” in court does not fulfil this requirement.
What Is Mitigation?
Why a Person’s Background Matters in Sentencing
“Mitigation” in criminal law refers to facts about a person or their circumstances that do not excuse or justify the crime but reduce the severity of the punishment that is appropriate. Mitigating factors might include: a history of abuse or trauma, extreme poverty, a mental illness, youth, lack of prior criminal history, remorse, or evidence of strong possibility of reform.
Mitigation is not about feeling sorry for a murderer. It is about answering the constitutional question: is this person so irredeemably dangerous and so incapable of reform that society is justified in ending their life?
That question cannot be answered by looking only at what the person did. It requires looking at who they are — and that requires investigation, documentation, and evidence. The Manoj v. State of Madhya Pradesh judgment mandated that this investigation must actually happen before any death sentence is pronounced.
Then, in August 2025, the Supreme Court reinforced the Manoj v. State of Madhya Pradesh framework in Vasanta Sampat Dupare v. Union of India. The court held explicitly that imposing a death sentence without following the safeguards mandated in Manoj v. State of Madhya Pradesh would be a violation of the accused’s fundamental rights — not merely a procedural irregularity, but a constitutional violation.
What the Muzaffarnagar Judgments Actually Show
Against this legal background, researchers examined the nine Muzaffarnagar death sentence judgments. Their findings are striking — not because the trial judge ignored Supreme Court precedents, but because he cited them extensively while ignoring what they actually require.
The judgments repeatedly cite the same set of Supreme Court cases — including Bachan Singh — in much the same sequence, often using the same excerpts. The citations are there. The reasoning is not.
When the judgments come to the actual decision — should this person be sentenced to death or to life imprisonment — the reasoning rests almost entirely on the nature and circumstances of the crime. The crimes are described in detail. Their brutality is documented. The offences are characterised as heinous. Death is imposed.
What is absent from the judgments is any indication that the Manoj v. State of Madhya Pradesh framework was followed. There is no evidence that probation reports, prison authority reports, psychological assessments, or mitigation reports were obtained or considered. There is no individualised examination of who the accused persons are — their backgrounds, mental states, histories, or possibilities of reform. The law as laid down by Bachan Singh and reinforced by Manoj was, in the key moment, simply not applied.
The National Picture: Only 4% Compliance
The Muzaffarnagar cases are troubling. The national data is alarming.
The National Compliance Picture — NALSAR Data
- Research period: 2023 to 2025 (after the May 2022 Manoj v. State of Madhya Pradesh judgment)
- Total trial court death sentences analysed: 216 cases
- Cases that complied with Manoj v. State of Madhya Pradesh requirements: 8 cases
- Compliance rate: less than 4%
- Cases not following mandatory Supreme Court procedure: more than 96%
Source: The Square Circle Clinic, NALSAR University of Law
Read that again. After the Supreme Court issued a detailed, specific, mandatory framework for how death sentences must be imposed — a framework it later elevated to the status of a fundamental right requirement — over 96 percent of trial courts that imposed death sentences in the following three years simply did not follow it.
This is not a few judges making isolated errors. This is a near-total systemic failure to implement a binding Supreme Court precedent in the highest-stakes legal context that exists. It raises profound questions about how India’s trial courts understand their relationship to Supreme Court authority.
What Happens to These 23 People Now?
Under Indian law, every death sentence imposed by a trial court must be confirmed by the relevant High Court before it can be carried out. This is called the “confirmation” process. The High Court reviews the case afresh — it examines both the conviction and the sentence independently, and it has the power to uphold, modify, or set aside the death sentence.
What Is Appellate Review of Death Sentences?
Why a Trial Court Death Sentence Is Not the Final Word
In India, a person sentenced to death does not go to the gallows on the basis of the trial court’s verdict alone. The law requires multiple layers of judicial review:
- High Court confirmation: Every death sentence is automatically referred to the High Court for confirmation. The High Court reviews the trial court’s judgment and must independently satisfy itself that the death sentence is warranted.
- Appeal to the Supreme Court: The accused (and the state) can further appeal to the Supreme Court.
- Mercy petition: Even after the Supreme Court, a condemned person can file a mercy petition with the Governor of the State and then the President of India.
This multi-layered process reflects the principle that the irreversibility of death demands an exceptional degree of care at every stage.
Virtually none of the 23 Muzaffarnagar death sentences will ultimately be upheld, precisely because they do not comply with the Manoj v. State of Madhya Pradesh framework. The Allahabad High Court will review them, find the Manoj v. State of Madhya Pradesh requirements unmet, and will be obliged to reject the sentences as constitutionally invalid.
