The Politics of Muslim Rage: Secular Law and Religious Sentiment in Late Colonial India

In 1924 the Lahore publisher Mahashay Rajpal printed a satire on the Prophet’s domestic life titled Rangila Rasul. The book’s title translated literally into English meant the colourful Prophet, but in Urdu and Hindi implied a strong insinuation of sexual dalliance. The government brought charges against Rajpal under Section 153A of the Indian Penal Code, which criminalized ‘attempts to promote feelings of enmity or hatred between different classes’. After years of legal battles, the Lahore High Court acquitted Rajpal in May 1927, finding that, although the pamphlet was highly offensive, there was no proof that its purpose was to promote feelings of enmity. In the months following the acquittal, the case provoked a firestorm of debate. In September 1927 the Indian Legislative Assembly approved an amendment to the Penal Code, Section 295A, which directly criminalized insults to religion, eliminating the requirement to prove that such insults promoted hatred between communities. In response newspapers in Lahore, calling the new law a dangerous concession to Muslim fanaticism, carried some of the earliest calls for India to embrace an explicitly secular politics.

In April 1929 the press again erupted with controversy when a young man named Ilmuddin murdered Rajpal. After his execution in October 1929 Ilmuddin became a folk hero for some Muslims, and he continues to be a subject of popular hagiographies today. In one such book, Ghazi Ilmuddin Shahid (The Warrior Ilmuddin, Martyr), published in the late 1980s, the semi-fictional narrative includes dialogues between Ilmuddin, his friends, and his father during the days before the murder.¹ These dialogues draw the reader into the intimate space of Ilmuddin’s emotional life. The prose narrative is interspersed with short passages of poetry evoking love for the Prophet. Blending fact and fiction, historical narrative and lyrical poetry, the book departs dramatically from the conventions of academic scholarship.

Yet the book also includes photocopies of court proceedings and police records from Ilmuddin’s case, a virtual legal archive. At first the inclusion of these documents appears distinctly at odds with the book’s emotional narrative of martyrdom. The court records detail the efforts of Ilmuddin’s lawyers, including Pakistan’s founder Muhammad Ali Jinnah, to prove that he was the victim of a miscarriage of justice. Yet the concern of the author with the legal dimensions of Ilmuddin’s case is not unusual among those who celebrate him as a folk hero. As recently as 2011, the Lahore High Court reviewed a petition to reopen Ilmuddin’s case.² The petition came in the wake of the assassination of Salman Taseer, Governor of the Punjab and a prominent critic of Pakistan’s controversial blasphemy laws. Interest in the legal cause of a long-deceased convict challenges common conceptions about the hyper-rationality of law. Instead Ilmuddin’s case suggests that the courtroom simultaneously invokes feelings of attachment, narratives of national memory, and arguments about justice.³

Given the importance in popular memory of the Rangila Rasul controversy and Rajpal’s subsequent murder, scholars have devoted surprisingly little attention to the episode. These events are normally cited as an example of Indian communalism and the heightened religious violence that broke out in the mid 1920s.⁴ Yet few historians have explored the debates that unfolded in the press about the trial and legislation.⁵ The relative lack of scholarly interest in the Rangila Rasul controversy is also surprising given the attention scholars have given to similar contemporary episodes, including the controversies surrounding Salman Rushdie’s Satanic Verses in the late 1980s and the Danish cartoons in 2005 and 2008.⁶

Taking the intermingling of law and emotion in popular hagiographies as a point of departure, this article explores the entangled histories of secular law and religious sentiment during the Rangila Rasul controversy. In some of the most interesting of the limited scholarly work on the controversy, David Gilmartin has argued that emotive appeals to Muslims’ feelings of devotion to the Prophet powered new forms of urban politics, an interpretation of the controversy which other scholars have repeatedly cited.⁷ This argument dovetails...