“This report does not critique religion or its festivals. It examines whether public religious mobilisations are being used to spread exclusionary rhetoric and whether authorities are responding.”

Background: Sanatan Hindu Ekta Padyatra

Launched by prominent right-wing Hindutva leaders, the Sanatan Ekta Padyatra is being promoted as a socio-spiritual movement. Led by Dhirendra Krishna Shastri of Bageshwar Dham, the yatra was flagged off from Delhi with the stated objectives of establishing a Hindu nation, eradicating casteism, and fostering social unity. Scheduled from November 7 to 16, it passed through 422 village panchayats across Delhi, Haryana, and Uttar Pradesh.

As part of the campaign, seven resolutions were announced, like promoting social harmony and supporting the “grand construction” of the Shri Janmabhoomi temple. The controversy primarily stems from the first and central resolution: the demand to declare India a Hindu Rashtra. This directly conflicts with the Constitution’s commitment to a secular state and violates the guarantees of freedom of religion under Article 25 as well as equality and non-discrimination under Articles 14 and 15.

However, the publicly stated resolutions tell only part of the story. Across multiple stops in Delhi, Haryana, Uttar Pradesh, and Madhya Pradesh, several speakers, including the Padyatra’s principal organisers, delivered inflammatory speeches that went far beyond calls for spiritual unity or social harmony. These speeches invoked communal conspiracy theories (“love jihad,” “land jihad”), portrayed Muslims as demographic threats, justified vigilante violence, and openly advocated for religious segregation and economic boycotts. Many of these statements raise serious concerns under the Bharatiya Nyaya Sanhita (BNS), the Bharatiya Nagarik Suraksha Sanhita (BNSS), and established Supreme Court jurisprudence on hate speech and incitement. 

Details of the Hate Speech Delivered

Below is a consolidated analysis of the most objectionable statements made during the Sanatan Hindu Ekta Padyatra, grouped under 3 main themes and mapped against the relevant legal frameworks.
The reference links of the speeches, with timestamps mentioned, are given below-

Ghaziabad, Nov 3

Palwal, Nov 10

Palwal, Nov 12

Chhatarpur, Nov 14

Faridabad, Nov 8

Banchari, Nov 12

Mathura, Nov 15

Palwal, Haryana, Nov 10

Banchari, Nov 12

A.  Direct Hate Speech (Violence, Hostility, Social Boycott)

(Statements advocating violence, hostility, coercion, or social/economic boycott; calls for expulsion; explicit majoritarian supremacy)

Across multiple stops of the Sanatan Hindu Ekta Padyatra, speakers issued direct calls that clearly cross the constitutional threshold into incitement as interpreted in Amish Devgan and Shreya Singhal. In Ghaziabad (Nov 3), the speaker declared that India “should become a Hindu Rashtra” (0:39–0:42) and added that population decline “should happen to those who follow the ‘chadar’ and the ‘father’,” (1:17–1:20) a statement which the Supreme Court would classify as high-intensity dehumanising hate speech. Similarly, in Palwal (Nov 10), a public oath was taken to ensure that “love jihad and aaved dharmantaran will not be allowed” (0:20–0:27), effectively encouraging vigilantism against interfaith couples and converts. Under Patricia Mukhim, such statements, though framed as “protection,” amount to direct incitement toward unlawful acts.

In Delhi (Nov 7), hostility was escalated through demographic-war rhetoric: “tumhari sampatti tumhari hogi, kabza unka hoga” (2:30–2:44), and by invoking civilisational conflict through “ye desh Babar ka nahi, Raghuvar ka hai” (2:58–3:02). The Court in Amish Devgan specifically flagged the use of derogatory historical figures to mobilise hatred in the present. In Faridabad (Nov 10), a speaker warned: “jab desh lutega… tumhari beti love jihad mei pad jayegi… tumhara beta jis din shukravar ko jaane lagega,” (2:34–2:56) creating a direct incentive to treat Muslim men as targets of suspicion and implying moral justifications for coercive action.

