In his recent Republic Day address, Indian president Abdul Kalam spoke about what has become a hot topic in India today. He said:
“…There are only three members of the society who can remove corruption… They are father, mother and elementary school teacher.”
The implication of his remarks is that widespread problem of corruption in India is ultimately a problem of moral character. President Kalam is not alone in these views in India: in fact, it is a common assumption.
It cannot be denied that the average citizen encounters more petty corruption in India than in the United States. If this corruption is a factor of relative moral character, then this must imply that Americans possess a higher moral character than Indians, which results in the United States having a lower degree of corruption than India. Examining data like the Corruption Perception Index published by Transparency International
[1], we find that a number of countries ravaged by European colonization show up as some of the most corrupt. It must then be concluded that the people in all these countries are moral imbeciles, who can't distinguish right from wrong and haven't been taught so by their parents and teachers.
While President Kalam is right that parents and teachers play a key role in building the values of a child, we argue here that widespread corruption in society is not simply a function of morality. The phenomena of what is seen as widespread corruption is a failure of the system rather than simply of individuals, and it is in the transformation of the system that we must seek primary remedies.
Are Indians Immoral Or Is It The System?
Firstly, let us examine the question of morality. If it is indeed the case that corruption is a result of character flaws of Indians rather than problems with the system, then this character flaw must be widely seen even when Indians are removed from the Indian system. However, we don't find that Indians in America, for instance, are perceived to be especially corrupt. They are generally regarded as honest, hard-working entrepreneurs, employees and citizens. How is it that the same mothers, fathers and teachers, who have presumably failed in India, appear to have not done a terribly bad job when their children land in the US? Are our friends and neighbors in India really so much less moral than the people we meet in the US? Is high morality the prerogative of a particular race or religion?
That is, if individuals with similar backgrounds appear to act differently within two different systems, understanding the difference in the two systems is likely to provide clues to understanding the difference in perceived corruption in India and the United States.
A Moral Issue Or A Legal Issue?
Let us take a classic example in India of petty corruption. I have applied for a phone but the telephone linesman is demanding a payment to install it. (Recent changes have made this example somewhat dated, but that will allow useful insight.) This bribe demanded by the linesman appears to be a clear instance of corruption. Yet, one may argue – isn't this a straightforward business transaction?
[6]I'm paying for a service to the lineman and he is installing the phone. On giving the payment, I am certain that the line will be installed, it would be very unusual for the fellow to run away with my money. So, on one level, this business transaction has a high level of integrity – and in that sense, the linesman doesn't appear to be fundamentally dishonest. On the other hand, one can argue that this is clearly corruption because he is already getting paid by the government to perform this service and he is not doing his job.
But, what if we legalized that? What if the government made a regulation that the linesman could collect a fee of five hundred rupees per line that he installs? The same transaction is taking place but we have now privatized it and we would no longer call it corruption. Has the integrity of the person changed or have we merely changed the rules? Are we defining corruption simply within the bounds of legality or can we determine right and wrong beyond those bounds?
Let us take another example. Top public accounting firms in America have come under a cloud for taking consulting assignments from the companies that they were auditing. There was no law to prevent this, but after Enron broke out, this became a major scandal. It was clear that the paid consulting assignments to the auditor were a legal tactic to “grease the wheels” of the audit and this was a practice that was widely being done in corporate America. Even though this was legal, can we deny that this is a form of corruption? If we examine the moral basis, public auditors were obligated to report on corporate accounts to the shareholders and the public. Accepting paid consulting assignments from the companies one is supposed to monitor to possibly give a more favorable picture of the accounts can only be seen as a clear instance of high-level bribery.
Similarly, many of the major financial services firms in the US are being accused of inflating the stock ratings of companies that they were doing business with to the detriment of their retail clients. Internal communications in the brokerage firms showed that analysts put out buy recommendations on stocks that they did not think would perform well, simply because those companies were giving them investment banking business
[2]. Aren't the payments that the corporate clients make to the analyst firms a form of bribery for illegitimate ratings? If we were considering the moral rather than simply the legal implications of the fact that this was done by nearly all the top financial services firms, would we then be forced to admit that there is widespread corruption in corporate America?
