Jus Corpus Law Journal

Open Access Law Journal – Copyright © 2023 – ISSN 2582-7820

Editor-in-Chief – Prof. (Dr.) Rhishikesh Dave; Publisher – Ayush Pandey

This is an Open Access article distributed under the terms of the Creative Commons Attribution-
Non-Commercial-Share Alike 4.0 International (CC-BY-NC-SA 4.0) License, which permits
unrestricted non-commercial use, distribution, and reproduction in any medium provided the
original work is properly cited.

From Belief to Tragedy: Unveiling the Layers of the Burari Case

Meghana Ga Tanush B Ab

a
MS Ramaiah College of Law, Bengaluru, India bMS Ramaiah College of Law, Bengaluru, India

Received 20 August 2023; Accepted 12 September 2023; Published 16 September 2023

__________________________________

‘To one who has faith, no explanation is necessary. To one without faith, no explanation is possible.’

- Thomas Aquinas.

There being a thin curtain between faith and blind faith, one must never forget that “You must not use your
God-given body for killing God’s creatures, whether they are human, animal or whatever.”

- Yajur Veda, chapter 12, verse 32.

In a quiet neighborhood of Delhi's Burari area, a seemingly ordinary family's existence took a chilling turn as their shared beliefs
led them down an unexpected and tragic path. Amidst this tapestry, the family's fate unraveled in a way that stunned their
community and the world. The secrecy surrounding their actions hinted at the deeply ingrained convictions that influenced their
decisions. The incident highlighted the importance of addressing mental health, shared delusions, and the need for open conversations
within families. The Burari case serves as a haunting reminder of how intertwined beliefs, familial connections, and psychological
factors can lead down paths unforeseen. It raises questions about the fine line between devotion and delusion while underscoring
the significance of understanding and supporting mental health within families. As the threads of this tragic narrative are woven
into our collective consciousness, it implores us to delve deeper into the complexities of human psychology and the impact of shared
beliefs on individual lives, and how law can play an effective role in the same.

67
 G & B A: FROM BELIEF TO TRAGEDY: UNVEILING THE LAYERS OF THE BURARI CASE

Keywords: burari case, mass suicide, shared psychosis, witchcraft, rituals.

INTRODUCTION

India is a very diverse country with different religions coexisting simultaneously. Every human
being has their own belief system, which can be a very simple source such as God. Nevertheless,
the belief can include their ancestors, i.e., the belief that the deceased family member is still
present and they can guide us. It is not uncommon to have such a belief since many cultural
religions believe the same. This is often termed as ‘ancestral worship’. This is a kind of religious
practice whose faith mainly lies on the fact that the deceased family member continues to exist
and their souls have an impact on the lives and luck of the living. It can be seen in the practice
of Día de Los Muertos from Mexico, where they connect with their departed family members by
using altars and unique Día de Los Muertos symbology. Apart from this, the Paganito ceremony
of the Philippines, venerated saints of Rome, Shi ceremony of China etc. celebrate and believe
in ancestral worship.1

However, these beliefs must be followed after a considerable amount of rationale behind it and
the fact that everything should be done within a limit must not be turned a blind eye on. Thus,
Ray Bradbury rightly said, ‘Too much of anything isn't good for anyone’. It is also said that too much
of anything is just the start of another mess. But sometimes mess can simply become the
synonym of tragedy, as in the case of Burari house, where the blind belief of the family members
resulted in something worse than a mess, i.e. the Death of 11 members. This case not only
shocked many but also raised the question of ‘how much is too much?’

The news of the Burari house spread like wildfire, leaving a trail of questions among the
common people and the police officers. The fact that this incident took place in the house that
was ready to host the wedding of one of their own daughters, created a perplexing situation for
all. A lot of assumptions were drawn to unravel the truth behind this horrifying act of the family

1Sarah Kessler, ‘12 Types of Ancestor Worship from Around the World’ (Cake, 14 June 2022)
<https://www.joincake.com/blog/ancestor-worship/> accessed 18 August 2023

68
 JUS CORPUS LAW JOURNAL, VOL. 4, ISSUE 1, SEPTEMBER – NOVEMBER 2023

members. Some of them were – mass suicide, abetment to suicide, occult, superstition, black
magic etc. Even though the police, after a severe investigation, concluded that it was just an
accident, the truth remains unclear. Thus, it wouldn’t be wrong to conclude that the family took
their secrets to the grave with them. In light of such a spine-chilling incident, it is imperative to
develop a mechanism to control and prevent such incidents from repeating itself in the future.
In a country like India, where there is a blend of innumerable cultures, practicing innumerable
rituals, it becomes quintessential to ensure that superstitious practices are prevented and people
involved in such a practice are awarded appropriate punishments along with mental health
support.

