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Religious persecution is the systematic mistreatment of an individual or group of individuals as a response to their religious beliefs or affiliations or lack thereof.
The tendency of societies or groups within society to alienate or repress different subcultures is a recurrent theme in human history. Moreover, because a person's religion often determines to a significant extent his or her morality, worldview, self-image, attitudes towards others, and overall personal identity, religious differences can be significant cultural, personal, and social factors.
Religious persecution may be triggered by religious bigotry (i.e. members of a dominant group denigrating religions other than their own) or by the state when it views a particular religious group as a threat to its interests or security. At a societal level, this dehumanisation of a particular religious group may readily turn into violence or other forms of persecution. Indeed, in many countries, religious persecution has resulted in so much violence that it is considered a human rights problem.
Religious persecution is defined as violence or discrimination against religious minorities, actions intending to deprive political rights and force minorities to assimilate, leave, or live as second-class citizen. In the aspect of state policy, it may be defined as violations on freedom of thought, conscience and belief spread by systematic and active state policy and actions of harassment, intimidation and punishment that infringes or threatens the right to life, integrity or liberty. The distinction with religious intolerance is that the latter in most cases is in the sentiment of the population, which may be tolerated or encouraged by the state. Denial of civil rights on the basis of religion is most often described as religious discrimination, rather than religious persecution.
Examples of persecution is confiscation or destruction of property, incitement to hate, arrest, imprisonment, beatings, torture, murder, and execution. Religious persecution can be considered the opposite of freedom of religion.
Bateman has differentiated different degrees of persecution. "It must be personally costly... It must be unjust and undeserved... it must be a direct result of one's faith."
Religious cleansing is a term sometimes used to refer to removal of a population from a certain territory based on its religion. Throughout antiquity, population cleansing was largely motivated by economic and political factors, although ethnic factors occasionally played a role. During the Middle Ages, population cleansing took on a largely religious character. The religious motivation lost much of its salience early in the modern era, although until the 18th century ethnic enmity in Europe remained couched in religious terms. Richard Dawkins has argued that the references to ethnic cleansing in the former Yugoslavia and Iraq is a euphemism for what should more accurately be called religious cleansing. According to Adrian Koopman, the widespread use of the term ethnic cleansing in such cases suggests that in many situations there is confusion between ethnicity and religion.
Other acts of violence, such as war, torture, and ethnic cleansing not aimed at religion in particular, may nevertheless take on the qualities of religious persecution when one or more of the parties involved are characterized by religious homogeneity; an example being when conflicting populations that belong to different ethnic groups often also belong to different religions or denominations. The difference between religious and ethnic identity might sometimes be obscure (see Ethnoreligious); cases of genocide in the 20th century cannot be explained in full by citing religious differences. Still, cases such as the Greek genocide, the Armenian Genocide, and the Assyrian Genocide are sometimes seen as religious persecution and blur the lines between ethnic and religious violence.
Since the Early modern period, there were increased religious cleansing entwined with ethnic elements. As religion is an important or central marker in ethnic identity, some conflicts can be described as "ethno-religious conflicts".
Nazi antisemitism provides another example of the contentious divide between ethnic and religious persecution, because Nazi propaganda tended to construct its image of Jews as race, and de-emphasized Jews as being defined by their religion. The Holocaust made no distinction between secular Jews, atheistic Jews, orthodox Jews and Jews that had converted to Christianity. The Nazis also persecuted the Catholic Church in Germany and Poland.
The descriptive use of the term religious persecution is rather difficult. Religious persecution has taken place at least since antiquity, and has happened in different historical, geographical and social contexts. Until the 18th century, some groups were nearly universally persecuted for their views about religion, such as atheists, Jews and zoroastrians.
One period of religious persecution which has been studied extensively is early modern England, since the rejection of religious persecution, now common in the Western world, originated there. The English 'Call for Toleration' was the turning point in the Christian debate on persecution and toleration, and early modern England stands out to the historians as a time in which literally "hundreds of books and tracts were published either for or against religious toleration."