Certainly, this becomes even more apparent in the political space. Cronyism and handing out large defense contracts to companies that have been campaign contributors has been part of the course in Washington. Money readily changes hands in Washington at the instance of special interest groups and multi-million dollar lobbying firms to buy influence. Legislative outcomes cater to the influence of big money. While this might not have the on-camera impact of a Bangaru Laxman accepting money for “the party” from the fictitious defense firm in the Tehelka setup; yet the difference might well be attributed to a lack of sophistication in comparison to the Washington counterparts rather than to any fundamental difference in morality.
Yet, even if we accept that the perceived difference in corruption between India and the US is not a question of relative morality, it is an undeniable fact that petty corruption does exist at a much higher level for the common citizen in India than in the US. If Indians are fundamentally no more “corrupt”, as a character flaw, than the people in America, why is the actual experience of the common man in India in getting basic government services like obtaining a telephone line or getting a police report filed so significantly different than the experience in America? Understanding this is a key to solving the problem of corruption that engages so many commentators in India.
Examining the System
The first major difference between the US and India is in the systems of governance. Traveling extensively in rural India, I find that the relationship and attitude of the people to the government is still that of a colonizing power, not something that either belongs to them or is in touch with their aspirations. After living in the US for many years, it is clear that there is a far higher degree of ownership and accountability of the local government to the local communities. Furthermore, the common citizen, for most of his or her needs, interfaces with the government in the local city or township rather than at the state or the national level. Power and accountability are devolved to a much greater level to the local administration. Also, American enterprise is far more privatized than is the case with India and there is less involvement of the government in daily life.
By contrast, in the Indian system, power is centralized to a much greater degree at the level of the national and state governments. Further, the centralized colonial state apparatus, right from its inception, was never designed to serve the people. As an example, the government official at the district level was called a collector, his primary role in the system was extortion, not service. Similarly, the power of the police apparatus devolved downwards as a means of control of the local population for the benefit of the rulers, not as an arm of the community for its own protection and service. The laws themselves were created and imposed in a top-down manner – and these laws were both alien to the people (the Indian penal code today is still based on the penal code created by the British in 1860, with a basis in the British system) and were created and directed for the benefit of the ruler, not the ruled. This included laws that outlawed many of the traditional sources of livelihood of the people, including textile manufacturing and metallurgy, as well as forms of traditional medicine to further the economic interests of the British.
Furthermore, even in the administrative structure, there was a clear class system. To implement the system on behalf of the rulers was the Indian Civil Service (later the Indian Administrative Service) that was originally only open to whites. Later on, the ICS also included an elite section of Indians who had been “made white” – i.e., who had gone through the colonial system of education and been indoctrinated to identify themselves with the rulers rather than the ruled. The layer of native Indian clerks and “sepoys” at the bottom were often enforcing rules and laws that they did not believe in on people who did not understand them. These natives could, of course, never rise up to the ranks of the officers or aspire to join their class.
At the top of this system was the Viceroy, drawing his authority from the Queen of England. It was a centralized and alien power structure, sprawling like a gigantic bear on the aspirations of the people. An understanding of this system and its origins is very relevant to understanding India today. This is because, despite independence and democracy, the administrative system of India remains completely continuous with colonial India (and completely discontinuous with pre-colonial India). While at the top layer the authority of the Viceroy was replaced by the authority of the elected cabinet and the Parliament, the entire structure of the government administration essentially remains colonial in its origin and attitudes.
The system in America was, ironically, also started by people who were originally English. The dramatic difference comes from the fact that America was a colony of settlement, while India was a colony of exploitation. In America, the natives were largely exterminated since the wealth of the land lay mainly in its natural resources and not in the produce of the natives and the systems of governance that evolved were what the settlers chose for themselves. In India, the wealth lay mainly in the output of the locals. The system was designed not for the settlement of the English, but for the most efficient exploitation and control of the Indians for obtaining the local produce via extortive taxation to be carted away to England
Thus, in America, the police force, for instance, evolved from the need of local communities forself-policing. Thus, as in the settlement of the West, a sheriff would be appointed by the community from within the local populace to maintain order. Thus the sheriff was a member of the community, not an imposed elite, enforcing the laws of the central rulers. In some ways, the American experience allowed for an even greater community involvement and accountability than England since it was difficult to have centralized authoritarian control in a far-flung land with different groups of settlers, even though the overall Anglican system rested on a strong belief in a centralized “rule of law” enforced and created by the authority of the Church and the Sovereign Ruler.