TIMELINE OF THE EVENT

A 13-member family of Chundawat, of whom 11 members of the family were found dead on the
morning of July 1 at 7:18 am in their Burari House. Mr. Rajeev Tomar, being the first policeman
to enter the house, was also the first person to describe the crime scene as, ‘It was shocking. I
stayed only for 10-15 seconds before rushing downstairs to call my seniors. At the time I did not see whose
hands were tied and whose eyes were covered. I just saw a lot of bodies hanging, just like branches of a
tree.’

The 11 members are Bhavnesh Singh; his brother, Lalit Singh; their wives, Savita and Tina,
respectively; their children - Neetu, Monu alias Maneka, Dhruv alias Dushyant and Shivam;
their sister - Pratibha alias Baby and her daughter Priyanka were found hanging in a circular
formation; Pratibha was hanging a little away from the group. The mother, 77-year-old Narayan
Devi, was found dead on the floor in the adjacent room. 2

While a thorough analysis was done at the crime scene, it was found that the family had
performed a ritual called as ‘badh tapasya [banyan tree worship]’. Further, the elder son
Bhavnesh showed clear signs of struggle as he had tried to set his hands free during the
performance of the ritual. The children were tied not only by their hands but also by their feet,

2Hemani Bhandari, ‘Burari Deaths: 11 bright people with one dark secret’ (The Hindu, 16 July 2018)
<https://www.thehindu.com/news/cities/Delhi/11-bright-people-with-one-dark-secret/article24428709.ece>
accessed 18 August 2023

69
 G & B A: FROM BELIEF TO TRAGEDY: UNVEILING THE LAYERS OF THE BURARI CASE

mercilessly tied to telephone wires. There were no indications of struggle or resistance from any
of them. Both their eyes and mouth were securely taped, and cotton was used to block their ears.
The eldest of the family, Narayani Devi, was found dead in another room with her body partially
turned. In addition to this, her body was found with few marks on the side of her neck which
was caused due to the belt encircling her neck. The common observation was that all family
members had hanged themselves with scarves around their necks.3

With further investigation, CCTV footage from June 28th, 2018 revealed that Tina along with her
son Shivam had purchased 4 stools. Later on June 30th Tina along with Nita was captured
carrying other required tools. Further Shivam was also captured carrying a bundle of wires. In
the investigation, a ledger was recovered adjacent to the pooja room. The CCTV footage also
indicated that no outsider entered the house from 10 p.m. on July 1 till the next day when 11
members of the family were found dead by a neighbour. After in-depth research, 11 diaries were
unearthed with the first entry being in 2007 and the final entry being made on the evening before
the incident in 2018. With such a spine-chilling incident witnessed by the police and media, the
whole incident became a puzzle-maze, with speculations such as – whether it was a ‘mass
suicide’, ‘murder’ or a ‘culpable homicide’ or just a ritual gone wrong?4

BEYOND THE SURFACE: DELVING INTO FORENSIC ANALYSIS

The initial stages of the postmortem report dealt with if it was a case of poisoning. However,
since the autopsy report of 6 showed no signs of poisoning, it became clearer that it was nothing
but a mass suicide.5 Finally, it strengthened the case of suicide when the postmortem report
reflected that 10 out of 11 deaths were caused due to hanging. Clues emerged from notes found
at Bhatia's house, hinting that only Lalit had knowledge of the impending tragedy and was the

3 Shashikant Sharma, ‘Burari Deaths: Unthinkable facts that will shake your conscience’ (News Nation, 4 July 2018)
<https://english.newsnationtv.com/cities/delhi-and-ncr/mysterious-burari-deaths-unthinkable-facts-about-
burari-family-suicide-delhi-family-suicide-198078.html> accessed 18 August 2023
4 Oishika Banerji, ‘Burari death case: an insight’ (iPleaders, 19 January 2022) <https://blog.ipleaders.in/burari-

death-case-insight/> accessed 18 August 2023

5 ‘Postmortem report of Burari family confirms hanging as cause of death’ (India Today, 11 July 2018)

