Major2008 Sati and The

Gender & History ISSN 0953-5233
Andrea Major, ‘The Burning of Sampati Kuer: Sati and the Politics of Imperialism, Nationalism and Revivalism in 1920s India’
Gender & History, Vol.20 No.2 August 2008, pp. 228–247.
The Burning of Sampati Kuer: Sati and the

Politics of Imperialism, Nationalism and
Revivalism in 1920s India
Andrea Major
Sati, the immolation of a Hindu widow on her husband’s funeral pyre, is a rare, but
highly controversial practice, which has inspired a surfeit of sophisticated scholarly
studies in the last twenty years.1 Within this literature, two main historical sati ‘episodes’
predominate: that of early-colonial Bengal, culminating with the British prohibition of
1829,2 and that of late twentieth-century Rajasthan, epitomised by the immolation of
Roop Kanwar in 1987.3 Comparatively little detailed historical analysis exists, however,
on sati between these two events.4 There has been some discussion of influential early
twentieth-century works on sati5 and the symbolic value of the rite is alluded to in the
wider historiography of gender and Indian nationalism,6 but few studies have focused
on specific sati cases and the debates that surrounded them, or attempted to unpick
their relevance for our understanding of the routes from ‘colonial’ to ‘postcolonial’
interpretations of sati. As a result, much Indian and British historiography treats the
early nineteenth-century Bengali case as paradigmatic of the colonial discourse on sati,
invoking it as the historical precedent for contemporary sati debates,7 without fully
exploring the many other trajectories the issue took, regionally and historically.8 This
paper explores British and Indian discourses on sati as they existed in late-colonial
India, arguing that sati remained an important site of contest between 1829 and 1987,
the ideological and political implications of which were embedded in specific local
and historical contexts rather than a calcified early nineteenth-century colonial debate.
By focusing on one late-colonial sati case, the burning of Sampati Kuer in Barh, Bihar,
in 1927, it will open up some of the complex historical terrain still to be negotiated
between early nineteenth-century colonial ideas and the ‘re-emergence’ of sati as an
issue in late twentieth-century India.
By the 1820s, toleration of sati had become highly problematic for the colonial
state, as evangelical and missionary campaigns rallied British public opinion against
the rite and pressed the East India Company to abolish it.9 This led, as Lata Mani has
demonstrated, to a protracted debate about the feasibility of the rite’s prohibition, its
perceived sacred status, and the nature of British religious ‘neutrality’. This debate,
Mani argues, was framed primarily in terms of sati’s scriptural sanction and was less

C The author 2008. Journal compilation
C Blackwell Publishing Ltd. 2008, 9600 Garsington Road, Oxford OX4 2DQ, UK and 350 Main Street,
Malden, MA 02148, USA.

The Burning of Sampati Kuer 229
about the ethics of burning women than it was about defining the nature and limits
of colonial control. Women were not the subjects of debate, but functioned as the
terrain on which wider issues were contested, as the complexities of female agency
were marginalised in favour of a simplistic representation of the widow as a passive
victim who needed to be saved.10 Mani’s influential exposé of the political motivations
of the colonial state has been pivotal in undermining imperialist interpretations of
sati’s ‘abolition’ as the benevolent act of a paternalist colonial regime. Her position,
however, together with that of Gayatri Spivak, who famously argues that in the case of
sati the subaltern female cannot speak,11 has been subject to critique in recent years.12
Ania Loomba, for example, argues for a more sophisticated analysis of female agency,
emphasising the need to ‘modify Lata Mani’s conclusions to suggest that women were,
then as now, the targets as well as the grounds of the debates over tradition’13 and
suggesting that ‘we can re-position the sati by looking not just at the widow who
died but at those who survived to tell the tale’.14 This paper argues that, while the
autonomous voice of Sampati Kuer herself was effectively written out of both British
and Indian accounts, the controversy that surrounded her immolation provided the
context for active female participation in the debate, provoking an early articulation
by an organised Indian women’s movement of ideas that were to inform feminist
discussions of sati in postcolonial India.
A second difficulty with Mani’s interpretation of the British debate on sati
relates to her failure to explore the divergence between the case of early-colonial
Bengal and other colonial encounters with the rite. Early nineteenth-century British
representations of sati were not the product of a static morality, but of the political and
ideological imperatives of a particular place and moment. By embedding discussions
of sati within the framework suggested for early nineteenth-century Bengal, we run the
risk of projecting this discourse beyond the context of its production and extrapolating
its terms of reference onto sati incidents in other times and places, while marginalising
other equally significant and useful colonial experiences of sati.15 Far from constitut-
ing a normative western reaction to the rite, vilification of sati in the 1810s and 1820s,
with the accompanying tropes of victimhood and barbarity, contrasted sharply with
seventeenth- and eighteenth-century interpretations, in which European condemnation
of the rite’s brutality was tempered by their admiration for the widow’s bravery and
conjugal devotion.16 Moreover, colonial debates on sati continued to develop through-
out the nineteenth and early twentieth centuries. Sati persisted legally in parts of what
is now Rajasthan until 1860 and the colonial discourse that emerged during British
attempts to eradicate the practice there demonstrated a significantly different set of
moral, political and ideological interpretations than that which had been formulated
in Bengal.17 Sati also occurred illegally throughout the colonial period in different
parts of British India and records of these sporadic criminal events18 provide a window
onto both the continuing development of colonial ideas and the emergence of contes-
tatory formations around sati that resonate strongly with postcolonial debates.19 By
looking in detail at one such sati event, this paper will emphasise the dissonance of
early nineteenth-century tropes when reproduced in the Patna High Court in 1928 and
explore the influence of other social, political and discursive trends within the con-
troversy that followed, including those that can be traced to colonial encounters with
sati outside Bengal and which resonate strongly with later rather than earlier debates.
Thus, while Kumkum Sangari and Sudesh Vaid have suggested that ‘ad hoc’ attempts

C Blackwell Publishing Ltd. 2008
230 Gender & History
to piece together a ‘modern’ narrative of widow immolation began in the 1950s,20 this
paper will argue that certain ‘contemporary’ formations on sati, including the politici-
sation of sati in Hindu nationalist debates, the commercialisation of the sati site, the
use of supernatural narratives to justify the immolation, the opposition of ‘the state’
to the glorification of sati and, most importantly, the participation of an organised and
autonomous women’s voice that saw the rite as an ideological as well as physical viola-
tion of women, can be seen in the debates surrounding this late-colonial immolation. In
doing so it will complicate the teleology between the experience of early-colonial Ben-
gal and contemporary sati discourse, representing instead a more complex historical
trajectory into which various British and Indian debates must be incorporated.
The Barh sati case

Like the burning of Roop Kanwar sixty years later, the immolation of Sampati Kuer
was a rare, but not unique event, made exceptional by its relevance to contemporaneous
socio-political debates. If the initial flurry of publicity was based on claims that the
pyre had spontaneously combusted, the longevity of public interest was due to the
controversial prosecution of the subsequent criminal case. Refracted through numerous
different agendas, a definitive narrative of the sati is elusive, but the undisputed facts are
as follows.21 On 21 November 1927 Sidheswar Pande, a Brahmin from the village of
Sartha near Barh in Bihar, died of a protracted illness. That evening, a party of sixteen
people, comprising his young widow Sampati, relatives and priests, started walking
with the body for the cremation ground on the banks of the Ganges at Barh. The party
arrived late that evening at the Sub-Divisional Officer’s court, where they spent the night
in an outbuilding. The following morning, rumours of an intended sati emerged. Police
officers attempted to intervene, eventually securing an agreement that the body should
proceed to the cremation ground without the widow, who would return to her village.
Once out of police presence, however, the widow’s party changed course and went to
the cremation ground, where Sampati bathed, changed and mounted the pyre. A large
and enthusiastic crowd gathered to witness the immolation, encouraging the widow
with shouts of ‘sati ki jai’ (long live the sati). The police, though present, were unable,
or unwilling, to forcibly remove the widow, so instead formed a cordon around the pyre
to prevent anyone lighting it. Despite this precaution, Sampati’s clothes ignited and the
pyre was soon ablaze. Not long after, both widow and corpse came, by uncertain means,
to be in the river. The police tried to rescue her, despite being urged not to interfere, and
eventually she lay down on the bank under a tree. There she remained, hideously burnt,
for more than forty-eight hours before the Sub-Divisional Officer (SDO) was able to
arrange for armed troops to remove her to the local jail for treatment. In the meantime,
the crowd had grown even larger, with motorbuses leaving their usual routes to bring
people to see the ‘satimata’ (literally ‘sati mother’, an honorific). The site took on
‘the appearance of a place of pilgrimage’ with ‘sightseers’ coming from considerable
distances.22 Sampati died at 11.30 p.m. on 25 November 1927 in the sub-divisional jail.
Local officials, keen to prevent the glorification of sati, refused permission for a public
procession and cremation, driving the body away quickly on a flower-decked lorry and
committing it to the Ganges, disappointing the large crowds who had gathered to see
the satimata’s final obsequies.