Following the Delhi car blast, Dhirendra Shastri, addressing Palwal (Nov 12), asked: “yehi (Muslims) kyu aatangwadi hote hain?” (0:27–0:39), treating the entire community as terrorists. He further warned that unless Hindus united, bomb blasts like Delhi would occur “in every gali” (0:57–1:26), which satisfies the proximity test under Shreya Singhal. In Chhatarpur, MP (Nov 14), dissenters to Hindu symbols were told to “get their ticket to Lahore” (0:00–0:13), echoing classic expulsion rhetoric the Court has treated as unprotected. The chant recorded in Faridabad (Nov 8) — “tel lagao Dabur ka, naam mita do Babur ka; jo Ram ka nahi wo kisi kaam ka nahi” — directly targets Muslims through symbolic eradication. In Banchari, Palwal (Nov 12), speakers vowed to conduct compulsory “ghar wapsi” for those who had “left Sanatan” (0:29–0:46), amounting to a call for coercive reconversion, contrary to Shafin Jahan (Hadiya), which protects decisional autonomy in matters of faith.

Finally, in Mathura (Nov 15), spiritual leader Devkinandan Thakur invoked the Babri Masjid demolition (“4:20–4:50”) while urging the crowd to “move toward Mathura and Vrindavan,” hinting at mobilisation to claim the Shahi Idgah Mosque. The Supreme Court in the Ayodhya judgment warned that religious disputes must not be weaponised for incitement. These statements collectively amount to direct hate speech under Indian constitutional and criminal jurisprudence.

B. Discriminatory / Exclusionary “Othering”

(Normalising prejudice, othering minorities, delegitimising citizenship, religious tests for belonging)

Several speeches sought to redefine citizenship and community belonging in expressly exclusionary terms. In Ghaziabad (Nov 3), the speaker framed Hindu women as victims of Muslim men by warning that “our daughters fall into love jihad” (0:44–1:01), establishing a stereotype that casts Muslim men as predatory. He also suggested that Hindus “are not extremist,” implying that extremism is inherent to other communities (1:32–1:39). Such rhetorical othering aligns with what Patricia Mukhim describes as hate speech that delegitimises equal citizenship.

In Delhi (Nov 7), converts were described as outsiders: “Hindu issai mei converted hota hai toh ‘sister’ aur ‘sir’ kehlata hai… Hindu Musalman mei converted hota hai toh ‘bhai-jaan, amma-jaan’ kehlata hai,” followed by a suggestion that Hindus should first identify only as “Hindu” before any caste label (1:47–2:22). This constructs religious identity as the sole marker of national legitimacy. In Haryana (Nov 10), the crowd was asked if they want to see their children “wearing topi” or “going to church on Sunday” (0:04–0:25), depicting basic religious expression by minorities as inherently undesirable. The line “jab topi walo ki ekta ho sakti, toh tilak walo ki kyu nahi” (0:30–0:37) frames religious groups as competing blocs, contradicting the constitutional ideal of fraternity.

Kajal Hindusthani, in Palwal (Nov 10), urged the crowd to “be Hindus, buy from Hindus, employ only Hindus” (0:20–0:33), an explicit economic boycott. Section 196 of BNS emphasises that no citizen can be coerced into religious conformity; here, exclusion is extended to everyday economic life. In Chhatarpur (Nov 14), slogans like “jo Ram ka nahi, wo kisi kaam ka nahi” (0:24–0:33) reduce non-Hindus to second-class status. The DNA-testing analogy used to delegitimise dissenter’s mirrors what Amish Devgan classifies as dehumanising metaphors, which have no constitutional protection. In Banchari (Nov 12), Nagendra Maharaj’s line— “those who object to Vande Mataram or Ram should go to Pakistan or Afghanistan” (0:33–0:41)—constructs a religious test for belonging, contrary to the secular character upheld repeatedly by the Supreme Court.

Such statements normalise hostility and social exclusion, and the Court in Pravasi Bhalai Sangathan explicitly warned that such majoritarian narratives fuel discrimination and justify vigilantism, attracting Sections 196 (Promoting enmity between different groups), Section 197 (assertions prejudicial to national integration), and Section 299 (Deliberate acts, intended to outrage religious feelings).