The most ambitious chronicle of that time is W.K.Jordan's magnum opus The Development of Religious Toleration in England, 1558-1660 (four volumes, published 1932-1940). Jordan wrote as the threat of fascism rose in Europe, and this work is seen as a defense of the fragile values of humanism and tolerance. More recent introductions to this period are Persecution and Toleration in Protestant England, 1558–1689 (2000) by John Coffey and Charitable hatred. Tolerance and intolerance in England, 1500-1700 (2006) by Alexandra Walsham. To understand why religious persecution has occurred, historians like Coffey "pay close attention to what the persecutors said they were doing."
No religion is free from internal dissent, although the degree of dissent that is tolerated within a particular religious organization can strongly vary. This degree of diversity tolerated within a particular church is described as ecclesiastical tolerance, and is one form of religious toleration. However, when people nowadays speak of religious tolerance, they most often mean civil tolerance, which refers to the degree of religious diversity that is tolerated within the state.
In the absence of civil toleration, someone who finds himself in disagreement with his congregation doesn't have the option to leave and chose a different faith - simply because there is only one recognized faith in the country (at least officially). In modern western civil law any citizen may join and leave a religious organization at will; In western societies, this is taken for granted, but actually, this legal separation of Church and State only started to emerge a few centuries ago.
In the Christian debate on persecution and toleration, the notion of civil tolerance allowed Christian theologians to reconcile Jesus' commandment to love one's enemies with other parts of the New Testament that are rather strict regarding dissent within the church. Before that, theologians like Joseph Hall had reasoned from the ecclesiastical intolerance of the early Christian church in the New Testament to the civil intolerance of the Christian state.
By contrast to the notion of civil tolerance, in early modern Europe the subjects were required to attend the state church; This attitude can be described as territoriality or religious uniformity, and its underlying assumption is brought to a point by a statement of the Anglican theologian Richard Hooker: "There is not any man of the Church of England but the same man is also a member of the [English] commonwealth; nor any man a member of the commonwealth, which is not also of the Church of England."
Before a vigorous debate about religious persecution took place in England (starting in the 1640s), for centuries in Europe, religion had been tied to territory. In England there had been several Acts of Uniformity; in continental Europe the Latin phrase "cuius regio, eius religio" had been coined in the 16th century and applied as a fundament for the Peace of Augsburg (1555). It was pushed to the extreme by absolutist regimes, particularly by the French kings Louis XIV and his successors. It was under their rule that Catholicism became the sole compulsory allowed religion in France and that the huguenots had to massively leave the country. Persecution meant that the state was committed to secure religious uniformity by coercive measures, as eminently obvious in a statement of Roger L'Estrange: "That which you call persecution, I translate Uniformity".
However, in the 17th century writers like Pierre Bayle, John Locke, Richard Overton and Roger William broke the link between territory and faith, which eventually resulted in a shift from territoriality to religious voluntarism. It was Locke who, in his Letter Concerning Toleration, defined the state in purely secular terms: "The commonwealth seems to me to be a society of men constituted only for the procuring, preserving, and advancing their own civil interests." Concerning the church, he went on: "A church, then, I take to be a voluntary society of men, joining themselves together of their own accord." With this treatise, John Locke laid one of the most important intellectual foundations of the separation of church and state, which ultimately led to the secular state.
The persecution of beliefs that are deemed schismatic is one thing; the persecution of beliefs that are deemed heretic or blasphemous is another. Although a public disagreement on secondary matters might be serious enough, it has often only led to religious discrimination. A public renouncement of core elements of a religious doctrine under the same circumstances, on the other hand, would have put one far greater danger. While a dissenter from its official Church was only faced with fines and imprisonment in Protestant England, six people were executed for heresy or blasphemy during the reign of Elizabeth I, and two more in 1612 under James I.
Similarly, heretical sects like Cathars, Waldensians and Lollards were brutally suppressed in western Europe, while, at the same time, Catholic Christians lived side-by-side with 'schismatic' Orthodox Christians after the East-West Schism in the borderland of eastern Europe.