<https://www.indiatoday.in/india/story/postmortem-report-of-burari-family-confirms-hanging-as-cause-of-
death-1282567-2018-07-11> accessed 18 August 2023

70
 JUS CORPUS LAW JOURNAL, VOL. 4, ISSUE 1, SEPTEMBER – NOVEMBER 2023

‘mastermind’ behind the orchestration of the seeming mass suicide.6 Questions lingered about
the three family members whose hands were loosely tied as to whether they struggled to free
themselves or succumb like the others.7 Further, the post-mortem reports spoke of ‘antemortem
hanging,’ supporting the theory of suicide.8 A belt near Narayan Devi's body and a scar around
her neck suggested a sinister truth—an almirah might have been her final anchor. This was
supported by the diary entry which provided clear instructions for the procedure to attain
‘salvation’.9There was no proof found to indicate that the family was in touch with any godman
or tantric10. The police said that the hands of Lalit, his wife Tina, and his elder brother Bhavnesh
were found tied loosely in the front, while the hands of the other members were tied behind their
backs. The police had also found 11 diaries, which contained ‘psychological musings’ and certain
things written about the ‘road to god’.11 In addition to this, the police had conducted
a psychological autopsy, whose report revealed that the family members did not wish to commit
suicide but the deaths happened due to an ‘accident that occurred during a ritual’12 and this was
supported by the fact that the CCTV footage from the neighborhood showed that that the family
bought goods used in ‘rituals’, five tables and bandage from a shop close to their Burari home.13
The development cemented the police’s theory of the family suffering from shared psychosis.
After the ritual hanging, everyone was supposed to untie each other. The ‘ritual hanging’ was

6 ‘Delhi Burari deaths case: Know all about Lalit Bhatia, who allegedly masterminded the ‘suicide-pact’’(Mirror
Now, 3 July 2018) <https://www.timesnownews.com/mirror-now/society/article/delhi-burari-death-cases-
who-is-lalit-bhatia-suspected-mastermind-of-the-burari-mass-suicide/249129> accessed 18 August 2023
7 ‘Burari Deaths: Final Autopsy Report Confirms All 11 Family Members Died Of Hanging’ (Outlook, 13 July 2018)

<https://www.outlookindia.com/website/story/burari-deathsfinal-autopsy-report-confirms-all-11-family-
members-died-of-hanging/313430/amp> accessed 18 August 2023
8 ‘Delhi Burari deaths case: After final post-mortem report, Delhi police to conduct psychological autopsy’ (Times

Now News,12 July 2018) <https://www.timesnownews.com/mirror-now/in-focus/article/delhi-burari-deaths-

case-delhi-police-clear-the-air-after-final-postmortem-of-bhatia-family/253540> accessed 18 August 2023
9 Nimisha Jaiswal and Deepshikha Ghosh, ‘Delhi Family Deaths Just Days After Daughter's Engagement: 10

Points’ (NDTV, 2 July 2018) <https://www.ndtv.com/delhi-news/burari-deaths-six-of-11-died-due-to-hanging-

says-post-mortem-report-1876364> accessed 18 August 2023
10 Burari Deaths: Final Autopsy Report Confirms All 11 Family Members Died Of Hanging (n 7)
11 ‘Burari deaths: Post-mortem report rules out foul play, says family members died due to hanging’ (Indian

Express, 11 July 2018) <https://indianexpress.com/article/cities/delhi/burari-family-deaths-hanging-murder-

post-mortem-report-5255351/> accessed 18 August 2023
12 ‘It was an accident: Report reveals how a ritual went wrong for Burari family’ (India Today, 15 September 2018)

<https://www.indiatoday.in/india/story/it-was-an-accident-report-reveals-how-ritual-went-wrong-for-burari-
family-1340281-2018-09-15> accessed 18 August 2023
13 Burari deaths: Post-mortem report rules out foul play, says family members died due to hanging (n 11)