After the sati, sixteen people were arrested under section 306 of the Indian Penal
Code (abetment of suicide), of whom six were acquitted at trial. The fate of the remain-
ing ten sparked further controversy, however, when the Session Judge referred the case
to the Patna High Court, despite the unanimous verdict of ‘not guilty’ recorded by the
Indian jury. The High Court overturned the jury’s findings and sentenced the accused
to up to ten years’ rigorous imprisonment – heavy, but not unprecedented sentences.23
This verdict caused a sensation, partly because the accused were respected local pan-
dits, but primarily because of the political and ideological implications of a British
High Court judge overruling the unanimous findings of an Indian jury, an affront ex-
acerbated by the inflammatory language used in the judgment. The English-language
Bihari daily Searchlight carried a series of articles criticising the judge’s findings that
were so confrontational that the newspaper was charged with contempt of court. The
Searchlight contempt case itself caused a considerable stir, although by this point the
issues had moved beyond the parameters of an individual sati, incorporating questions
about the freedom of the Indian press and Indian self-determination in judicial and po-
litical processes. Consequently, the newspaper was championed by a number of leading
nationalists, including Motilal Nehru, who used the case to challenge the authority of
the colonial state.
Not surprisingly, interpretations of these events varied considerably. ‘The assem-
bled crowd’, the Anglo-Indian daily Pioneer reported, ‘was convinced that a miracle
had occurred, and that this woman was a true sati, and that the strength of her reli-
gious faith had kindled the fire’.24 This version of events was championed by the local
Patna-based English-language newspaper Searchlight and the more famous Calcutta
spreadsheet Amrita Bazar Patrika (hereafter ABP), both of which hailed the sati as
authentic and miraculous. Conversely, progressive publications like Gandhi’s journal
Young India,25 the Calcutta-based Modern Review26 and the Women’s India Associ-
ation journal Stri Dharma27 categorically condemned it. Colonial reports were also
conflicted. Official reports and coverage in the Anglo-Indian press rejected supernat-
ural explanations, but left issues of agency and culpability unresolved. Chief Justice
Courtney Terrell, on the other hand, told ‘the story of the crime’ unambiguously as
a premeditated plot by evil and self-interested pandits, embedding his analysis firmly
within an early-colonial interpretive framework.28 The following sections will look
in detail at the discursive contours of the Indian controversy, drawing parallels with
postcolonial sati debates, before going on to look at Terrell’s judgment as an example
of a dislocated early-colonial discourse.
Situating a late colonial sati: nationalist and revivalist discourses

As Sangari and Vaid point out, ideologies surrounding sati incorporate religious,
social and cultural beliefs into wider ‘contestatory formations that address concepts
such as Hinduism, tradition, nation or Indian history’.29 Debates surrounding individual
immolations must be situated within their historical context and the controversy over
the immolation of Sampati Kuer cannot be understood without reference to the socio-
political climate of late-colonial India. By the 1920s, Indian nationalism was a mass
movement incorporating both secular and Hindu revivalist strands. The same period
also saw the emergence of an incipient Indian women’s movement, as improvements in
female education and a loosening of patriarchal constraints among progressive groups

created space for women’s social and political involvement. Initially confined to small,
localised organisations, the emerging women’s movement reached the national level
when in 1917 the Women’s India Association (WIA) was formed to provide women
with an India-wide platform that combined support for Indian nationalism with a social
reform agenda.30 Aspirations for gender reform had, however, to mediate wider nation-
alist debates about how to reconcile ‘western modernity’, national development and
women’s emancipation with the defence of authentic Indian identity/ies.31 For some,
reform of problematic social practices like child marriage, purdah and sati was a pre-
requisite for self-rule; for others, such practices required protection and were viewed
as synonymous with what Partha Chatterjee calls the ‘inner, essential, identity of the
East’.32 Consequently, as Tanika Sarkar discusses, women’s issues were imbued with
added political significance, as the religious, cultural and domestic arenas came to
symbolise an ‘uncolonised’ private space that was jealously guarded against real or
perceived colonial incursions.33
Sati was, of course, a contested site within the ideological framework of public
and private, and Indian attitudes to both the practice and its ‘ethos’ were often ambiva-
lent.34 For some, sati was an aberration that had emerged during Hinduism’s medieval
decline from Vedic purity and as such could, indeed should, be eliminated from Hindu
culture. Gandhi saw ‘nothing praiseworthy’35 in sati, while the Modern Review called it
an ‘inhuman and barbarous practice’ that could neither be commended nor tolerated.36
Others supported the proscription of enforced immolation, but reserved space for belief
in an ‘authentic’, divinely sanctioned sati that was part of the Indian ‘tradition’ and
beyond the control of the colonial state. Voluntary sati could be an icon for Hindu
superiority; as Bankimchandra, the progenitor of modern Hindutva (Hindu National-
ism), put it:
When I think of elevated sections of women, the vision that rises is of the sati, determined to be
cremated along with her dead husband. I picture the burning pyre and in the midst of rising flames,
the virtuous woman lovingly holding to her bosom her husband’s feet. Opening out slowly, the fire
embraces one portion of her body and moves towards the other. The fire-gripped woman thinks of
her master’s feet and, in between, exhorts the assemblage to chant the name of Hari. She betrays no
trace of physical pain. Her face is joyous. Gradually the sacred flame flies up, life is left behind, and
the body reduced to ashes. Blessed is her tolerance! Blessed her love! Blessed her devotion! When
I think that, until a while back, the delicate women of my country could court death in this manner,
a new hope courses through my mind. I am convinced that the seeds of greatness are in us. Shall we
not be able to witness this greatness tomorrow?37
The image of the ‘true’ sati as a cathartic consummation of Hindu female/spiritual

ideals was not restricted to the orthodox. The ‘ethos’ of sati epitomised the stoicism,
purity and sacrifice of the nationalists’ ‘new woman’.38 Even those who rejected sati in
practice could find resonances in its feminine ideals of chastity, self-sacrifice, submis-
sion, devotion and love.39 In ‘Suttee’, Sarojini Naidu, ‘Gandhi’s poetess’, romanticised
the impulse to die with the beloved, asking ‘Why should the blossom live when the tree
is dead?’40 Even the highly critical Modern Review later carried a short story entitled
‘Suttee’ that used sati imagery to laud Indian women’s noble capacity for sacrifice.41
In the ideological sense, as an ideal of Indian femininity and an icon of Hindu
‘tradition’, sati could be publicly defended as part of the ‘private’ sphere. Of course,
by its very nature, however, sati existed in the ‘world’ as well as the ‘home’; to be
meritorious it had to be a public event, performed within the sight and with the sanction

of the community. Indeed, Radhika Singha argues that it was the very public nature
of sati and the encroachment on British public space that made it particularly noxious
to a colonial state that sought to retain for itself ‘the privilege of taking life’.42 As
a public violation of the law, sati after 1829 was inextricably entangled with issues
of criminality, law and order, jurisprudence and politics, providing a site where the
spiritual/domestic ideologies of the uncolonised space intersected with the material
jurisdiction of the colonial state.
Sati’s potential as a site of contest between Indian society and the colonial state is
apparent in most late-colonial sati cases, although actual confrontation was usually con-
fined to the local level, with communities closing ranks to hamper state intervention or
investigation. The popular resonance of sati debates was magnified in 1927–28, how-
ever, by two controversies that dominated the Indian social and political landscape.
The publication of Katherine Mayo’s pro-imperialist diatribe Mother India, with its
scathing attack on Indian social customs, caused an unprecedented controversy. As
Mrinalini Sinha demonstrates, Mother India represented a transformative moment
simultaneously provoking a defiant defence of Indian social customs and a renego-
tiation of the relationship between Indian nationalism and social reform, a response
epitomised by the debates surrounding Sarda’s Child Marriage Restraint Bill in 1927–
30.43 The announcement of the all-white composition of the Indian Statuatory or
‘Simon’ Commission, which was charged with exploring the issue of constitutional
reform and future government in India, meanwhile, was a political slight which once
again made the right to self-determination and self-representation central to Indian
nationalist discourse. Both these controversies were raging at the time of the Barh
sati, making questions of the location of authority, adjudication of criminality and
interpretation of Indian tradition highly politically loaded. Consequently, the Barh sati
controversy became a vehicle for the articulation of various nationalist, revivalist and
reformist agendas and immediate, pressing social and political concerns.
Authenticating sati: narration, politicisation and glorification