The Bishop of Vladimir Feodor turned some people into slaves, others were locked in prison, cut their heads, burnt eyes, cut tongues or crucified on walls. Some heretics were executed by burning them alive. According to an inscription of Khan Mengual-Temir, Metropolitan Kiril was granted the right to heavily punish with death for blasphemy against the Orthodox Church or breach of ecclesiastical privileges. He advised all means of destruction to be used against heretics, but without bloodshed, in the name of 'saving souls'. Heretics were drowned. Novgorod Bishop Gennady Gonzov turned to Tsar Ivan III requesting the death of heretics. Gennady admired the Spanish inquisitors, especially his contemporary Torquemada, who for 15 years of inquisition activity burned and punished thousands of people. As in Rome, persecuted fled to depopulated areas. The most terrible punishment was considered an underground pit, where rats lived. Some people had been imprisoned and tied to the wall there, and untied after their death. Old Believers were persecuted and executed, the order was that even those renouncing completely their beliefs and baptized in the state Church to be lynched without mercy. The writer Lomonosov opposed the religious teachings and by his initiative a scientific book against them was published. The book was destroyed, the Russian synod insisted Lomonosov's works to be burned and requested his punishment.
...were cutting heads, hanging, some by the neck, some by the foot, many of them were stabbed with sharp sticks and impaled on hooks. This included the tethering to a ponytail, drowning and freezing people alive in lakes. The winners did not spare even the sick and the elderly, taking them out of the monastery and throwing them mercilessly in icy 'vises'. The words step back, the pen does not move, in eternal darkness the ancient Solovetsky monastery is going. Of the more than 500 people, only a few managed to avoid the terrible court.
More than 300 Roman Catholics were put to death by English governments between 1535 and 1681 for treason, thus for secular rather than religious offenses. In 1570, Pope Pius V issued his papal bull Regnans in Excelsis, which absolved Catholics from their obligations to the government. This dramatically worsened the situation of the Catholics in England. English governments continued to fear the fictitious Popish Plot. The 1584 Parliament of England, declared in "An Act against Jesuits, seminary priests, and such other like disobedient persons" that the purpose of Jesuit missionaries who had come to Britain was "to stir up and move sedition, rebellion and open hostility". Consequently, Jesuit priests like Saint John Ogilvie were hanged. This somehow contrasts with the image of the Elizabethan era as the time of William Shakespeare, but compared to the antecedent Marian Persecutions there is an important difference to consider. Mary I of England had been motivated by a religious zeal to purge heresy from her land, and during her short reign from 1553 to 1558 about 290 Protestants had been burned at the stake for heresy, whereas Elizabeth I of England "acted out of fear for the security of her realm."
Persecution of Hindus resulting in the death of thousands in the Anti Hindu riots in India.
Although his book was written before the September 11 attacks, John Coffey explicitly compares the English fear of the Popish Plot with the contemporary Islamophobia in the Western world. Among the Muslims imprisoned in the Guantanamo Bay detention camp there also were Mehdi Ghezali and Murat Kurnaz who could not have been found to have any connections with terrorism, but had traveled to Afghanistan and Pakistan because of their religious interests.
According to Rabbinic tradition, monotheistic Judaism arose in Egypt under the direction of Moses. Among the Ten Commandments of that religion was one that forbade the worship of any other god than Yahweh; this led to conflict when Imperial Rome extended its reach into the Middle East.
Early Christianity also came into conflict with the Roman Empire, and may have been more threatening to the established polytheistic order than had been Judaism, because of the importance of evangelism in Christianity. Under Nero, the Jewish exemption from the requirement to participate in public cults was lifted and Rome began to actively persecute monotheists. This persecution ended in 313 AD with the Edict of Milan, and Christianity was made the official religion of the empire in 380 AD. By the eighth century Christianity had attained a clear ascendancy across Europe and neighboring regions, and a period of consolidation began marked by the pursuit of heretics, heathens, Jews, Muslims, and various other religious groups.
The Bangladesh Liberation War (1971) resulted in one of the largest genocides of the 20th century. While estimates of the number of casualties was 3,000,000, it is reasonably certain that Hindus bore a disproportionate brunt of the Pakistan Army's onslaught against the Bengali population of what was East Pakistan. An article in Time magazine dated 2 August 1971, stated "The Hindus, who account for three-fourths of the refugees and a majority of the dead, have borne the brunt of the Muslim military hatred." Senator Edward Kennedy wrote in a report that was part of United States Senate Committee on Foreign Relations testimony dated 1 November 1971, "Hardest hit have been members of the Hindu community who have been robbed of their lands and shops, systematically slaughtered, and in some places, painted with yellow patches marked "H". All of this has been officially sanctioned, ordered and implemented under martial law from Islamabad". In the same report, Senator Kennedy reported that 80% of the refugees in India were Hindus and according to numerous international relief agencies such as UNESCO and World Health Organization the number of East Pakistani refugees at their peak in India was close to 10 million. Given that the Hindu population in East Pakistan was around 11 million in 1971, this suggests that up to 8 million, or more than 70% of the Hindu population had fled the country.The Pulitzer Prize–winning journalist Sydney Schanberg covered the start of the war and wrote extensively on the suffering of the East Bengalis, including the Hindus both during and after the conflict. In a syndicated column "The Pakistani Slaughter That Nixon Ignored", he wrote about his return to liberated Bangladesh in 1972. "Other reminders were the yellow "H"s the Pakistanis had painted on the homes of Hindus, particular targets of the Muslim army" (by "Muslim army", meaning the Pakistan Army, which had targeted Bengali Muslims as well), (Newsday, 29 April 1994).