But this will take years. The 23 people condemned in those Muzaffarnagar courtrooms will spend those years under the shadow of a death sentence that was almost certainly going to be overturned from the moment it was imposed. They will wait. Their families will wait. The legal process will grind on.
The Bigger Problem: What These Cases Reveal About the System
The Muzaffarnagar judgments, and the NALSAR data behind them, point to three distinct but interconnected failures.
First: A failure of legal training. If more than 96 percent of death sentence judgments are non-compliant with a four-year-old Supreme Court precedent, something has failed in how that precedent is being communicated to and absorbed by trial courts. The Manoj judgment is not obscure or difficult — it is one of the most discussed Supreme Court rulings of recent years. Trial judges who impose death sentences should know it and apply it. That most apparently do not suggests a systemic gap in judicial training and oversight.
Second: A conflation of crime and criminal. The temptation in severe cases is obvious. A crime has been committed that shocks the conscience. A judge who lets the horror of the crime dominate the sentencing reasoning is, in human terms, understandable. But it is legally wrong. The Bachan Singh standard exists precisely because the severity of a crime is not, by itself, sufficient justification for killing the person who committed it. A judge who sentences on the basis of crime severity alone — however egregious the crime — is not applying the law. They are substituting their moral reaction for it.
Third: A confusion about what judicial independence means. Judicial independence cannot and does not mean judicial freedom from the law. A trial court judge has independence from external political or personal pressure. They do not have independence from binding Supreme Court precedent. The law laid down in Bachan Singh, Manoj, and Dupare is not optional. It is not something a trial judge can decide to weigh against their own philosophy of punishment. It is binding.
It means not the courage to impose a death sentence when a crime is horrible — that, in fact, requires very little courage, because the public and the judge’s own instinct may support it. The real courage is in following the law even when it demands more from you, even when it complicates the obvious response, even when it requires you to look at the person who committed the crime and not just at what they did.
Twenty-three people in Muzaffarnagar are currently under death sentences that were almost certainly imposed in violation of the Constitution. They will probably not be executed. But they will wait, for years, for the appellate process to confirm what the law already says. That is not justice. That is a legal system failing to keep its own house in order.
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INTRODUCTION
Since most of the early scholars, researchers and historians were men, many aspects of society did not find a place in history books. For example, child-birth, menstruation, women’s work, transgenders, households etc. did not find much mention.
[wptelegram-join-channel link=”https://t.me/s/upsctree” text=”Join @upsctree on Telegram”]Rather than building a holistic picture of the past, some select aspects such as polity and the different roles of men became the central focus of history writing. Women were confined to one corner of the chapter where a paragraph or two was devoted to the ‘status and position of women’.
Even the details of these paragraphs were hardly different from each other. This made it look like as if history (and thereby society, polity, economy and all culture) belonged to men while women were only a small static unit to be mentioned separately. Of course, there were some exceptions, but these were however rare. This practice is being corrected now and the roles and presence of women are being read into all parts of historical questions.
SOURCES FOR UNDERSTANDING GENDER HISTORY
Sources are the bases of history writing. From simple pre-historic tools to abstruse texts, everything can be utilized to understand life and roles of women in history. The presence as well as the absence of women from sources needs to be duly noticed, deliberated and argued upon and only then to be theorised upon.
Certain objects being directly related to the lives of women or depicting the ideas of the female principle are of central importance. These include but are not limited to female figurines, art objects, texts attributed to or authored or compiled by women, monuments created by or for women, various objects relating to their lifestyle, objects associated with women on account of their cultural roles and so on.
It has been rightly pointed out by Uma Chakravarti that much of the gender history written in early phase was a ‘partial view from above’. This referred to the utilization of select textual sources and focused only on relational identity of women. There were, however, a few exceptions.
GENDER HISTORIOGRAPHY
Amongst the many narratives propagated to denigrate Indian civilization and culture by the British colonial rulers, the condition of Indian women became a point of central reference. Various social evils that made the life of women miserable were pointed out and efforts were also made to introduce ‘reforms.’ Sati, child-marriages, imposed widowhood, polygamy, dowry, educational and economic inequality, purdah (ghoonghat) and many other practices prevailed during the colonial period that made the life of women difficult and pitiable.
Some practices affected women of higher social and economic households while others led to misery for poorer women. Many social reform movements were started in the 19th century to address these issues and contributions were made by Indian reformers as well as British officials and other Europeans.