While some newspapers condemned the Barh sati, or remained relatively impartial,
Searchlight and ABP presented a strong ‘pro-sati’ narrative from the outset, depict-
ing the immolation as a miraculous modern manifestation of a glorious Hindu custom
and criticising state attempts to treat it as a criminal event. Their defence of sati as a
cultural icon resonated with their wider ideological orientation and political agenda;
both newspapers were staunchly nationalist, with Hindu orthodox perspectives on
social and communal matters. ABP had a reputation for contesting colonial interven-
tions in Indian social and religious issues; indeed, the British had criticised it for
carrying sympathetic accounts of illegal satis back in 1905.44 It is important to note,
however, that though conservative, neither Searchlight nor ABP were anti-reformist
in Tanika Sarkar’s sense of a ‘status-quoist’ revivalist-nationalism that resisted even
internal reform.45 ABP carried articles advocating moderate, sensitive Indian-led social
reforms and Searchlight actively supported the campaign to eliminate purdah in Bihar.
Indeed, Searchlight lauded Rammohan Roy for his role in suppressing the degraded
practice of involuntary sati and even conceded that ‘as the law stands at present sati,
either voluntary or involuntary, is a crime’.46 An apparently authentic, miraculous sati,
however, was a divine manifestation of Hindu woman’s virtue, devotion and courage

and provided a timely opportunity to assert the superiority of Hindu belief and pub-
licly reject colonial interventions in Hindu ‘tradition’. The mythologised narration of
Sampati’s immolation was thus in part an attempt to gain political capital by reclaiming
the ‘true’ sati as a signifier of Hindu cultural identity, as both newspapers combined
the articulation of an orthodox pro-sati discourse with their own political agendas.
Searchlight in particular utilised the sati to attack local colonial authorities and to vent
an ongoing feud with the Patna High Court, making the sati and its glorification a
distinctly political issue. Perhaps more importantly, the newspapers’ emphasis on the
miraculous allowed them to rhetorically circumvent the criminal liability inherent in
even a voluntary sati, a discursive strategy that, as Sangari and Vaid demonstrate, was
employed in the wake of many postcolonial satis47 and which had its roots, as we shall
see, in mid-nineteenth-century debates in the Rajput states, rather than in pre-abolition
Bengal.
As Sangari and Vaid argue in relation to late twentieth-century sati, in cases where
the sati is defended and revered, the process of ‘mythologisation’ starts immediately
after the immolation, with tales of supernatural occurrences reinforcing assertions of the
sati’s self-determination. The actual mechanics of the rite, usually performed by other
people, ‘are submerged in the broader, public story in which miracles are assembled
in a seamless, virtually self-creating series of events’.48 These miracles, like emphasis
on the widow’s volition, serve a dual function; they become ‘a means of concealing
and denying individual assistance and community responsibility’49 and act as evidence
of the presence of sat (a metaphysical manifestation of virtue accrued through a life
of exceptional conjugal devotion). Sat confers supernatural powers of prescience and
the ability to curse, ‘proving’ a sati’s authenticity and rendering attempted intervention
futile, as it heats up the widow’s body until she spontaneously ignites on the funeral
pyre.50 Immolation is thus not a choice, but an inspiration resulting from accumulated
sat. This supernatural ideal underpins famous sati legends like that of Rani Sati Narayani
Devi, whose temple in Jhunjhunu, Rajasthan, is the second wealthiest in India. It is also
the plot that informs the representation of most recent sati cases, as those complicit in
the sacrifice narrate it as supernatural in order enhance the prestige of the sati site and
circumvent criminal liability for the widow’s death.51
Accounts of the Barh sati in ABP and Searchlight resonate strongly with late
twentieth-century immolation narratives, interweaving ideas of supernatural interven-
tion and the widow’s autonomous ‘desire’ to die.52 Sampati is represented as a thought-
ful, pious and literate young woman, capable of independent agency and exhibiting
signs of divine inspiration. ‘On the 20th November last,’ ABP reported, ‘seeing that
her husband was about to die, the young wife of Siddheswar, who was only 18,
expressed her desire to become “sati” during the lifetime of her husband. She
retired to a room in the house reserved for the family deity, where she read religious
books and offered her prayer. As she was coming out of the room fire suddenly caught
her clothes, which, however, was soon extinguished by the members of the family’.53
Despite official suggestions that ‘local Hindu Government servants were in secret sym-
pathy, or at any rate could not screw up the courage to take effective action’,54 ABP
claimed that ‘The police authorities, her relatives and the public reasoned with her not
to sacrifice her life in that way, but all persuasion proved to no avail’.55 Formulaic
dissuasion could be disingenuous, of course, designed to reinforce rather than prevent
the immolation, and unsuccessful opposition was indispensable in proving the widow’s

volition and divine inspiration.56 The latter was confirmed by the ‘miraculous’ ignition
of the funeral pyre. In Barh, the police cordon lent credibility to claims that fire was
not externally applied for, although with hindsight one must question both the cordon’s
efficacy against a mob of thousands and the motivation behind police claims of its
effectiveness, at the time even British accounts acknowledged that nobody approached
the pyre. It is possible that Sampati lit the pyre herself, an explanation that implies her
complicity in her own destruction, but not supernatural intervention. Given her later
action in escaping the pyre, however, this seems a dubious proposition. As Sangari and
Vaid point out, however, supernatural determinants like spontaneous ignition, so crucial
to the later narration of an authentic sati, may occur in a community’s collective re-
collection, even when human hands applied the fire.57 Under the headline ‘Miraculous
Sati’, ABP stated that
The religious ceremonies over, she was seated on the pyre with the head of her husband on her
thigh. Then a very miraculous incident happened. It might be mentioned here that the police gave
her permission to become sati if the fire breaks out from her person of itself. The officers were
strictly watching that no fire be set from outside. She was reading the Gita and other religions when
all of a sudden, to the infinite surprise of thousands of spectators present on the spot, fire gushed
out of her sari and she was seen in flames.58
Similarly Searchlight wrote that she ‘sat on the funeral pyre near the head of the dead
body, with the Bhagwad Gita in her hand. She read a few lines from the Bhagwad and
then went into contemplation for a few minutes, and behold! Fire suddenly burst out
from her waist and both the bodies dead and alive were covered with smoke and flames,
which rose very high’.59
Sampati did not remain upon the pyre for long. Her apparent act of will in escaping
into the river destabilised the orthodox narrative, casting doubt on her complicity and
suggesting she was an unwilling participant in the sacrifice. At best, it implied she
could not stand the torment, invalidating the miracle – ‘true’ sati was painless – if not
her initial volition. In an attempt to maintain the immolation’s authenticity, Searchlight
reported that bystanders accidentally extinguished the pyre, prompting Sampati to try
to complete the sacrifice by drowning.60 ABP claimed that an overenthusiastic crowd
knocked the pyre and its incumbents into the water.61 Both maintained that she did
not desire rescue, inverting the meaning of her escape by using it to reinforce her
determination to die. The reality of Sampati’s physical agony which, according to
official reports, ‘must have been acute as . . . almost the whole of her back, and her
legs and thighs had been burnt, exposing the raw flesh below’62 was also elided. Both
newspapers refused to acknowledge her experience of pain.63 ‘Since 10 a.m. yesterday
she has been lying on cotton,’ reported Searchlight, ‘her body more than half burnt,
and has been in a conscious state, replying to all questions and enquiries and consoling
her sympathisers and exhorting them to remember and confide in the almighty and all
merciful. She is quite composed and serene and appears to be unaffected by the burning
altogether . . . The left half of her body is badly burned and has been besmeared by cow’s
ghee and the outer skin appears scraped. The head and heart have not been affected’.64
Both newspapers represented Sampati as lying beatific on the riverbank, surrounded by
reverential priests and onlookers, claiming that she refused to be moved and portraying
her eventual transfer to the local jail as a draconian arrest. Police reports, however,
state that she was moved in order to receive sorely needed medical attention and that