71
 G & B A: FROM BELIEF TO TRAGEDY: UNVEILING THE LAYERS OF THE BURARI CASE

supposed to be the final thanks to the spirits.14 Police further stated that the fact that there were
11 diaries maintained over a period of eleven years is a coincidence and it is not in any way
related to the deaths of the 11 family members.15 The notes corroborate the crime scene. They
have a strong similarity with the way the mouths and eyes of the deceased were tied and taped.16

FAMILY DYNAMICS

The Chundawat family’s journey was like a puzzle of connections and surprises. They moved
from Rajasthan to Delhi's Burari area for a fresh start. Bhopal Singh, the head of the family, was
highly respected. This move brought both good and challenging times as they blended their old
ways with new ones. Inside this close-knit group, each person had a special role. Bhavnesh, the
older son, chatted a lot at his grocery store. Neetu, his daughter, helped him there and added
warmth. Their closeness made the family strong. Among them was Lalit, who was a mix of
serious and funny. He took care of the family when they came to Delhi. After his dad, Bhopal
Singh, passed away in 2007, things changed. Lalit felt his dad’s presence in dreams, guiding their
daily routines. Their neighbours noticed the family’s kindness. Narayan Devi, the mother, was
wise, and daughters-in-law Savita and Tina took care of the house. But changes were happening
too, like no more non-vegetarian food and more rituals.

The young ones like Neetu and Maneka were full of energy. They balanced school and traditions.
Teenagers Shivam and Dhruv did the same, focusing on studies and beliefs. Lalit's friend Ahmed
Ali remembered how Lalit talked about his dad's advice. But something changed in Lalit’s
behaviour before the tragic event. His absence at work and his distance from others worried
people. Despite all this complexity, the family kept quiet about their plans. Even Dinesh Singh

14 Somreet Bhattacharya and Sidharth Bhardwaj, ‘Bhatia diaries hint at ritual to free 'spirits' from their house’
(Times of India, 6 July 2018)
<http://timesofindia.indiatimes.com/articleshow/64876367.cms?utm_source=contentofinterest&utm_medium=t
ext&utm_campaign=cppst > accessed 18 August 2023
15 ‘Burari family didn't expect to die, thought earth would shake and they'll be saved’ (India Today, 5 July 2018)

<https://www.indiatoday.in/india/story/burari-deaths-cctv-footage-family-not-expecting-death-thought-will-
be-saved-diaries-1277789-2018-07-04> accessed 18 August 2023
16 ‘Burari deaths: Final autopsy report confirms all 11 family members died of hanging’ (Hindustan Times, 13 July

2018) <https://www.hindustantimes.com/delhi-news/burari-deaths-final-autopsy-report-confirms-all-11-
family-members-died-of-hanging/story-KRc0lT1d1fIJfglsPMg7XI_amp.html> accessed 18 August 2023

72
 JUS CORPUS LAW JOURNAL, VOL. 4, ISSUE 1, SEPTEMBER – NOVEMBER 2023

Chundawat, Bhopal Singh’s surviving son, didn't know. The family's silence showed how
strongly they believed in their choices.

The Chundawat family’s story was about being together and having secrets. It showed how
families shape our lives, and how we can be influenced by strange forces. Their story reminded
us that there's more beneath the surface in a world full of connections.17

THE GHOST WHO SPEAKS

In the shadowed corridors of the Burari case, an aura of mystique envelopes the Bhatia families'
perplexing journey from ritualistic practices to their chilling mass suicide. Lalit had lost his voice
because of an accident in the past and after the death of Bhopal Singh the whole family was
devastated and a priest was called for Garuda Purana paath (a prayer) for 10 days. ‘One of those
10 days, they were all sitting and listening to the prayers when Lalit suddenly started chanting
Om. His voice came back, and everybody said, ‘Daddy aa gaye [Daddy has returned].’ This was
perhaps the beginning of the end. The dead patriarch of the family, Late Bhopal Singh continues
to influence the family and seems to have total authority over all their actions and choices made
in their lives even after his death. At the heart of this mystery stands Lalit, Bhopal Singh's son,
who embodies his father's essence. By channeling his father's gestures, mannerisms, and
wisdom, Lalit breathes life into his father's presence. The convergence of past and present
becomes a tapestry of devotion and mimicry, as the torchbearer embarks on a journey that
redefines his identity, guiding the family on what to do and what not to do. As revealed by the
recovered notes and testimonies, Bhopal Singh seemed to allegedly communicate with his son,
Lalit. The handwritten notes, inscribed with instructions and strict guidelines, bear the
distinctive voice of Bhopal Singh, guiding the family's daily routine and decisions. His presence
was said to manifest in dreams, conversations, and the very actions the family undertook. The
instructions were followed by every member of the family with deep sincerity and respect which
also led the family to financial prosperity and familial harmony. However, no one knew what