C. Fearmongering & Demographic Conspiracy Claims

(Alarmist misinformation about population, survival, territorial takeover; invoking existential threat narratives)

A consistent theme throughout the padyatra was the portrayal of Hindus as being on the verge of demographic extinction. In Ghaziabad (Nov 3), the speaker claimed that Hindus are “khatam ho rahe hai” despite India’s overwhelming Hindu majority, and that once “Hindus do not unite, they will not be safe” (1:55–2:06). He also asserted that Hindus are declining “day by day” (1:04–1:16), ignoring census realities. This comes under spreading demographic conspiracy narratives constitutes incitement because it fosters suspicion and hostility against minorities.

In Delhi (Nov 7), the crowd was told that “20 saal baad, Bharat ka Hindu apne astitva ki ladai lad raha hoga” (0:38–), and that minorities would seize Hindu property: “sampatti tumhari hogi, kabza unka hoga” (2:30–2:44). Such claims resemble classic “replacement” conspiracy theories. When combined with militaristic lines like “na toh pad rehna hai, na kad rehna hai” (0:55–0:58), the rhetoric urges mobilisation against an imagined security threat. In Haryana (Nov 10), Partition was invoked (“Jinnah ki leadership mein… alag Pakistan bana”), followed by an analogy that if “Sanatan Dharma ke naam par” India does not become a Hindu Rashtra, it will face a “Bangladesh-like situation” where “haq kisi aur ka hoga” (1:53–2:06). The Supreme Court in Pravasi Bhalai explicitly noted that selective historical parallels are often used to trigger fear and justify majoritarian aggression.

After the Delhi blast, Dhirendra Shastri claimed that unless Hindus unite, “aisa har gali mein hoga” (0:57–1:26), and asserted that the arrested individual— “doctor, musalman… crore-o ki jaan lene ki tayaari”—was preparing mass murder, furthering the narrative that Muslims pose a blanket existential threat. Fear of demographic loss was also invoked repeatedly: in Delhi (Nov 7), the claim that Hindus have become minorities in “9 states” is factually incorrect yet presented as imminent collapse. In Banchari (Nov 12), Nagendra Maharaj warned that Hindus could be “expelled from their homes like Srinagar,” framing political developments as religious persecution.

Such narratives fall squarely within the Supreme Court’s treatment of misinformation that has a proximate connection to public disorder (Shreya Singhal). Fearmongering of this kind shifts the public mindset from coexistence to hostility, creating conditions for violence without issuing explicit violent commands.

Legal Framework

India’s constitutional and statutory framework places clear limits on speech that promotes enmity, incites violence, or undermines the country’s secular structure. Several statements delivered during the Sanatan Ekta Padyatra appear to contravene these provisions.

Constitutional Provisions

Various provisions of the Indian Constitution safeguard against hate speech and communal othering.

1. Article 14 — Equality before law

Communal othering, demographic fear-mongering, and calls for exclusion (“be Hindus, buy only from Hindus”) violate the constitutional guarantee of equal protection to all communities.

2. Article 15 — Non-discrimination on grounds of religion

Calls for a ‘Hindu Rashtra’, alongside statements urging economic segregation, employment discrimination, or “ghar wapsi” of all converts, contradict the constitutional prohibition against discrimination on religious grounds.

3. Article 19(1)(a) & 19(2) — Freedom of speech and its reasonable restrictions

Speech that threatens public order, incites violence, or promotes communal disharmony falls squarely within the restrictions permitted under Article 19(2).
The Supreme Court has repeatedly held that advocacy crossing into incitement is not protected speech.

4. Article 25 — Freedom of religion

Sections of the BNS

1. Section 196 of BNS: Promoting enmity between different groups on grounds of religion, race, place of birth, residence, language, etc., and doing acts prejudicial to maintenance of harmony

(1) Whoever—

• by words, either spoken or written, or by signs or by visible representations or through electronic communication or otherwise, promotes or attempts to promote, on grounds of religion, race, place of birth, residence, language, caste or community or any other ground whatsoever, disharmony or feelings of enmity, hatred or ill-will between different religious, racial, language or regional groups or castes or communities; or Liability of owner, occupier, etc., of land on which an unlawful assembly or riot takes place. Affray. Assaulting or obstructing a public servant when suppressing a riot, etc.
  (b) commits any act which is prejudicial to the maintenance of harmony between different religious, racial, language or regional groups or castes or communities, and which disturbs or is likely to disturb the public tranquillity;

2. Section 197 of BNS: Imputations, assertions prejudicial to national integration.

(1) Whoever, by words either spoken or written or by signs or by visible representations or through electronic communication or otherwise, —