Women in India came to be treated as a homogeneous category and over generalisation became the norm. While many communities in India practised widow remarriage and did not practise (much less forced) sati and while some practised divorces or separation, the image of the Indian woman who had been subjugated as woman, wife and widow became a dominant theme in history writing.
Secondly, a western vision was placed over the non-western societies and hence interpretations were far removed from the context. For example, notion of stridhan was equated with dowry and little regard was paid to the provisions regarding its use and ownership by women.
The huge social stigma that came along with the selling of jewellery of the household (one of the main components of stridhan) was paid no attention to. Similarly, penal provisions listed by ancient texts for misappropriation of women’s property were not even looked into.
During the Paleolithic age, hunting and gathering was norm. However much importance was given to Hunting than gathering in all literature of history. Studies, however, show that hunted prey formed only 35% of the diet while gathering fruits and other edible material supplied the major portion. Gathering of food resources was ordinarily done by women. Since gathering was an important activity, more than hunting for game, it could point to significant role playing by women.
The gendered understanding of Harappan civilization is being built upon and various archaeological remains have been studied in this respect. The female figurines, idols of pregnant women, the statue of the ‘dancing girl’, various pieces of jewellery and personal belongings that have been discovered at various sites and offer useful insights on the public and private lives of women and men.
The statue of a girl obtained from Mohanjodaro has been called a ‘dancing girl’ on grounds of familiarity with the institution of devadasis in the later times. Such backward looking explanations are problematic.
There is a wide variety of terracotta female figurines that have been found at different sites right from the pre-Harappan times. Women figures are found suckling a baby, holding utensils, kneading dough, nursing infants, carrying objects like drums, seated figures for board games, with steatopygia (fat deposition on the hips and elsewhere), with floral head-dresses and in many other forms.
Even figurines of pregnant women are quite common. However, most of these have been uncritically associated with fertility, religiosity and reproductive ideas, and have been passed off as representations of the Mother Goddesses. While some of them were votive objects, others are held to be toys or other utilities. The focus on female form has been so stereotypical that women have been seen as associated only with home, hearth, fertility, sexuality and divinity. So much so that sometimes even male figurines in assumed womanly roles were classified as female figurines.
POSITION OF WOMEN IN EARLY INDIA
The first literary tradition in the Indian subcontinent (and the oldest in the world) is that of the Vedic corpus. From the four Samhitas to the Upanishads, we find many interesting references to women in various roles. Some of these women have left their mark on the cultural heritage to this day and are remembered in various ritual and social contexts. Their names, stories, some highly revered hymns, and other interesting facets are mentioned in the Vedic corpus.
The Vedic literature has been classified as Early Vedic and Later Vedic. The Rigvedic society and polity seems to be teeming with life and agro-pastoral economy was enmeshed in close kinship ties. Women as well as men participated in society, economy and polity. Some of the most revered hymns including the gayatri mantra are ascribed to women.
Various natural phenomena are depicted as Goddesses and they are offered prayers. While quantitative analysis highlights the predominance of Indra, Agni, Varuna and other male gods, the power and stature of the goddesses is equally well established.
Women participated in all three Vedic socio-political assemblies viz. Sabha, Samiti and Vidhata. They had access to education and were even engaged in knowledge creation. They could choose to be brahmavadinis with or without matrimony.
Hence, there is no reason to believe that they were only confined to home and hearth. T. S. Rukmani attempts to understand if women had agency in early India. Her work has highlighted many interesting details. The author acknowledges the fact that though the patriarchal set up put women at a loss, there were instances where women found space to exercise their agency.
She points out that though the texts like the Kalpasutras (Srautasutras, Dharmasutras and Grhasutras) revolved around the ideology of Dharma and there was not much space to express alternative ideas, still these works also find some leeway to express ideas reflecting changed conditions.
For example, there is a statement in the Apastamba Dharmasutra that one should follow what women say in the funeral samskaras. Stephanie Jamison believes that in hospitality and exchange relations, women played an important role. She says that the approval of the wife was important in the successful completion of the soma sacrifice. In another study it has been shown that women enjoyed agency in deciding what was given in a sacrifice, bhiksha to a sanyasin. The men had no authority in telling her what to do in these circumstances.
Vedic society was the one which valued marriage immensely. In such contexts, Gender Perspectives if a woman chose not to marry, then it would point to her exercising choice in her decision to go against the grain and remain unmarried.
Mention may be made of Gargi. She was a composer of hymns and has been called a brahmavadini. This term applies to a woman who was a composer of hymns and chose to remain unmarried, devoting herself to the pursuit of learning.
Similarly, in the case of Maitreyi, she consciously opts to be educated in the Upanishadic lore and Yajnavalkya does not dissuade her from exercising her choice.