the pandits and members of the crowd initially prevented this, presumably for fear that
she might invalidate the sacrifice by surviving it.
The newspapers’ use of the supernatural to validate Sampati’s sati represents a
break from early-colonial debates. Prior to abolition in Bengal, the British differentiated
between ‘legal’ voluntary satis and ‘illegal’ coerced ones, measuring sati’s legitimacy
in terms of its scriptural sanction, within a debate that was dominated on both sides by
textual issues.65 Early twentieth-century debates over ‘traditional’ practices like child
marriage still utilised this discursive framework, but questions of textual authority are
conspicuously absent in discussions of sati. Criminalisation had changed the available
strategies of legitimisation and authentication; textual authority was irrelevant and the
widow’s volition alone was now insufficient to legitimise the sacrifice. By emphasising
the supernatural, Searchlight and ABP avoided engaging in a theoretical debate about
sati’s legality, which the colonial state had already won, instead positioning the sati
beyond the state’s temporal authority by constructing it as a miracle.66 Such strategies,
which replaced closed legal and judicial avenues with an appropriation of ‘tradition’
and popular belief, are very similar to those employed by of pro-sati groups in 1987.
These sought to shift the debate away from questions of laws, rights or even ethics, and
make the central point of contestation Hindu belief in the possibility of the supernatural
or truly ‘dharmic’ sati.67 Significantly, this sort of supernatural narration was almost
entirely absent from the debate on sati in early-colonial Bengal, where immolations
might be represented as voluntary and devout, but were rarely seen as miraculous. The
supernatural aspects of the rite did, however, feature heavily in mid-nineteenth-century
sati debates in the Rajput princely states;68 individual rulers such as Maharaja Man
Singh of Jodhpur and Maharao Ram Singh II of Kota, for example, attempted to reserve
space for the exceptional, miraculous sati within their negotiations with the British
over prohibition,69 while numerous individuals involved in illegal sati cases resorted
to a supernatural narration of events in mitigation of their crime.70 The supernatural
narration of the Barh sati thus seems to draw its precedents from Rajput rather than
Bengali debates, a fact which may suggest the influence of an emerging Marwari Rajput
community in early twentieth-century Bihar71 and which certainly underlines the need
to incorporate ideas from the non-Bengali archive into our understanding of later sati
cases.
Not all commentators on the Barh sati ascribed to a supernatural interpretation of
events, of course. For the WIA journal Stri Dharma, the question was not one of belief
in a potentially miraculous sati, but of volition and the nature of a woman’s potential
for agency within the ideological structures that informed such immolations. The WIA
was both nationalist and progressive in its politics, combining support for Congress-
led campaigns for Indian independence with the promotion gender reforms in areas
like female education, purdah and child marriage. Significantly, despite its nationalist
orientation, the WIA often couched its arguments for reform not only in terms of the
potential contribution to the strength and vitality of the emerging Indian nation, as was
the case with many male reformers, but also in terms of the intrinsic right of women to
lead happy, fulfilled and purposeful lives and to be active and acknowledged participants
in debates concerning their status.72 Its position on the Barh sati thus reflects its belief
that women were not only objects to be physically protected, but also ‘rights-bearing
subjects’73 to be empowered:

A young girl of Bihar committed sati. When the flames became intolerable she jumped into the
Ganges, but was rescued. After two days and nights of agony she died. Sufferings such as these,
which gave a thrill of horror to all civilised sensibilities elicits the following remark from the
Searchlight of Bihar “Sati represents the acme of moral perfection and its whole merit is based on
its voluntariness”. There is no voluntariness in conduct to the extent that it is wrought in deception.
It is deception to tell uneducated young girls that their husbands are their gods however devoid of
merit, and that to mount their funeral pyre is the surest way to heaven. There is no voluntariness
in action to the extent it is induced by pressure. Public opinion is a mighty pressure, and in olden
days there were millions like the writers to the Searchlight who pointed to widows the funeral
flames of their husbands as the best place for them. There is no voluntariness in deeds to the extent
they are inspired by fear. The fear inspiring is the suffering and humiliation that Hindu Society has
reserved for widows who elect to live. One may also consider how many men have followed “the
acme of moral perfection” which they so easily preach to women, and mounted the flames of their
wives. ‘Voluntary’ self-torture seems never popular with those who have the liberty to do what they
please. Do women have that liberty? “No liberty for women” says the Code of Manu. Spirituality is
often distinct from the practice of religion and ceremonial. The histories of religion and crime have
therefore many coinciding points - Sati is one. Also, religious men are often the worst criminals.
When wickedness stoops to cruelty, cowardice seeks exculpation in ceremonies and religion.74
Stri Dharma’s use of this case to interrogate the ‘reality’ of women’s so-called volition
in sati reflects its concern with women as potentially autonomous agents working
within and against oppressive patriarchal structures.75 The WIA response to the Barh
sati was the first time that an organised women’s voice was raised against the practice
of sati and we can see the genesis of the postcolonial feminist response, so crucial in
the Roop Kanwar controversy, in its positioning of even ‘voluntary’ sati as an issue
of ideological subjugation as well as physical violation. Compare, for example, Stri
Dharma’s position with the comments of Rani Chuhrawat in 1987 that
If a woman does not have the right to decide whether she wants to marry, and when, and whom,
how far she wants to take a particular job or not – how is it she suddenly gets the right to make
such a major decision as whether she wants to die . . . Given women’s general powerlessness, lack
of control over their own lives, and definition of their status by their relationship to men . . . can
any decision of theirs, particularly such a momentous decision, really be called voluntary and self
chosen?76
Although Stri Dharma’s critique was not produced until 1928, tensions over how
to interpret the sati began immediately after the event, when the Sub-Divisional Officer,
keen to ‘prevent any commemoration of this revolting episode’77 refused to hand the
body over to a quickly set up ‘sati committee’78 for a public procession and ritual
cremation. The government praised his actions, but Searchlight and ABP both attacked
his failure to facilitate public veneration of the satimata. ABP complained that the
haste with which the body was driven away caused the ‘procession’ (which had formed
in contravention of official orders) to break up, lamenting that ‘The music and the
musicians, flags, etc. were all left behind. The bhajan party could not sing’.79 This
was, of course, the SDO’s intention, but the ABP maintained that the people had been
deprived of their right to pay homage to the sati, asking
What business or right had the SDO or the police to interfere in the discharge of religious rites
and ceremonies? It was the main and only duty of police officers to make proper arrangements to
regulate the traffic on the roads in such a way that everyone might have a good view of the satee
[sic]. This was not done. The people were left to move disorderly. Numerous respectable gentlemen
and ladies with photographers and pandits came from Patna and they were very much disappointed,
as the immersion of the dead body had taken place before they arrived.80