Hindus constitute approximately 0.5% of the total population of the United States. Hindus in the US enjoy both de jure and de facto legal equality. However, a series of attacks were made on people Indian origin by a street gang called the "Dotbusters" in New Jersey in 1987, the dot signifying the Bindi dot sticker worn on the forehead by Indian women. The lackadaisical attitude of the local police prompted the South Asian community to arrange small groups all across the state to fight back against the street gang. The perpetrators have been put to trial. On 2 January 2012, a Hindu worship center in New York City was firebombed. The Dotbusters were primarily based in New York and New Jersey and committed most of their crimes in Jersey City. A number of perpetrators have been brought to trial for these assaults. Although tougher anti-hate crime laws were passed by the New Jersey legislature in 1990, the attacks continued, with 58 cases of hate crimes against Indians in New Jersey reported in 1991.
In Bangladesh, on 28 February 2013, the International Crimes Tribunal sentenced Delwar Hossain Sayeedi, the Vice President of the Jamaat-e-Islami to death for the war crimes committed during the 1971 Bangladesh Liberation War. Following the sentence, activists of Jamaat-e-Islami and its student wing Islami Chhatra Shibir attacked the Hindus in different parts of the country. Hindu properties were looted, Hindu houses were burnt into ashes and Hindu temples were desecrated and set on fire. While the government has held the Jamaat-e-Islami responsible for the attacks on the minorities, the Jamaat-e-Islami leadership has denied any involvement. The minority leaders have protested the attacks and appealed for justice. The Supreme Court of Bangladesh has directed the law enforcement to start suo motu investigation into the attacks. US Ambassador to Bangladesh express concern about attack of Jamaat on Bengali Hindu community. The violence included the looting of Hindu properties and businesses, the burning of Hindu homes, rape of Hindu women and desecration and destruction of Hindu temples. According to community leaders, more than 50 Hindu temples and 1,500 Hindu homes were destroyed in 20 districts.
The Persecution of Christians can be found historically and in the current century. Even from the beginnings of the religion as a movement within Judaism, Early Christians were persecuted for their faith at the hands of both Jews and the Roman Empire, which controlled much of the areas where Christianity was first distributed. This continued from the first century until the early fourth, when the religion was legalised by the Edict of Milan, eventually becoming the State church of the Roman Empire. In his book, There is no crime for those who have Christ: Religious Violence in the Christian Roman Empire, Michael Gaddis wrote:
The Christian experience of violence during the pagan persecutions shaped the ideologies and practices that drove further religious conflicts over the course of the fourth and fifth centuries... The formative experience of martyrdom and persecution determined the ways in which later Christians would both use and experience violence under the Christian empire. Discourses of martyrdom and persecution formed the symbolic language through which Christians represented, justified, or denounced the use of violence.
Today, Christians are harshly persecuted in countries like North Korea, China, Iraq, Iran, Pakistan, Afghanistan, Tajikistan, Uzbekistan, Kazakhstan, Turkmenistan, Syria, Somalia, Eritrea, Sudan, Yemen among others.
A major component of Jewish history, persecutions have been committed by Seleucids, ancient Greeks, ancient Romans, Christians (Catholics, Orthodox and Protestant), Muslims, Communists, Nazis, etc. Some of the most important events constituting this history include the 1066 Granada massacre, the Rhineland massacres (by Catholics but against papal orders, see also : Sicut Judaeis), the Alhambra Decree after the Reconquista and the creation of the Spanish Inquisition, the publication of On the Jews and Their Lies by Martin Luther which furthered Protestant anti-Judaism and was later used to strengthen German antisemitism in pogroms and the Holocaust.