The statement in the Rigveda that learned daughters should marry learned bridegrooms indicates that women had a say in marriage. Though male offspring is desired, there is a mantra in the Rigveda, recitation of which ensures the birth of a learned daughter.
Altekar refers to the yajnas like seethayagna, rudrayajna etc. that were to be performed exclusively by women. Some of the women were known for their exceptional calibre, for example, from the Rigveda Samhita we find mention of women like Apala, Ghosha, Lopamudra, Gargi, Maitreyi, Shachi, Vishwavara Atri, Sulabha and others.
Women have not only been praised as independent individuals but also with reference to their contributions towards their natal or marital families.
The Later Vedic literature shows the progression towards a State society with a change in the organization of the society and polity. The chief comes to be referred to as bhupati instead of gopati. However, within the twelve important positions (ratnis) mentioned, the chief queen retains a special position under the title mahisi.
The importance of the chief queen continued as gleaned from several references to them in the Epics, Arthashastra and even in coins and epigraphs from early historical times.
The other Samhitas also refer to women sages such as Rishikas. The wife is referred to as sahadharmini. Brahmanas or the texts dealing with the performance of the yajna (Vedic ritual), requires a man to be accompanied by his wife to be able to carry out rituals.
For example, Aitareya Brahmana looks upon the wife as essential to spiritual wholesomeness of the husband. However, there is a mention of some problematic institutions as well.
Uma Chakravarti has pointed towards the condition of Vedic Dasis (female servant/slave) who are referred to in numerous instances. They were the objects of dana (donation/gift) and dakshina (fee).
It is generally believed that from the post Vedic period the condition of the women steadily deteriorated. However, Panini’s Ashtadhyayi and subsequent grammatical literature speak highly of women acharyas and Upadhyayas.
Thus, the memory and practice of a brahmavadini continued even after the Vedic period. The Ramayana, Mahabharata and even the Puranas keep the memory of brhamavadini alive.
Mention may be made of Anasuya, Kunti, Damyanti, Draupadi, Gandhari, Rukmini who continued to fire the imagination of the poets. Texts show that the daughter of Kuni-garga refused marriage because she did not find anyone worthy of her.
The Epics also mention women whose opinions were sought in major events. For example, after the thirteen years of exile, while debating upon the future course of action regarding the restoration of their share, the Pandavas along with Krshna asks Draupadi for her views. Similarly, when Krishna goes to the Kaurava’s court to plead the case of Pandavas, Gandhari is called upon to persuade her sons to listen to reason.
Since a woman taking sanyasa was an act of transgression, one can explore women’s agency through such instances. In the Ramayana, Sabari, who was the disciple of Sage Matanga, and whose hermitage was on the banks of river Pampa was one such sanyasin.
Such women find mention in Smriti literature and Arthashashtra. Kautilya’s prohibition against initiating women into Sanyasa can make sense only if women were being initiated into sanyasa. He advises the king to employ female parivrajakas as spies.
Megasthenes mentions women who accompanied their husbands to the forest, probably referring to the Vanaprastha stage. Another category of literature called Shastras that comprises of sutras (aphorisms) and the smriti texts (‘that which is remembered’) becomes important in the postVedic period.
These textual traditions cover many subjects relating to the four kinds of pursuits of life referred to as purusharthas (namely dharma, karma, kama and moksha). In all these texts we find very liberal values and freedom for both women and men.
The setting up of a household is seen as an ideal for men as well as women (though asceticism for learning is equally praised for both). For example, Apastambha Sutra opines that rituals carried out by an unmarried man do not please the devatas (divinities). Similarly, Manusmriti provides that ‘for three years shall a girl wait after the onset of her puberty; after that time, she may find for herself a husband of equal status. If a woman who has not been given in marriage finds a husband on her own, she does not incur any sin, and neither does the man she finds’
Thus, we see that women enjoyed choice in matters of matrimony. It is interesting to note that unmarried daughters were to be provided for by the father. In fact, daughter is stated to be the object of utmost affection. Should a girl lose her parents, her economic interests were well looked after. It was provided that from their shares, ‘the brothers shall give individually to the unmarried girls, one-quarter from the share of each. Those unwilling to give will become outcastes’
With regards to defining contemporary attitude towards women, Apastambha Sutra prescribed that ‘All must make a way for a woman when she is treading a path.’ Later Dharmashastra also makes similar statements.
Yagnavalkyasmriti mentions that ‘women are the embodiment of all divine virtues on earth.’ However, there are several provisions that look problematic.