Colonial opposition to the glorification of sati was not a facet of the early nineteenth-
century debate in Bengal; indeed, the local government in Calcutta even allowed the
building of a sati temple there in 1832, only three years after the rite’s prohibition.
There is evidence, however, that British officials in Rajputana sought to prevent the
commemoration of individual satis after the rite was outlawed there, again suggesting
the influence of non-Bengali strands of the colonial debate on the interpretation of later
sati cases. The emphasis on glorification as a site of conflict in 1927 also mirrored
tensions between the divine and the criminal that were to be a central issue during the
Roop Kanwar controversy, when government failure effectively to prevent the celebra-
tion of the chunari (veil burning) ceremony caused controversy and led eventually to
the passing of the Glorification of Sati (prevention) Act in 1988.
Concern with the glorification of sati suggests a desire not only to criminalise
the act, but also to control the spirit of the belief. It was also closely connected to
the economies of the rite. The British had discussed the pecuniary implications of sati
in early nineteenth-century Bengal, focusing on women’s inheritance rights under the
Dayabhaga inheritance system as a motivation for removing ‘inconvenient’ widows and
on rapacious priests who encouraged sati in order to receive payment for officiating at
the sacrifice and even raked through the smouldering ashes to recover the widow’s jew-
ellery. Terrell drew on these tropes when suggesting that the Barh pandits had contrived
Sampati’s death for pecuniary gain. After the immolation, he claimed, came ‘the first
fruits for which the pandits had been waiting – a stream of coins began to flow which
they greedily picked up’.81 In reality, however, the ‘commercialisation’ of the Barh
sati bore more resemblance to the late twentieth-century model than to earlier colonial
constructions. The Pioneer reported that during the forty-eight hours before Sampati
was moved ‘the cremation ground . . . resembled a fair’ and that ‘shops had been set
up’,82 events that mirror those in Deorala in 1987, when photomontage postcards de-
picting Roop Kanwar on the pyre were sold. It was also reported that Roop Kanwar’s
in-laws and local leaders collected large sums of money donated for the construction of
a temple to her, making them rich men.83 In Barh, the SDO reported that local Marwaris
wanted to build a temple to Sampati. This group has been prominent in glorifying sati in
the late twentieth century, funding the Rani Sati temple in Jhunjhunu and others across
India. As Anne Hardgrove demonstrates, satipuja (sati worship) has become a cultural
identifier for a dispersed Marwari community.84 The Barh sati coincided with a peak
in migration among Marwaris, with considerable numbers moving east and asserting
their political and cultural influence in their new home. Marwari involvement in the
glorification of the Barh sati, combined with the commercialisation of the sati site, thus
indicates a far more complex and ‘modern’ phenomenon than the Terrell’s depiction
of rapacious Brahmins grubbing around for coins in the dust suggests.
Dislocated discourse: colonial representations of the Barh sati

Terrell’s findings in the Patna High Court in June 1928 reversed the verdict of the
Session Court jury and provided a narrative of events diametrically opposed to that
of Seachlight and ABP. For Terrell, though the accused were charged with abetment
of suicide, they were guilty of premeditated and self-interested murder. ‘This is our
judgment’, he concluded,

firstly that such evildoers may be punished, secondly that an innocent girl may be avenged so far as
we can avenge her, and, thirdly, that those who will not learn by reason may be taught by fear. We
can only punish the body. I do not pretend to know if there be any survival after this life is finished,
but if so, and if God be just and merciful in the sense that we very imperfectly understand justice and
mercy, then such of these men who survive their earthly punishment may well go on a pilgrimage to
Sampati’s flower decked shrine and with ashes on their heads cast themselves down and invoke her
gentle spirit to intercede with the almighty to save their guilty souls from ever lasting damnation.85
Terrell’s rhetoric is reminiscent of early nineteenth-century rescue tropes, summed up

by Gayatri Spivak as ‘white men saving brown women from brown men’.86 Within
Terrell’s judgment Sampati was a victim, an object to be saved – or rather avenged
– completely lacking in agency. ‘The young widow was a pious, gentle Hindu girl of
high caste’, he reported, ‘She was pardanashin87 and was possessed of such rudiments
of education as that condition permits. She had no father, she had no efficient male
protection . . . and she was left therefore with only a weak-minded, superstitious boy
brother. What a victim she presented to those who were to profit by her death!’88 A child
bride, Sampati was married aged eight or ten, but the union remained unconsummated
as she did not live with her husband until she went to nurse him three months before
he died. Sampati was the epitome of the high caste virgin widow, an iconic figure in
late-colonial discourses on Hindu women, socially marginalised by the stigmatisation
of widow remarriage and, with no prospects or protector, the victim of Hindu social
practice even before her immolation. Such issues were extremely topical in 1927–
28; Harbilas Sarda’s Hindu Child Marriage Restraint Bill, designed partly to prevent
early widowhood, was debated in the Legislative Assembly in September 1927 and,
of course, child marriage was central to the Mother India controversy. The Barh sati
case thus incorporated a number of key contemporary social concerns, embodying the
paradigmatic relationship between child marriage, widowhood and sati in late-colonial
gender discourses. Although he mentioned the conditions of her life, Terrell did not
embed his judgment within the context of these contemporary social debates, however,
choosing instead to reproduce much earlier colonial tropes.
The victimhood narrative of Terrell’s judgment was constructed on the dual as-
sumptions of Sampati’s helplessness and the Pandits’ ‘malignant ingenuity’.89 The
police, he claimed, had succeeded in convincing ‘the poor, brave, weak-minded
lady . . . of the foolishness of the whole proceeding’,90 but her decision to return to
her village would have ‘spoiled the pandits’ plan’ and they ‘recaptured their victim’
before she could depart. Although Terrell acknowledged that later Sampati resisted
attempts to dissuade her, telling police that she was ‘about to become a true sati’ and
that ‘miraculous fire would appear to destroy her and the body of her husband on
the pyre’,91 Terrell believed she had been misled about the nature of the ordeal, and
that her volition was the result of delusion and indoctrination. The fatal dénouement,
he believed, was orchestrated by the pandits, who stalked Sampati like prey. He even
claimed that they contrived the pyre’s mysterious ignition using an unspecified artifice
‘simpler than a conjuror’s trick at a country fair’,92 designed to create the illusion of
heaven-sent fire and shield them from the retribution of the law. Indeed, he suggested
that they obstructed both her rescue from the river and subsequent medical intervention
to prevent the discovery of this trick from incriminating them. He depicted a helpless,
severely injured young woman held hostage by callous priests who, having planned
her murder, were now insensible to her agony and impending death, being concerned

only with reaping the financial benefit of the sacrifice and saving their own murderous
skins.
Superficially, Terrell’s representation of Sampati as victim seems to have
coincided with emerging feminist rejections of volition as a mitigating factor in sati.
Rather than draw on contemporary debates to explore the complexities of Sampati’s
potential for agency, however, Terrell relied upon relatively simplistic early nineteenth-
century imagery of the widow as passive object, incapable of rational agency and
vulnerable to Machiavellian priests.93 Terrell’s use of this pre-existing British trope
may seem unsurprising, but when his judgment is read alongside other contempo-
raneous British treatments of sati, the dissonance of his position is exposed. British
interpretations of sati were neither static nor homogenous and by the early twenti-
eth century more romantic constructions had re-emerged. ‘Sati has been much talked
about and has helped to prejudice us a great deal against India and her social cus-
toms’, commented Mrs J. Ramsey MacDonald in 1910, ‘yet it had a beautiful side –
a very romantic side. The idea that after the husband is dead the wife has no interest
in life, and that she would serve him and her own desires best if she followed him
into the other world. This is a beautiful idea’.94 As missionaries and reformers, who
once focused their vitriol primarily on sati, shifted their attention to widowhood and
child marriage, the few moments of intense agony suffered by the sati were contrasted
favourably with the drawn-out suffering, or ‘cold sati’, of the widow;95 a position
also ascribed to in some late nineteenth-century Indian women’s writing on sati and
widowhood.96
The suggestion that sati might be a rational choice, albeit within the context of
limited options, allowed the widow to be reinvested with a degree of agency. Moreover,
encounters with sati in the semi-independent states of Rajputana between 1830 and 1860
had led to a subtle shift in British attitudes. Exposure to local ideas about the nature of
sati, preconceived orientalist stereotypes about ‘martial’ Rajputs and a lack of political
authority to intervene to prevent or investigate sati meant that, while they still denounced
the practice, British officials in this period began to view the widow as the perpetrator
of sati, with her family and/or the local community guilty primarily by omission.97
Accounts of illegal satis in early twentieth-century British India suggest that this trend
continued in their own territories. British judgments in sati cases repeatedly represented
the widow as a grief-stricken, but self-determined perpetrator of sati, prosecuting others
for their failure to prevent the sati or their complicity in assisting with the ceremony,
rather than on the grounds of overt or covert coercion. In Aurangabad in 1903, for
example, the local official referred to a supposedly ‘miraculous’ immolation as a ‘pure
case of sati’, meaning that the widow had gone to her death voluntarily, having set
fire to her own clothing. Seven people were convicted and sentenced to three years’
imprisonment, solely on the grounds that they had failed to prevent this widow’s self-
willed action.98 Similarly, in a case near Patna in 1904, the Sessions Judge concluded
that the widow instigated the sati. Although evidence for her initial complicity was
no stronger than for Sampati Kuer, the judge in this case found ‘no evidence that any
pressure was brought to bear on the widow to induce her to commit sati. So far as we
know she was a free agent and the evidence indicates that she was a willing victim and
desired to be burned along with the body of her husband’.99 In one case in Hazaribagh,
Bihar, in 1930, a rescued sati was actually prosecuted for attempting the sacrifice and
sentenced to three months’ imprisonment.100