17Hemani Bhandari, ‘Burari Deaths: 11 bright people with one dark secret’ (The Hindu, 16 July 2018)
<https://www.thehindu.com/news/cities/Delhi/11-bright-people-with-one-dark-secret/article24428709.ece>
accessed 18 August 2023

73
 G & B A: FROM BELIEF TO TRAGEDY: UNVEILING THE LAYERS OF THE BURARI CASE

was coming next, at the heart of this enigma lies the thanksgiving ceremony performed as a
token of gratitude to their father Late Bhopal Singh in the form of badh tapasya [banyan tree
worship] which led to a haunting tragedy that claimed the lives of 11 members of a family.18

CASE OF SHARED PSYCHOSIS?

Shared Psychotic Disorder is a rare disorder characterized by sharing a delusion among two or
more people in a close relationship. The inducer who has a psychotic disorder with delusions
influences another nonpsychotic individual or more based on a delusional belief.

As time passed Lalit took over the place of his father, the late Bhopal Singh. The patriarchal
system of the family also helped the whole case as it is highly doubted that if the genders were
reversed, Lalit’s control over the family would not have been to this extent. 19 Further, a
psychiatrist, Dr Nimesh Desai, Chief of the Institute of Human Behaviour and Allied Sciences in
Delhi observed that Lalit exhibited typical symptoms of psychotic disorder, whose symptoms
can be hallucinations, hearing, seeing, or smelling things not there, or delusions, i.e. thinking one
has special abilities or that people are after them.20 With a strange power, he led his family down
a disturbing path, driven by a belief that defied reason. As the grip of shared psychosis tightened,
their lives were forever changed. This concept of shared psychotic disorder reminds us of the
fascinating yet treacherous paths our minds can take. It's a reminder that reality can blur when
beliefs become shared, and the consequences can be haunting.

In the case of Lalit, he was blinded by the belief that his father instructed him on how to lead
their life and he shared this delusion with other members of the family. This again depends on
various factors, the length and nature of relationships play pivotal roles, as do factors like social
isolation, personality disorders, untreated mental illness, and cognitive impairments. Stressful

18 Ibid
19 Suditi Sundaram, ‘House of Secrets: The Burari Deaths And The Gendered Realities Of Our Households’
(Feminism in India, 9 November 2021) <https://feminisminindia.com/2021/11/09/house-of-secrets-the-burari-
deaths-and-the-gendered-realities-of-our-households/> accessed 18 August 2023
20 Damayanti Datta, ‘Burari family's deadly leap of faith: How Lalit convinced others to kill themselves’ (India

Today, 6 August 2018) <https://www.indiatoday.in/magazine/society/story/20180806-a-deadly-leap-of-faith-

1296560-2018-07-28> accessed 18 August 2023

74
 JUS CORPUS LAW JOURNAL, VOL. 4, ISSUE 1, SEPTEMBER – NOVEMBER 2023

life events, communication difficulties, age and even gender add layers to this intricate tapestry
of shared delusion. The Burari family's life held these same threads. Their close-knit bonds,
mingled with social isolation, personality complexities, and untreated mental struggles of Lalit
ultimately led to the horrific tragedy. Shared psychotic disorder unravels the enigma of twisted
minds, where beliefs spring to life by themselves. It underscores how the chain of our thoughts
may swing into unforeseen turns, echoing the potency of human connections and the intricate
nature of our psychology that blinded these 11 people to the point that they took their own lives.