On one hand, we have reverence assigned to the feminine (divine and worldly) and important roles being played by them, on the other hand we have questionable provisions and descriptions like right to chastise them through beating or discarding.
The post-Vedic phase from 6th century BCE onwards is also rich in literary traditions with ample depictions of women. Interestingly, we have an entire body of literature that is ascribed totally to women who became Buddhist nuns. These are referred to as Therigathas i.e. the Songs of the Elder Bhikkhunis (Buddhist Women who joined the Sangha).
The Arthashastra Gender Perspectives gives us information on women who were engaged in economic activities of various kinds. They formed a part of both the skilled and the unskilled workforce. They were into professional as well as non-professional employment.
Some of their vocations were related to their gender, while the others were not. There were female state employees as well as independent working women. Similarly, some of them were engaged in activities which though not dependent on their biological constitution are nonetheless categorized as women’s domain, e.g. domestic services etc. Some of them were actual state employees, while some others were in contractual relations with the State. For example, we have female bodyguards and spies in the State employment.
Jaiswal suggests that these women perhaps came from Bhila or Kirata tribe. Female spies were not only to gather information and relay it to proper source, but also to carry out assassinations. However, a closer look at the text shows that there were different classes of female spies engaged for different purposes. Amongst others ‘women skilled in arts were to be employed as spies living inside their houses’. Others were required to work as assassins. Some were to the play the roles of young and beautiful widows to tempt the lust of greedy enemy.
We also have various Buddhist and Jaina traditions giving us some glimpses of the ideas and institutions of the times. Apart from the orthodox (Vedic and Brahmanic) and heterodox normative tradition we have many popular texts like the Epics in Sanskrit and Jatakas in Pali.
Even Prakrit language has many interesting narratives and poetic texts. The Therigatha by the Buddhist nuns are an interesting literary source that provides us with a glimpse of various women who attained arhantship or similar other stages of Realisation.
The deliberation on the age and deterioration of the body by Ambapali, the non-importance of sensual or bodily pleasures by Nanda, Vimla and Shubha etc points towards the intellectual and spiritual engagements and attainments of women.
It is interesting to note that an absolutely contrary picture is presented by the Jatakas wherein more often than not, women are depicted as evil. It is important to note that women were given an evil aura mostly in their roles as wives or beloveds.
Both the texts and the archaeological remains have been studied by various scholars and opposing interpretations are not rare. For example, on one side Sita (from Ramayana) and Draupadi (from Mahabharata) have been seen as victims of the patriarchal order; on the other hand, they are also represented as selfwilled women.
Draupadi after the game of dice presents herself as a forceful and articulate woman. It’s her wit that saves her husbands from becoming slaves of the Kauravas. Her incensed outrage at the attack on her modesty, her bitter lamentations to Krishna, her furious tirade against Yudhishthira for his seeming inability to defend her honour and many more such instances show her to be an aggressive woman. This persona is juxtaposed to her representations as an ideal wife elsewhere. However, Draupadi is never idealised as a perfect wife who endures the most severe trials without complaint. This honour is reserved for Sita in the Ramayana. She is also presented as a victim like Draupadi and voices her concern at her fate openly. However, her aggression is directed inwards as indicated by her action against the self which culminate in her union with the mother Earth.
Are the limited number of hymns ascribed to the Vedic women a signifier of their general status? Are the goddesses merely representational with no connection to the ideas and behaviour towards women? Did only princesses choose their spouses? Are the warrior women an exception? Such searching questions need to be addressed with due diligence.
While women studies are a good development there is a need to expand the horizons to include other varieties of human existence. We have narratives of fluid sexuality in various texts. The one year of Arjuna’s life spent as Brihallana and rebirth of Amba as Shikhandi are some interesting instances. The artefacts found at the site of Sheri Khan Tarakai include visibly hermaphroditic figurines. There is a need to understand the notions of the feminine, masculine, neuter, and other forms of gender and sexual identities. These will have ramifications for understanding the ideas of conjugality, family, community, society and even polity and spirituality.
CONCLUSION
Human civilisations were built by men as well as women, however, history writing has a huge male-bias. Women were confined to questions of status and position that were largely evaluated in terms of their roles in the domestic sphere.
Their treatment as wives and widows became a central focus of most research alongside their place in ritual or religious context. This made them peripheral to mainstream history. This was questioned by various scholars from time to time and led to the development of gendered understanding of history. Focusing attention on women’s history helps to rectify the method which sees women as a monolithic homogeneous category. Writing gender history has helped in building an image of the past that is wholesome and nuanced.