Terrell’s representation of Sampati as the passive victim of a diabolical plot had

more in common with early nineteenth-century paradigms than recent sati cases. His
choice of idiom thus needs some explanation. The precedents set by recent, local
sati cases would have enabled him to convict and sentence the accused solely on the
grounds of their failure to prevent the ceremony and their complicity in the practical
arrangements for it. He did not need to argue a premeditated plot, or present the pandits
as the melodramatic villains of early nineteenth-century discourse in order to punish
them.101 Rather, his choice of idiom suggests a wider political and ideological agenda.
Terrell was relatively new to the Patna bench in 1928, but he had already established his
credentials as a strongly pro-imperial and anti-nationalist judge – two of his other recent
judgments had caused outrage in the Bihari Press for their ‘anti-Indian’ sentiment. His
language in the Barh judgment echoes the sort of rhetoric used by Katherine Mayo
in Mother India, which deployed pre-existing stereotypes and ‘barbaric’ Indian social
customs to invoke a longstanding discourse about the role of women’s status as an
index of civilisation and fitness for self-rule. In dismissing their verdict in the Barh
sati case, Terrell commented that, while the jury members were learned men, ‘learning
connotes neither wisdom nor courage and, in our opinion, these jury men were deficient
in both these qualities, the qualities that are necessary to a jury, the qualities that are
necessary to citizenship’.102 Terrell’s judgment was thus about more than the culpability
of certain men in the burning of a young woman, it was about the very necessity for
colonial rule.
The aftermath
Terrell’s judgment caused a sensation in the Indian press. In a series of three articles,
Searchlight ferociously attacked his findings, arguing both that the judgement was not
good jurisprudence and that Terrell’s ‘alien’ interpretation of events revealed his igno-
rance about sati as an institution. Terrell’s judgment was in places confusing, unclear
and unsupported – abetment of suicide could be established, but the incorporation of an
unproved murder plot destabilised his findings, leading to accusations that he had not
applied the best principles of British jurisprudence and had addressed the case from a
standpoint of cultural superiority rather than rigorous legal investigation. Searchlight’s
criticisms were quickly picked up by other nationalist newspapers, which used the
case’s ‘extraordinary’ judgement to attack the institutions of colonial rule. ‘Even in
these degenerate days’, Calcutta-based daily Forward declared, ‘when an irresponsible
executive of India hopes to thrive by bringing the judiciary almost wholly within the
orbit of its influence, the Barh sati case will rank high among judicial decisions that ran
wholly at a tangent to the fundamental principles of jurisprudence’.103 ABP complained
that ‘the language lacks that sobriety that characterises judicial pronouncements’ and
that the ‘opinions, remarks and observations’ made during the course of it were based
on impression rather than hard evidence. Not all nationalists viewed events from this
perspective, of course. The Modern Review held that ‘the accused have been rightly
punished’ and attacked Searchlight for its defence of sati, while Stri Dharma, as we
have seen, also opposed Searchlight’s position. That said, the number of attacks on
the judgment from the wider nationalist press, and their support for Searchlight during
the subsequent contempt of court case, demonstrated how far beyond the parameters
of an individual sati the debate had moved. Opposition to the judgment in newspapers

like Forward concentrated on deficiencies in the judgment rather than reverence for
sati, while the defence offered by Motilal Nehru’s team in the Searchlight contempt
case nowhere attempted to defend sati, basing its argument entirely upon issues of the
freedom of the press and using the case to attack the structures of British rule.
If the wider nationalist response privileged secular judicial arguments, Search-
light itself also accused the Chief Justice of basing his judgement on ‘a wholly
misconceived notion about the institution of sati’,104 arguing that, as a ‘stranger’ to
India, he could not ‘appreciate the psychology behind that institution’.105 Terrell’s pre-
conceived ideas about sati were said to have affected his judgment, influencing him
more than the facts of the case, while his denunciation of sati as ‘the belief of savages’
was an unwarranted attack on the sentiments of the Hindus. ‘Not being able to con-
ceive of a purely voluntary sati,’ Searchlight declared, ‘instances of which are daily
sung of in every Hindu home and belief about which is ingrained in the fibre of every
Hindu woman, it is scarcely surprising that His Lordship should form the opinion that
Sampati was deliberately victimised’.106 Searchlight thus both contested Terrell’s
authority to speak on Hindu socio-religious issues and discursively positioned sati
with the domestic/spiritual sphere, which must be protected from colonial incursions.
In 1927, as in 1987, sati was defended against those outside the fold of orthodox Hin-
duism; Searchlight maintained that sati ‘invokes the profound reverence of all Hindus
who have not divested themselves of their age-long culture’107 and attacked Terrell
as ineligible to pass judgment on Hindu customs.108 In doing so, it was propagating
its own political agenda, attacking colonial rule and asserting its position on socio-
cultural identity issues. The assumption that any anti-sati position was inconsistent
with the true cultural identity of Hindus foreshadows the position of pro-sati groups
in 1987, which dismissed anti-sati protestors as degenerate, westernised colonialists,
incapable of comprehending an authentically Indian view of sati.109 ‘People who
accept that this life is the beginning and the end,’ the editor of Jansatta wrote after the
Roop Kanwar case, ‘and see the greatest happiness in their own individual happiness
and pleasure, will never understand the practice of sati . . . The practice of sati should
now be totally re-examined. But this is not the right of people who neither know, nor
understand the faith and belief of the masses of India’.110 In both cases, sati was used
to define the boundaries of an ‘authentic’ Hindu community, with lines of inclusion
and exclusion being drawn not only between Indians and British colonists, but also
between progressive-reformist and orthodox-revivalist sections within Indian society.
Given that members of the WIA were referred to as ‘ladies strayed out of the ancient
Indian manner of feminine ideal and conduct’ by orthodox members of the Legislative
Assembly,111 we can perhaps begin to trace the emergence of the ideological divisions
within the Hindu polity that inform the contemporary debate.
As Romila Thapar has argued for the Deorala case,112 the Barh sati differed from
other contemporaneous instances of sati not because of the specifics of its performance,
but because of the attempt by certain sections of the community to justify it at a spe-
cific historical juncture. Dominant social and political concerns coalesced to make the
events surrounding this immolation and its prosecution particularly relevant, as the
immolation became a site on which a revivalist-nationalist defence of Hindu identity
intersected with the criminal jurisdiction of the colonial state. The unprecedented scale
of the controversy demonstrates its relevance to immediate political concerns; it pro-