While coming back to the problems in the contemporary Indian system, it is worth examining briefly the system that existed in pre-colonial India. It appears that this system was far more community-based in terms of village and
jati laws than the colonial system. Even during the Mughal rule, though there were some centralized laws, the law-making and enforcement authority of the local communities were largely left undisturbed. Further, a large percentage of the local revenue remained with the local community by which local civil services – such as water resource management, education and order -- could be maintained. The local community, in many respects, devolved power upwards, to greater aggregates, rather than having a centralized power structure devolve power downwards
[3]. In colonial times, this equation was reversed with much of the local produce being taken away by extortive British taxation, causing local institutions to decay. Furthermore, a centralized system was steadily imposed that took away the power from local communities and concentrated it into the hands of government officials.
As we mention below, this system remained largely unchanged post independence, though people like Mahatma Gandhi realized the harm that the destruction of the local community had caused. While there have been some reforms in the system, in the form of the Panchayati Raj act, yet more progress remains stymied by the fact that the panchayats have very little relative authority and control over the sources of revenue, which remain in the hands of bureaucrats.
From Colonization to Socialism
The post-independence socialist system further strengthened the approach of an essential patriarchic system – where the state knew best and private enterprise was something to be controlled by spools and spools of red tape.
Along with the politicians, the popular media projected the image of the corrupt, greedy, rapacious businessman, colluding with the corrupt politician and cruelly suppressing the people. The difficulties faced by an honest businessman in the legitimate and necessary enterprise of creating wealth for himself and for the nation were rarely appreciated. In the book, `India Unbounded', Gurcharan Das, former CEO of Proctor and Gamble India, documents the insanity of the license raj that sought to reduce business to the same level of low-performance as the government. You could actually be penalized for producing efficiently or more than the allotted quota.
Even now, despite some liberalization with respect to business, there is a dramatic contrast between the ease by which one can set up a new business in the United States as compared to India. In the former case, the state is geared to assist you. In the latter case, it is often standing in the way.
Finally, both the colonial period with its widespread poverty and the breakdown of job security in traditional occupations, as well as the controlled economy of the socialist period led to the creation of a culture of scarcity. This culture of scarcity itself led to a desperation, an attitude of every man for himself, a need to break the symbolic and literal queue and get in front, since it was doubtful whether staying in the queue would get one served at all.
Thus, to the inherited colonial system was added the license raj with its opposition to private enterprise, where the rules were not designed to serve the people and encouraged a culture of scarcity where one had to circumvent the rules to succeed – and we were headed into the inevitability of what we call corruption.
The Creation Of A Parallel System
So, what does all this tell us about corruption? The first and foremost idea we must realize is that the people and the state, for well over a century, have been antagonistic to each other. The colonial government apparatus has been designed to control the people, not to support them. For the common people, the business community and even the lower-level government functionaries, the system has been both incomprehensible as well as an obstacle to their needs and desires. In this situation, the system is something that needs to be overcome and avoided rather than something to be abided by. A huge amount of creativity and energy of the people is thus expended in finding ways to circumvent the system rather than support it.
Furthermore, there is little or no performance accountability within the administrative system. It is very difficult to fire corrupt or non-performing employees, and very few rewards for honest and conscientious employees within the system. As a result, corruption is a form of subverting the system, both by the employees as well as by their customers, the general public – by creating an unofficial, but functioning system of private transactions in lieu of the dysfunctional and often antagonistic official one from the perspective of the people. This is one aspect of understanding why a large number of countries that show up at the bottom of Transparency International's Corruption Perception Index are former colonies.
Why is the unofficial system functioning? Going back to the telephone example, making a payment to the linesman will ensure that the work is done. The linesman will probably himself have a system of “revenue-sharing” with other officials and employees, as a result of which a parallel system and economy is created. What are the characteristics of this economy? That one's job will get done relatively efficiently, that the bribe-receiver will be accountable to the bribe-giver, and the people who are more productive in this system will make more money than the people who are less productive. In other words, this system partly restores the very characteristics of accountability, efficiency and recognition of performance that should be part of any well-functioning system and which is largely missing in the official system.
This does not imply that all is well. There are plenty of problems with the parallel system, including the fact that there is a high degree of overall inefficiency in having two systems -- and this ultimately is debilitating and costly for the nation. Over times, it erodes the very foundations on which the institutions of the state rest. But before we can talk of eliminating or minimizing this parallel system of bribe taking and giving, it is critical to understand the real problems with it.