RATINGS OVER REALITY

The dark side of media sensationalism in the Burari Tragedy cannot be left unaddressed. The
media’s rush to report led to false speculations, inaccurate information, and exaggerated
narratives leading to confusion and misrepresentation of facts further sensationalizing the tragic
events. Sensationalizing tragic events in the Burari case led to the commercialization of grief.
Media's pursuit of higher viewership overshadowed the human aspect of the incident. The
media’s responsibility to report responsibly and ethically was compromised in the race for
breaking news. Balancing the need for information with sensitivity and accuracy is the primary
responsibility of the media which was clearly ignored. The intrusive nature of media coverage
infringed upon the privacy of victims and their families and biased reporting shaped public
perception, leading to misconceptions about the case. This further perpetuated stereotypes and
stigmatized the faith involved without a comprehensive understanding of the complexities.21

It is rightly said by Malcolm X that ‘The media’s the most powerful entity on earth. They have the power
to make the innocent guilty and to make the guilty innocent, and that’s power. Because they control the
minds of the masses and with great power comes great responsibility and thus, media houses
should report with truth, empathy, integrity and sensitivity and not just run in the race for TRPs.

21‘Deaths Without Distress: The dramatised portrayal of the Burari case’ (Mind Piper, 10 July 2018)
<https://medium.com/@Mind.Piper/deaths-without-distress-the-dramatised-portrayal-of-burari-case-
bd2f475fd7f7> accessed 18 August 2023

75
 G & B A: FROM BELIEF TO TRAGEDY: UNVEILING THE LAYERS OF THE BURARI CASE

CULTURAL COMPASS AND SOCIETAL IMPACT - NAVIGATING THE AFTERMATH OF

THE BURARI TRAGEDY

What happened after the tragedy? Some people refused to believe it was a suicide and alleged
that the entire family was murdered, while some were horrified and clueless, some associated it
with black magic and witchcraft, some called it an accident, some called them possessed, and
everyone had their own interpretations initially until the post mortem report was released. The
chain of questions it raised throughout the country and its strong impact on society exposed the
power of shared psychotic beliefs within families and communities. It raised questions about
how these shared delusions can escalate into dangerous actions, challenging the fine line
between devotion and extremism.

The case shed light on the vulnerability of individuals to psychological manipulation, especially
when influenced by charismatic figures or perceived spiritual leaders. It prompted discussions
about mental health awareness and the need for early intervention. The incident sparked
conversations about preventive measures. It brought attention to the importance of community
support, mental health initiatives, and educational programs to identify early signs of shared
psychotic disorders and intervene effectively. The gruesome tragedy parts with us leaving
behind some important lessons to learn, it shows us the power of faith and how dangerous its
misinterpretation could be. The horrific incident left the people of the country speechless and
made them delve into their minds and look for answers and the missing pieces of the unsolved
puzzle.

RELIGIOUS EXTREMISM OR DEVOTION? LEGAL CHALLENGES IN IDENTIFYING THE

FINE LINE

The primary challenge lies in differentiating genuine religious devotion from dangerous
extremism. The family's activities and notes suggest a strong connection to spiritual practices,
making it difficult to determine whether their actions were driven by sincere beliefs or a
distorted interpretation of their faith. This reflects the character of religious extremism which
means a high sense of ideological commitment that is expressed through certain actions that

76
 JUS CORPUS LAW JOURNAL, VOL. 4, ISSUE 1, SEPTEMBER – NOVEMBER 2023

show deep loyalty to a belief system. It includes practices that characterize and define the rituals
and customs of many religious groups. Was the tragedy led by informed consent or
coercion? Establishing whether all family members were active participants or coerced into the
activities is another unsolved mystery. Understanding if any members were manipulated or
forced into following extreme practices is crucial in assessing individual culpability. Another
challenge was, understanding the extent of the practice of superstition, which partially falls
under the ambit of religious freedom. While individuals have the right to religious expression,
these extreme blind practices, which led to deaths raise concerns about public safety as such a
practice can seep into the lives of others and influence them to do the same. Evaluating the
mental health of the family members, particularly those who actively participated in the rituals
leading to deaths, becomes a significant challenge on top of that determining their mental state
and competency at the time of the events becomes essential for appropriate legal action. Now
such cases are subject to cultural and religious sensitivity, avoiding stigmatization of the faith
involved while addressing the potential risks posed by extreme interpretations, requires careful
legal navigation which becomes very crucial in arriving at the right conclusion. Should family
members be prosecuted as criminals, or should they be subject to psychological evaluation and
rehabilitation? Prosecution demands evidence of criminal intent and accountability, yet the
presence of mental health issues blurs the lines. Finding the root causes of such incidents
becomes extremely difficult leading to more questions than answers.