The Samaritan Temple at Mount Gerizim was destroyed by John Hyrcanus in about 128 BC, partly because it was attracting some northern Jews as a place of worship. In 107 BC, Hyrcanus destroyed Schechem. In the seventeenth century, Muslims from Nablus forced some Samaritans to convert to Islam and forbade access to Mount Gerizim.
The 1984 anti-Sikhs riots or the 1984 Sikh Massacre were a series of pogroms directed against Sikhs in India, by anti-Sikh mobs, in response to the assassination of Indira Gandhi by her Sikh bodyguards. There were more than 8,000 deaths, including 3,000 in Delhi. In June 1984, during Operation Blue Star, Indira Gandhi ordered the Indian Army to attack the Golden Temple and eliminate any insurgents, as it had been occupied by Sikh separatists who were stockpiling weapons. Later operations by Indian paramilitary forces were initiated to clear the separatists from the countryside of Punjab state.
The violence in Delhi was triggered by the assassination of Indira Gandhi, India's prime minister, on 31 October 1984, by two of her Sikh bodyguards in response to her actions authorising the military operation. After the assassination following Operation Blue Star, many Indian National Congress workers including Jagdish Tytler, Sajjan Kumar and Kamal Nath were accused of inciting and participating in riots targeting the Sikh population of the capital. The Indian government reported 2,700 deaths in the ensuing chaos. In the aftermath of the riots, the Indian government reported 20,000 had fled the city, however the People's Union for Civil Liberties reported "at least" 1,000 displaced persons. The most affected regions were the Sikh neighbourhoods in Delhi. The Central Bureau of Investigation, the main Indian investigating agency, is of the opinion that the acts of violence were organized with the support from the then Delhi police officials and the central government headed by Indira Gandhi's son, Rajiv Gandhi. Rajiv Gandhi was sworn in as Prime Minister after his mother's death and, when asked about the riots, said "when a big tree falls (Mrs. Gandhi's death), the earth shakes (occurrence of riots)" thus trying to justify communal strife.
There are allegations that the Indian National Congress government at that time destroyed evidence and shielded the guilty. The Asian Age front-page story called the government actions "the Mother of all Cover-ups" There are allegations that the violence was led and often perpetrated by Indian National Congress activists and sympathisers during the riots. The government, then led by the Congress, was widely criticised for doing very little at the time, possibly acting as a conspirator. The conspiracy theory is supported by the fact that voting lists were used to identify Sikh families. Despite their communal conflict and riots record, the Indian National Congress claims to be a secular party.
Used before the 18th century as an insult, atheism was punishable by death in ancient Greece, in ancient Israel, in Christian countries during the Middle Ages and in Muslim countries. Today, atheism is punishable by death in 13 countries (Afghanistan, Iran, Malaysia, Maldives, Mauritania, Nigeria, Pakistan, Qatar, Saudi Arabia, Somalia, Sudan, United Arab Emirates and Yemen), all of them Muslim, while "the overwhelming majority" of the 192 United Nation member countries "at best discriminate against citizens who have no belief in a god and at worst can jail them for offences dubbed blasphemy". 
Victims of Muslim persecution include Jews, Christians, Zoroastrians, Hindus, Buddhists, Bahá'ís,, Serers and Atheists. Muslim persecution of fellow Muslims include as victims Shia, Ahmadis, Sufi, Alevis and Salafis.
State atheism has been defined by David Kowalewski as the official "promotion of atheism" by a government, typically by active suppression of religious freedom and practice. It is a misnomer referring to a government's anti-clericalism, which opposes religious institutional power and influence, real or alleged, in all aspects of public and political life, including the involvement of religion in the everyday life of the citizen.
State atheism was first practised during a brief period in Revolutionary France and repeated only in Revolutionary Mexico and Communist states. The Soviet Union had a long history of state atheism, in which social success largely required individuals to profess atheism, stay away from churches and even vandalize them; this attitude was especially militant during the middle Stalinist era from 1929-1939. The Soviet Union attempted to suppress religion over wide areas of its influence, including places like central Asia, and the post-World War II Eastern bloc. One state within that bloc, the Socialist People's Republic of Albania under Enver Hoxha, went so far as to officially ban all religious practices.