(a) makes or publishes any imputation that any class of persons cannot, by reason of their being members of any religious, racial, language or regional group or caste or community, bear true faith and allegiance to the Constitution of India as by law established or uphold the sovereignty and integrity of India; or

(c) makes or publishes any assertion, counsel, plea or appeal concerning the obligation of any class of persons, by reason of their being members of any religious, racial, language or regional group or caste or community, and such assertion, counsel, plea or appeal causes or is likely to cause disharmony or feelings of enmity or hatred or ill-will between such members and other persons; or

3. Section 299: Deliberate and malicious acts, intended to outrage religious feelings of any class by insulting its religion or religious beliefs. 

Whoever, with deliberate and malicious intention of outraging the religious feelings of any class of citizens of India, by words, either spoken or written, or by signs or by visible representations or through electronic means or otherwise, insults or attempts to insult the religion or the religious beliefs of that class, shall be punished with imprisonment of either description for a term which may extend to three years, or with fine, or with both.

4. Section 352: Intentional insult with intent to provoke breach of peace.

 Whoever intentionally insults in any manner, and thereby gives provocation to any person, intending or knowing it to be likely that such provocation will cause him to break the public peace, or to commit any other offence, shall be punished with imprisonment of either description for a term which may extend to two years, or with fine, or with both.

5. Section 353: Statements conducing to public mischief.

 (1) Whoever makes, publishes or circulates any statement, false information, rumour, or report, including through electronic means—

(b) with intent to cause, or which is likely to cause, fear or alarm to the public, or to any section of the public whereby any person may be induced to commit an offence against the State or against the public tranquillity; or

(c) with intent to incite, or which is likely to incite, any class or community of persons to commit any offence against any other class or community, shall be punished with imprisonment which may extend to three years, or with fine, or with both.

Judicial Precedents

Indian constitutional jurisprudence has consistently sought to balance freedom of expression with the imperative of preserving public order, equality, and the secular fabric of the nation. While there is no universally accepted definition of ‘hate speech’, the Supreme Court has laid down clear principles that define when speech crosses the boundary from protected expression into unlawful incitement or communal hatred.

The foundational judgment in Kedar Nath Singh v. State of Bihar (1962) affirmed that criminal provisions affecting speech must be interpreted narrowly. The statute is constitutionally valid only to the extent it punishes speech that has the intention or tendency to create disorder or incitement to violence or disturbance of law and order.

The Padyatra speeches, alleging demographic conquest, “love jihad,” and calling for social boycotts and vigilante resistance, demonstrate a direct intention to cause disharmony between religious groups travelling through communally sensitive regions of Delhi, Haryana, and Uttar Pradesh. The route’s culmination at Banke Bihari Temple, Vrindavan, a site recently embroiled in controversy, heightens the imminent potential for communal mobilisation.

A decade later, Kesavananda Bharati v. Union of India (1973) reaffirmed the inviolable constitutional commitment to secularism, equality, and fundamental rights by introducing the Basic Structure doctrine. Through this, the Court held that any attempt, legislative or otherwise, that undermines the secular character of the Republic would be unconstitutional at its core. This principle shapes the broader legal environment within which communal speech is assessed.

On debates around ‘love jihad’ and ‘illegal conversion’, the Supreme Court in the Hadiya Marriage Case (2018), held that the right to marry a person of one’s choice is integral to Article 21, and the choice of a partner lies within the exclusive domain of an individual, and is a part of the core zone of privacy, which is inviolable.

The modern understanding of hate speech was articulated in Pravasi Bhalai Sangathan v. Union of India (2014), where the Supreme Court held that

Hate speech is an effort to marginalise individuals based on their membership in a group. Using expression that exposes the group to hatred, hate speech seeks to delegitimize group members in the eyes of the majority, reducing their social standing and acceptance within society. Hate speech, therefore, rises beyond causing distress to individual group members. It can have a societal impact.

Responding to this mandate, the Law Commission’s 267th Report proposed a structured framework for understanding hate speech. Para 5.2 laid down the criteria for identifying hate speech:

(i) The extremity of the speech

(ii) Incitement

(iii) Status of the author of the speech

(iv) Status of victims of the speech

(v) Potentiality of the speech

(vi) Context of the Speech

The Court’s earlier ruling in Shreya Singhal v. Union of India (2015) further clarified that only speech amounting to “incitement to imminent lawless action” can be legitimately restricted under Article 19(2), reinforcing the centrality of context, intent, and likely consequences.