One of the biggest problems with the colonial apparatus of government is that it is a corruptingsystem. That is, it is a system that is more challenging for an honest individual than for a dishonest one. How is that?
Let us take the example of an honest telephone linesman. He goes about his job installing a telephone line without demanding a bribe. The problem is that he now becomes a threat to the revenue of the unofficial system. This means that he will be targeted by his peers who are operating within the unofficial system and in the likely case of his boss being part of the “cut”, he will get transferred to some other, less privileged location, so that the unofficial system can continue unhindered. Obviously, he will also be making less money than his peers. All in all, the system will make it both harder and much less attractive for him to remain honest – that he does so will be as a result of the sheer force of his will.
Similarly, for the ambitious businessman interested in growing (and thus creating jobs), the system has stood as an obstacle. He had to succeed despite the system, not because of it. Are Indian business people fundamentally dishonest? I would say not. In fact, business in India has traditionally relied on a very high degree of trust – with word of mouth agreements often standing in lieu of signed contracts. It is this high degree of mutual integrity that has enabled Indian traders to control a majority of the world diamond trade today, for instance. Yet, like the government employee, the successful businessman has been penalized by the system, making him complicit in its corruption.
Thus, rather than fundamentally corrupt individuals, we have a corrupting system – a system in which it is more difficult and less rewarding for someone to be honest than to be corrupt. A well-functioning system is one in which exactly the opposite is true – the cost of being dishonest is far greater than the rewards of being honest. A corrupting system is corrosive to all that encounter it – it literally breeds corruption and transforms honest people into corrupt people over time. Ultimately, this corrosive system completely dissolves the integrity of the official system – to survive at all, one needs to start playing by the unofficial rules. Of course, the unofficial rules soon need their own enforcement mechanisms and the money power starts combining with muscle power. This raises the importance of non-state enforcers and the spiral into criminality begins. One can see a higher degree of such breakdown in places such as Bihar, for instance, where parallel “senas” and private justice have replaced even these non-functional state institutions.
Why then have we tended to study corruption largely as a symptom of social morality and culture? We need to remember that the larger system also consists of the institutions of education and media, all of which relate very differently to the people in the Indian context than in the United States. There is a noticeable difference between social science programs in India and the United States
in how they study their own societies. The Indian elite intelligentsia tends to study their own society largely through colonially inspired categories and lenses. As such, it is programmed to construct cultural blame for criminal acts in a way that academics in the United States are not
[4]. This creation of culture blame (and culture shame) is a phenomenon found in most colonial societies. It was an original construction of the colonizing powers that set up and controlled the institutions to make the natives easier to rule by having them accept the cultural superiority of their masters (and the relative inferiority of their own). Social science studies in India thus show continuity from colonial times and institutions and a disjunction from the people at large.
A Culture Of Entrepreneurship?
If there were a cultural generalization that can be drawn about the Indian response to a non-functioning and antagonistic system, one would hazard the generalization of Indian entrepreneurship.
Even in a repressive state-controlled economy, entrepreneurs like Dhirubhai Ambani managed to circumvent the system and succeed. People such as JRD Tata, stymied by government control at home, established industrial enterprises throughout South-East Asia. Indians that migrated throughout the world demonstrated a talent for entrepreneurship – from low-tech hotels and restaurants to the high-tech software revolution.
We needn't look only at large entrepreneurs, but at small ones as well. The unorganized sector – small businessman, traders and others -- remains a very large part of the Indian economy and employment base. From the vendors boarding buses at strategic stops selling knick-knacks to the mushrooming STD operators, people found creative ways to innovate.
In fact, large hierarchical institutions have rarely been part of the Indian ethos, whether in religion, government, or even private enterprise. Our religious ideas themselves were entrepreneurial and not controlled by large centralized hierarchical institutions, unlike Western Christianity. Our pre-colonial laws themselves were highly diverse, localized and community-based rather than all of them being handed down and enforced by a single central authority. Even functions such as the maintenance of land-records were not state-run, but managed by private individuals – the dependence of their livelihood on their reputation for honesty assured the integrity of the system. A network of specialist contractors rather than monolithic institutions managed even large projects, such as the construction of fabulous buildings or the manufacture of ships. In contemporary times, the now famous Mumbai
tiffinwalas, profiled in Forbes, distribute 175,000
tiffins a day exceeding Six Sigma quality of delivery, based solely on a network of private operators
[5].