The Bahá'ís are Iran's largest religious minority, and Iran is the location of one of the largest Bahá'í populations in the world. Bahá'ís in Iran have been subject to unwarranted arrests, false imprisonment, beatings, torture, unjustified executions, confiscation and destruction of property owned by individuals and the Bahá'í community, denial of employment, denial of government benefits, denial of civil rights and liberties, and denial of access to higher education.
More recently, in the later months of 2005, an intensive anti-Bahá'í campaign was conducted by Iranian newspapers and radio stations. The state-run and influential Kayhan newspaper, whose managing editor is appointed by Iran's supreme leader, Ayatollah Khamenei , ran nearly three dozen articles defaming the Bahá'í Faith. Furthermore, a confidential letter sent on October 29, 2005 by the Chairman of the Command Headquarters of the Armed Forced in Iran states that the Supreme Leader of Iran, Ayatollah Khamenei has instructed the Command Headquarters to identify people who adhere to the Bahá'í Faith and to monitor their activities and gather any and all information about the members of the Bahá'í Faith. The letter was brought to the attention of the international community by Asma Jahangir, the Special Rapporteur of the United Nations Commission on Human Rights on freedom of religion or belief, in a March 20, 2006 press release .
In the press release the Special Rapporteur states that she "is highly concerned by information she has received concerning the treatment of members of the Bahá'í community in Iran." She further states that "The Special Rapporteur is concerned that this latest development indicates that the situation with regard to religious minorities in Iran is, in fact, deteriorating." .
Persecution of Buddhists was a widespread phenomenon throughout the history of Buddhism lasting to this day, beginning as early as the 3rd century AD by the Zoroastrian Sassanid Empire. Anti-Buddhist sentiments in Imperial China between the 5th and 10th century led to the Four Buddhist Persecutions in China of which the Great Anti-Buddhist Persecution of 845 was probably the most severe. In the 20th century Buddhists were persecuted by Asian communist states and parties, Imperial Japan and by the Kuomintang among others.
Persecution of the Serer people of Senegal, the Gambia and Mauritania is multifaceted, and it includes both religious and ethnic elements. Religious and ethnic persecution of the Serer people dates back to the 11th century when King War Jabi usurped the throne of Tekrur (part of present-day Senegal) in 1030, and by 1035, introduced Sharia law and forced his subjects to submit to Islam. With the assistance of his son (Leb), their Almoravid allies and other African ethnic groups who have embraced Islam, the Muslim coalition army launched jihads against the Serer people of Tekrur who refused to abandon Serer religion in favour of Islam. The number of Serer deaths are unknown, but it triggered the exodus of the Serers of Tekrur to the south following their defeat, where they were granted asylum by the lamanes. Persecution of the Serer people continued from the medieval era to the 19th century, resulting in the Battle of Fandane-Thiouthioune. From the 20th to the 21st centuries, persecution of the Serers is less obvious, nevertheless they are the object of scorn and prejudice.
The persecution of the Falun Gong spiritual practice began with campaigns initiated in 1999 by the Chinese Communist Party to eliminate Falun Gong in China. It is characterised by multifaceted propaganda campaign, a program of enforced ideological conversion and re-education, and a variety of extralegal coercive measures such as arbitrary arrests, forced labor, and physical torture, sometimes resulting in death.
There have being reports of Organ harvesting of Falun Gong practitioners in China. Several researchers—most notably Canadian human rights lawyer David Matas, former parliamentarian David Kilgour, and investigative journalist Ethan Gutmann—estimate that tens of thousands of Falun Gong prisoners of conscience have been killed to supply a lucrative trade in human organs and cadavers.
"Persecution" in this study refers to violence or discrimination against members of a religious minority because of their religious affiliation. Persecution involves the most damaging expressions of prejudice against an out-group, going beyond verbal abuse and social avoidance.29 It refers to actions that are intended to deprive individuals of their political rights and to force minorities to assimilate, leave, or live as second-class citizens. When these actions happen persistently over a period of time, and include large numbers of both perpetrators and victims, we may refer to a "campaign" of persecution that usually has the goal of excluding the targeted minority from the polity.
The 25th anniversary of Indira Gandhi's assassination revives stark memories of some 3,000 Sikhs killed brutally in the orderly pogrom that followed her killing
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