vided an opportunity to challenge the judicial structures of the imperial state, contest
colonial interventions in Hindu society and culture and assert the right of the Hindu
nation to locate its own traditions within an Indian interpretative framework. In this
sense, the significant question was not whether Sampati Kuer was murdered or not,
but who had the right to adjudicate that fact – a particularly poignant question that
coalesced with broader concerns about Indian self-determination and self-rule in the
context of ongoing controversies over India’s political (Simon Commission) and social
(Mother India) voice. Searchlight repeatedly criticised the Chief Justice for not seeking
the assistance of one of his Indian colleagues, ‘for that at least would have saved him
from findings and observations which no one familiar with Hindu sentiments would
come to for a moment’.113 By doing so, it created space for its own relevance as an
authoritative social commentator and emphasised the need for Indian self-rule. The
rejection of Terrell’s eligibility to overrule an Indian jury thus reflected a larger rejec-
tion of the colonial state’s right to speak for India in religious, social and political issues.
As Lata Mani has pointed out in relation to the early nineteenth-century debate, and
as was the case in the politicisation of Roop Kanwar’s sati, the controversy surround-
ing the immolation of Sampati Kuer was about far more than the burning of a young
woman, it also provided a context in which issues of tradition, identity and nation could
be contested. The significance of the Barh sati case, however, goes beyond its utility
in illustrating this important, but well-known proposition. The Barh sati controversy
represented a transitional moment between colonial and postcolonial constructions of
sati’s social and political implications, incorporating aspects not only from the colonial
encounter with sati in early nineteenth-century Bengal, but also from debates on sati in
other parts of India at other times. Indeed, the dissonance of early nineteenth-century
paradigms projected outside the context of their production is thrown into sharp relief
when read against the political, ideological and commercial pressures that informed
the treatment of the Barh sati. The divisions created by the sati did not reproduce neat
bifurcations between coloniser and colonised, reformers and revivalists that informed
the framework of the early nineteenth-century debate. Instead, it created a num-
ber of overlapping and opposing spaces, in which early nineteenth-century tropes,
Rajput debates, contemporaneous British interpretations, revivalist discourses, emerg-
ing feminism and secular nationalism interacted in a complex matrix of alignments
and oppositions. Perhaps most significant, however, was the emergence of a distinc-
tive, organised female voice against sati during this debate, which presented sati as a
‘women’s rights issue’ to be understood for its ideological as well as physical impact
on women as autonomous, individual, rights-bearing subjects, rather than as victims
or objects to be saved.
Notes
This article is drawn from wider doctoral and post-doctoral research carried out at the University of Edinburgh
between 1999 and 2006. I would like to thank the Arts and Humanities Research Board, Economic and Social
Research Council, British Academy, Carnegie Trust for the Universities of Scotland for the various funding
contributions that have made this work possible. I would also like to thank Markus Daechsel for his comments
on an earlier draft of the paper, as well as various anonymous reviewers for their insightful comments. Any
deficiencies that remain are, of course, entirely my own.
1. For general studies, see Joerg Fisch, Burning Women: A Global History of Widow-Sacrifice from Ancient
Times to the Present (London: Seagull, 2006); Sakuntala Narasimhan, Sati: Widow Burning in India (New

Delhi: HarperCollins, 1998); Arvind Sharma, Sati: Historical and Phenomenological Essays (Delhi:
Motilal Banarsidass, 1988); Romila Thapar, ‘In History’, Seminar 342 (1988), pp. 14–19; Catherine
Wittenberger-Thomas, Ashes of Immortality: Widow Burning in India (New Delhi: Oxford University
Press, 2000).
2. See Vasudha Dalmia, Orienting India: European Knowledge Formation in the Eighteenth and Nineteenth
Centuries (New Delhi: Three Essays Collective, 2003); Lata Mani, Contentious Traditions: The Debate
on Sati in Colonial India, 1780–1833 (Berkeley: University of California Press, 1998); Anand Yang,
‘Whose Sati? Widow-Burning in Nineteenth Century India’, Journal of Women’s History 1:2 (1989),
pp. 8–33; Gayatri Spivak, ‘Can the Subaltern Speak? Speculations on Widow Sacrifice’, in Patrick Williams
and Laura Chrisman (eds), Colonial Discourse and Post Colonial Theory (Hemel Hempstead: Harvester
Wheatsheaf, 1994), pp. 66–111.
3. See Kumkum Sangari and Sudesh Vaid, ‘Institutions, Beliefs, Ideologies: Widow Immolation in Contempo-
rary Rajasthan’, in Kumari Jayawardena and Malathi De Alwis (eds), Embodied Violence: Communalising
Women’s Sexuality in South Asia (New Delhi: Kali for Women, 1996), pp. 240–96; Veena Oldenburg, ‘The
Roop Kanwar Case: Feminist Responses’, in John Stratton Hawley (ed.), Sati: The Blessing and the Curse
(Oxford: Oxford University Press, 1994), pp. 101–30; Madhu Kishwar, Off the Beaten Track: Rethinking
Gender Justice for Indian Women (Delhi: Oxford University Press, 1999); Mala Sen, Death By Fire: Sati,
Dowry Death and Infanticide in Modern India (London: Weidenfeld and Nicolson, 2001); Kamala Bhasin
and Ritu Menon, ‘The Problem’, Seminar 342 (1988), pp. 12–13.
4. Some feminist scholars make this dichotomy explicit, seeing Roop Kanwar’s immolation as ‘reopening’
a debate that was satisfactorily settled in 1829: see Oldenburg, ‘The Roop Kanwar Case’, p. 104; Bhasin
and Menon, ‘The Problem’, p. 12. For a more nuanced analysis of the links between early colonial and
contemporary debates, see Ania Loomba, ‘Dead Women Tell No Tales: Issues of Female Subjectivity,
Subaltern Agency and Tradition in Colonial and Post-Colonial Writings on Widow Immolation in India’,
History Workshop Journal 36 (1993), pp. 209–27.
5. Edward Thompson, Suttee: A Historical and Philosophical Enquiry into the Hindu Rite of Widow-Burning
(London: Unwin, 1928); Anand Coomaraswamy, ‘Sati: A Vindication of the Hindu Woman’, Sociological
Review, April 1913, pp. 117–35. See Loomba, ‘Dead Women Tell No Tales’, on Thompson; Ashis Nandy,
‘The Human Factor’, Illustrated Weekly of India, 17 January 1988, on Coomaraswamy.
6. E.g., Sudhir Chandra, The Oppressive Present: Literature and Social Consciousness in Colonial India (New
Delhi: Oxford University Press, 1992); Anshuman Mondal, ‘The Emblematics of Gender and Sexuality
in Indian Nationalist Discourse’, Modern Asian Studies 36 (2002), pp. 913–36.
7. See Dalmia, Orienting India.
8. See Fisch, Burning Women, for a brief overview of the intervening period, and Andrea Major, ‘Self-
Determined Sacrifices? Victimhood and Volition in British Constructions of Sati in the Rajput States
1830–60’, History and Anthropology 18 (2006), pp. 313–25, for sati in the princely states.
9. See Mani, Contentious Traditions, pp. 121–57; Clare Midgley, ‘Female Emancipation in an Imperial
Frame: English Women and the Campaign against Sati (Widow-Burning) in India, 1813–1830’, Women’s
History Review 9 (2000), pp. 95–121; Andrea Major, Pious Flames: European Encounters with Sati
1500–1830 (New Delhi: Oxford University Press, 2006).
10. Mani, Contentious Traditions.
11. Spivak, ‘Can the Subaltern Speak?’
12. Mani later qualified her position by stressing that the inability to trace an autonomous female voice in the
colonial archive does not necessarily mean that we have to concede ‘to colonial discourse what it, in fact,
did not achieve – the erasure of women’. Cited in Loomba, ‘Dead Women Tell No Tales’, p. 219.
13. Loomba, ‘Dead Women Tell No Tales’, p. 222.
14. Loomba, ‘Dead Women Tell No Tales’, p. 223.
15. The proclivity of some scholars to do this may reflect a wider tendency within ‘colonial studies’ to give
disproportionate emphasis to Bengal in understanding pan-Indian experiences and to construct ‘grand
narratives’ out of specifically nineteenth-century events.
16. See Kate Teltscher, India Inscribed: European and British Writing on India, 1600–1800 (New Delhi and
Oxford: Oxford University Press, 1995); Poompa Banerjee, Burning Women: Widows, Witches and Early
Modern European Travellers in India, (New York: Palgrave, 2003); Major, Pious Flames.
17. Major, ‘Self-Determined Sacrifices’, p. 314.
18. See National Archives of India, Home Department Records (HDR), 1862–1947, files on sati.
19. Studies of illegal satis in British India are few and far between. Fisch gives some empirical detail on sati
in British India after prohibition in Burning Women, while Andrea Major, Sati Sovereignty and Social
Reform: British Colonialism and the Campaign against Widow-Burning in the Princely States, (Calcutta:

Anthem Press, forthcoming 2008) discusses British involvement in policing and prosecuting sati in the
Rajput states, 1830–60.
20. Sangari and Vaid, ‘Institutions, Beliefs, Ideologies’, p. 245.
21. This narrative of events is constructed from points agreement between official records in HDR/Police,
file 114/27, 1927; the Anglo-Indian Press, especially ‘Woman Attempts Suttee’, Pioneer, 28 November
1927 (Pioneer, 28/11/27); orthodox Indian press, including ‘Miraculous Sati’, Amrita Bazar Patrika,
29 November 1927 (ABP, 29/11/27) and ‘Sati at Barh’, Searchlight, 28 November 1927 (Searchlight,
28/11/27); Chief Justice Courtney Terrell’s High Court Judgment, 13 June 1928 (Judgment, 13/06/28).
22. HDR/Police, file 114/27, 1927.
23. The average sentence in late-colonial sati cases was four to five years, but sentences of ten years were not
unheard of. See HDR, 1862–1947, files on sati.
24. Pioneer, 28/11/27.
25. See Mohandas K. Gandhi, ‘A Twentieth Century Sati’, Women and Social Injustice (Ahmedabad; Nava-
jeevan Press, 1947).
26. Modern Review 44, July 1928.
27. Stri Dharma 11:10, August 1928, pp. 207–8.
28. Judgment, 13/06/28.
30. For an excellent overview of both the emerging women’s movement and women’s involvement in the
nationalist campaign, see Radha Kumar, The History of Doing (Delhi: Kali for Women, 1993).
31. Partha Chatterjee, The Nation and its Fragments (Princeton: Princeton University Press, 1993), pp. 237–9.
32. Chatterjee, The Nation and its Fragments, p. 238.
33. Tanika Sarkar, Hindu Wife, Hindu Nation (New Delhi: Permanent Black, 2001); see also Anupama Roy,
Gendered Citizenship (New Delhi: Orient Longman, 2005).
34. See Nandy ‘The Human Factor’, p. 22, on the difference between sati as practice and sati as ideology in
contemporary sati debates.
35. Gandhi, ‘A Twentieth Century Sati’.
36. Modern Review 44, July 1928.
37. Cited in Chandra, The Oppressive Present, p. 112
38. Chatterjee, The Nation and its Fragments, p. 127.
39. See Shakuntala Rao, ‘Woman-as-Symbol: The Intersections of Identity Politics, Gender, and Indian
nationalism’, Women’s Studies International Forum 22 (1999), pp. 324–5 on the contradictions inher-
ent in Gandhi’s rejection of sati as an act, but espousal of ‘satihood’ as an ideal of purity and sacrifice.
40. Sarojini Naidu, ‘Suttee’, The Golden Threshold (London: William Heinemann, 1905).
41. Modern Review 44, September 1928.
42. Radhika Singha, A Despotism of Law: Crime and Justice in Early Colonial India (New Delhi: Oxford
University Press, 2000), p. 118.
43. Mrinalini Sinha, Specters of Mother India: The Global Restructuring of an Empire (London and Durham:
Duke University Press, 2006).
44. See HDR/Public, file 170, 1905.
45. Sarkar, Hindu Wife, p. 192.
46. ‘The Sati Case’, Searchlight, 24 June 1928.
47. Sangari and Vaid, ‘Institutions, Beliefs, Ideologies’.
50. See Lindsey Harlan, Religion and Rajput Woman: The Ethic of Protection in Contemporary Narratives
(Berkeley: University of California Press, 1992).
52. For more on the importance of ‘desire’ in colonial and postcolonial debates, see Loomba, ‘Dead Women
Tell No Tales’, pp. 216–26.
53. ABP, 29/11/27.
54. HDR/Police, file 114/27, 1927.
55. ABP, 29/11/27.
56. See Major, ‘Self-Determined Sacrifices?’, p. 319.
58. ABP, 29/11/27.
59. Searchlight, 28/11/27.

61. ABP, 29/11/27.

62. HDR/Police, file 114/27, 1927.
63. For more on the significance of pain in postcolonial sati discourses, see Rajeshwari Sunder Rajan, Real
and Imagined Women: Gender, Culture and Postcolonialism (London: Routledge, 1993).
65. Mani, Contentious Traditions.
66. The power of this perspective was confirmed when the all-Hindu jury at the Sessions Court acquitted all
the accused on the grounds that the sati might have been genuine. Although culpability for lighting the
pyre could not be proved, this was not essential for a prosecution for abetment of suicide and there was
ample evidence that the accused were involved in other aspects of the immolation. The jury’s failure to
convict suggests slippage in the legal interpretations of sati, potential belief in authentic immolation and a
political rejection of state incursions into Hindu ‘traditions’. The closing of community ranks to hamper
the investigation and prosecution of the Barh case mirrors the secular Indian state’s failure to convict any
of the forty-five accused in the Roop Kanwar case, even though thousands witnessed the immolation.
67. M. P. Rege ‘Editorial’, in New Quest, September–October 1987, pp. 259–60.
68. See Major, ‘Self-Determined Sacrifices’, pp. 320–21.
69. Major, Sati Sovereignty and Social Reform.
70. Major, Sati Sovereignty and Social Reform.
71. This group, originally from the Shekhewati region of what is now Rajasthan, was prominent in the aftermath
of the Barh sati, as indeed they have been in many post-colonial sati debates.
72. See Andrea Major, ‘Mediating Modernity: Colonial State, Indian Nationalism and the Renegotiation of
the “Civilising Mission” in the Indian Child Marriage Debate of 1927–1932’, in Michael Mann (ed.), From
Improvement to Development: British Colonialism and the Civilising Mission (Calcutta: Anthem Press,
forthcoming 2008) for more on Stri Dharma’s position on child marriage.
73. Sinha, Specters of Mother India, p. 13.
74. Stri Dharma, 11:10, August 1928, pp. 207–8.
75. Sati was often invoked in progressive gender reform debates as an indicator of the oppression of women
involved in an uncritical or reactionary acceptance of Hindu ‘tradition’, while the rite’s prohibition was
presented as setting a precedent for further social reform (see e.g., Cornelia Sorabji’s letter to the Times,
4 August 1936). The Barh sati case was, however, the first time that the WIA had responded publicly to a
specific sati case.
76. Cited in Kishwar, Off the Beaten Track, p. 64.
77. HDR/Police, file 114/27, 1927.
78. After Roop Kanwar’s immolation, another ‘sati committee’, the Sati Dharm Raksha Samiti, was set up to
defend the sati.
79. ABP, 29/11/27.
80. ABP, 29/11/27.
81. Judgment, 13/06/28.
82. Pioneer, 28/11/27.
83. See Oldenburg, ‘The Roop Kanwar Case’.
84. Anne Hardgrove, Community and Public Culture: The Marwaris in Calcutta (New Delhi: Oxford Univer-
sity Press, 2004) p. 248.
85. Judgment, 13/06/28.
86. Spivak, ‘Can the Subaltern Speak?’
87. A woman who observes purdah, or seclusion.
88. Judgment, 13/06/28.
89. Judgment, 13/06/28.
90. Judgment, 13/06/28.
91. Judgment, 13/06/28.
92. Judgment, 13/06/28.
93. See Major, Pious Flames, p. 161.
94. Modern Review 3:2, August 1910. Mrs MacDonald’s interpretation of sati here reflects pre-nineteenth-
century European attitudes that lauded the sati’s spirit of conjugal devotion. Such positive interpretations
were largely suppressed during the early nineteenth-century debate in Bengal, although they re-emerged
to some extent in the context of the Rajput states. See Major, Pious Flames.
95. See Harriet Lloyd, Hindu Women with Glimpses of their Lives (London: Nisbet, 1882).
96. See the extract from ‘The Plight of Hindu Widows as Described by a Widow Herself’, cited in Loomba,
‘Dead Women Tell No Tales’, p. 223.

97. Major, ‘Self-Determined Sacrifices?’, pp. 321–2.

98. HDR/Public, file 260, 1904.
99. HDR/Public, file 108–9, 1904.
100. HDR/Police, file 132/30, 1930.
101. See e.g., HDR/Public, file 77–9, 1906.
102. Judgment, 13/06/28.
103. Reproduced in ‘Travesty of Justice’, Searchlight, 3 August 1928.
109. See Sen, Death By Fire, p. 8.
110. Cited in Oldenburg, ‘The Roop Kanwar Case’, pp. 105–6.
111. Legislative Assembly Debates, vol. 1, 1929, p. 262.
112. Thapar, ‘In History’.


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Gender & History ISSN 0953-5233

The Burning of Sampati Kuer: Sati and the

Malden, MA 02148, USA.

The Barh sati case

Situating a late colonial sati: nationalist and revivalist discourses

The image of the ‘true’ sati as a cathartic consummation of Hindu female/spiritual

Authenticating sati: narration, politicisation and glorification

Dislocated discourse: colonial representations of the Barh sati

Terrell’s rhetoric is reminiscent of early nineteenth-century rescue tropes, summed up

Terrell’s representation of Sampati as the passive victim of a diabolical plot had

61. ABP, 29/11/27.

97. Major, ‘Self-Determined Sacrifices?’, pp. 321–2.

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