There exists an utter drought with regard to the legislation to govern such superstitious
activities. The term ‘superstition’ means a belief related to ignorance or fear and characterized
by obsessive reverence for reverence for the supernatural.22 Prevention of Witch Hunting bill
was tabled in Lok Sabha in 2016, which was not passed. Apart from this, the Drugs and Magic
Remedies Act 1954 also aims to tackle the debilitating impact of various superstitious activities
prevalent in India. In IPC, Section 30223 and Section 295A24 discourage practices of superstition
and human sacrifice. Further, certain States have taken cognizance of the matter and have

22 ‘Anti-superstition laws in India’ (Dristi IAS, 1 November 2022) <https://www.drishtiias.com/daily-

updates/daily-news-analysis/anti-superstition-laws-in-india> accessed 19 August 2023
23 Indian Penal Code 1860, s 302
24 Indian Penal Code 1860, s 295A

77
 G & B A: FROM BELIEF TO TRAGEDY: UNVEILING THE LAYERS OF THE BURARI CASE

successfully enacted legislations such as Bihar’s The Prevention of Witch (Daain) Practices Act,
Maharashtra's Prevention and Eradication of Human Sacrifice and Other Inhuman, Evil, and
Aghori Practices and Black Magic Act, Karnataka Prevention and Eradication of Inhuman Evil
Practices and Black Magic Act.25 These Acts play a crucial role in controlling inhumane practices
related to religious rituals. Maharashtra's anti-superstition law specifically defines ‘godmen’ as
a person who claims to possess supernatural powers.26 Such legislation becomes crucial to put a
full stop to activities that are superstitious and also the practice of the occult, where people are
manipulated into believing blinding and thereby controlled. Further, there is need for a
Centralised legislation to dwell into such matters with not only provide for punishments but
also provide for psychological analysis and aid to the convict and the victim. The Burari case is
just an incident that further stressed the need for legal strategies to effectively address the
complexities of mental health and legal responsibility in achieving long-term legal reforms to
address evolving challenges.

WAY FORWARD

As we close the chapter on the Burari case, we find ourselves at the intersection of belief and
blind faith. The Burari case stands as a chilling testament to the convergence of human
psychology, religious beliefs, and societal dynamics. This haunting saga unraveled a web of
complexities that stretched from shared psychotic disorders to spiritual devotion, from family
ties to media sensationalism. As we reflect on this tragedy, we are reminded of the fine line
between faith and extremism, the challenges of discerning mental health nuances, and the power
of influence in shaping our actions.

As we move forward with the horrors of the Burari case, it is imperative that society draw critical
insights. We must recognize the importance of mental health awareness, intervention, and
support. It makes us reassess our system of expressing empathy, communication, and resources

25 Swathi Satish, ‘Anti-superstition law’ (ClearIAS, 11 November 2022) <https://www.clearias.com/anti-

superstition-laws/> accessed 19 August 2023
26 Rounak Kumar Gunjan, ‘Burari Horror: India Needs Strong 'Occult Law' But Public and Political Will Too

Weak’ (News18, 3 July 2018) <https://www.news18.com/news/india/burari-horror-india-needs-strong-occult-

law-but-public-and-political-will-too-weak-1798859.html> accessed 19 August 2023

78
 JUS CORPUS LAW JOURNAL, VOL. 4, ISSUE 1, SEPTEMBER – NOVEMBER 2023

to ensure the well-being of individuals who might be struggling silently. Simultaneously, it

implores us to scrutinize the potential consequences of media sensationalism, urging responsible
journalism that upholds ethical standards.

This case underscores the significance of cultural sensitivity and education, as well as the
development of a Centralised Act in combating the beliefs that prima facie reflects harmful
superstition leading to any mental or bodily injury or death. Along with this, there is a need for
the development of legal scrutiny in the aspects of witchcraft and the occult. Further, it calls for
a proactive approach to preventing future incidents by fostering open dialogue, promoting
critical thinking, and building resilient communities that support one another. As we navigate
the complexities of faith, mental health, and societal influences, the lessons from the Burari case
take us on a journey to take steps toward building a society that is compassionate, informed, and
attuned to the well-being of all its members.

79