In Patricia vs State of Meghalaya (2021), the Supreme Court quashed a FIR against a journalist, concluding that the post was a genuine plea for justice and equality rather than an attempt to promote hatred or communal discord. In Amish Devgan v. Union of India (2020), the court further stated that: the mode of exercise of free speech, the context and the extent of abuse of freedom are important in determining the contours of permissible restrictions.

Aftermath of Padyatra

The Sanatan Ekta Padyatra triggered immediate political and social pushback across several states. The Azaad Samaj Party (ASP) condemned the march on constitutional grounds, arguing that India’s identity as a secular republic cannot be undermined by a public movement openly calling for a “Hindu Rashtra.” ASP formally petitioned the President to halt the yatra, while the Dalit Pichda Samaj Sanathan (DPSS) joined ASP in filing a PIL before the Supreme Court seeking a complete stop to the march and a ban on its “inflammatory” speeches. In response, Gwalior-based politician Damodar Singh Yadav announced a counter-mobilisation titled the Samvidhan Bachao Yatra, set to begin on November 16, framing it as a defence of constitutional values.

On the ground, several areas witnessed unrest directly linked to the padyatra. Samagra Bharat reported that on 9 November in Indergarh (Datia district, MP), residents gathered at Ambedkar Park and attempted to burn an effigy of Dhirendra Shastri, alleging that his speeches promoted caste humiliation and communal hatred. Members of the Hindu Sangathan retaliated with stone-pelting, leading to a police lathi-charge when tensions escalated. Locals later filed an FIR against Shastri, but authorities have taken no concrete action. A week later, on 17 November, Patrika reported a scuffle at Vrindavan’s Banke Bihari Temple during Shastri’s visit, where a confrontation between temple priests and the police resulted in torn garments and allegations that the padyatra’s politicised presence compromised the sanctity and security of the temple premises.

Broader Pattern of Impunity towards Hate Speeches

The fallout from the padyatra reflects a broader pattern in which communal mobilisation and hate speech by far-right Hindutva leaders are met with minimal institutional response. India has witnessed repeated episodes of religiously charged violence—such as the 2019 lynching of Tabrez Ansari in Jharkhand, where the victim was forced to chant “Jai Shri Ram”—and mass events like the 2024 Ayodhya Ram Mandir consecration have increasingly become sites for majoritarian mobilisation. Despite this backdrop, police responses remain inconsistent, especially when politically influential individuals are involved. NDTV reports that although five FIRs were filed over two years against BJP legislator T. Raja Singh for comments such as “The Old City of Hyderabad is a mmini-Pakistan” two were closed, and the remaining three have seen no decisive progress.

Legal scrutiny has extended to Baba Dhirendra Shastri as well, with multiple complaints for delivering hate speeches in Udaipur, Maharashtra, and Madhya Pradesh. In 2023, a PIL before the Gujarat High Court sought enforcement of the Supreme Court’s Tehseen Poonawalla guidelines—requiring preventive intelligence units, immediate action against hate speech, and punitive steps against officials who fail to curb mob violence—but the petition was declined. This pattern of judicial reluctance, combined with police inaction, underscores a systemic tolerance toward inflammatory communal rhetoric, even when it directly violates constitutional guarantees and statutory prohibitions under the BNS. The result is a public environment where speeches like those delivered during the Sanatan Ekta Padyatra, openly calling for a Hindu Rashtra and targeting minority communities, continue largely unchecked, emboldening majoritarian mobilisation while eroding constitutional safeguards.

(The legal research team of CJP consists of lawyers and interns; this has been worked on by Shyamli Pengoriya)

Related:

Targeted as ‘Bangladeshis’: The hate speech fuelling deportations

India Hate Lab Report 2024: Unveiling the rise of hate speech and communal rhetoric

2024: CJP’s battle against communal rallies before and after they unfold

Exclusion at the Gate: Navratri becomes the new front for communal politics

Hate Has No Place in Elections: CJP moves State EC against BJP MP Ashwini Choubey’s communal speech

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