So, we are no strangers to either free enterprise or small government. Corruption can then be regarded as forced, perverse manifestation of this spirit or even a form of dissent in the context of an alien and antagonistic system. If the system were changed to support and harness this entrepreneurial spirit rather than stymie it, the sky is the limit to what we can achieve.
Towards Change
How then do we create change in the system so that it is more responsive to the people, more fulfilling to the employees and more effective for the nation? The following steps should be considered, in order of importance:
- 1. Reducing the size of the government and privatizing non-essential functions.
- 2. De-centralizing government functions away from large hierarchical bureaucracies and creating greater local accountability.
- 3. Simplifying laws, rules and procedures, taking into account the actual needs and practices of the people and creating a greater focus on customer service in public institutions
- 4. Simplifying taxation, reducing duties on property taxes and property transfers and creating greater transparency and “buy-in” for the use of tax-proceeds by devolving more taxation and spending to local administration from the center and states
- 5. Tackling campaign finance reform – realizing that elections today involve large expenditures and creating rules for legal campaign contributions that take this into account while reducing the influence of criminal/black money
- 6. Creating a clear performance-based reward system within the government to create greater incentive for honesty and performance
- 7. More effective enforcement and prosecution of the remaining corrupt personnel to increase the cost for the corrupt
The first fact to realize is that the answer is not more rules and larger bureaucracies, but a more transparent, accountable and responsive system. One option there is simply greater privatization where market demand and competition will drive accountability. The telephone example is again a good one. If we are fundamentally corrupt, why is it that we do not have to pay a bribe in India to get a mobile phone? How would the situation have been different if mobile phones were to be a government monopoly instead? The answer is simple – in the case of competitive private enterprise, it is in the interests of the private operator to provide greater customer service – it is only in a monopoly where these interests are divergent. Some of these aligning of interests can also happen in semi-private models. In a recent journey on a local bus in Delhi, I was pleased to find courteous service and the conductor making sure that I got a ticket. Later I was told that the driver and conductor now get a percentage of the proceeds and both the quality of service and the revenue that is collected by the government has gone up as a result.
Secondly, a restructuring of government function needs to happen so that there is far greater local accountability. Let us take the example of education. Currently, appointments and administration of teachers for schools are centralized at the level of the entire state. This means that accountability flows into the state level bureaucracy that is itself only accountable to the ministers. Since the ministers are elected, it turns out that the loop of accountability to the consumers is closed only at the highest level. This is inefficient and frustrating at all levels. The teachers find that they are subject to arbitrary transfers by bureaucrats, the end consumers are not in the loop at all of teacher accountability or performance, the ministers find themselves deluged with personal requests for low-level appointments and the bureaucrats find themselves at the mercy of politicians. I recently met one of the senior-most bureaucrats in the state of Rajasthan with a reputation for honesty. A visit to his house showed that he had a very simple lifestyle. However, he was despondent about his lack of ability to make change. “Everything in this system is delegated upwards,” he said. “Even the transfer of a chapprassi will come as an order from the minister.” Clearly, the system serves no one well.
In contrast, the accountability in the US in areas of day-to-day contact of citizens, such as education or the police force, is usually far more local. School boards operate at a city or school district level. The boards are elected and accountable to the parents. Similarly, the mayor of the city and the local police chief are the highest level of authority that concern the citizens in most local matters – not state level police chiefs, secretaries or governors.
The importance of having a more performance oriented government system can also not be over-emphasized. A job that is satisfying and rewarding is itself an incentive not to look for other avenues of gratification. I was recently talking with a government executive engineer who had been posted at the Bhakra-Nangal Dam for many years. I was surprised to learn that he was a civil engineer. When I asked what work was there for a civil engineer on a dam that was constructed several decades ago, he replied laconically, “There is no work.” This is a sad commentary on the affairs of the government – what kind of performance will such a system monitor?
Taxation is another area of reform. Land and property transactions as well as local retail sales remain areas of high black money generation. There was a time when capital gains on sales of property were as high as 66%. No one in their right mind, after holding property for twenty years, would pay 66% of it in tax to the government – especially when the government appeared as a black hole of antagonistic incompetence, serving very little useful purpose. While this has been reduced, property transfers still remain expensive transaction with high stamp duties. Devolving more taxes down to the local community level, where the benefits of the government expenditures are both more visible and more accountable, will also help in this regard.
It is also worth noting that greater prosecution of corrupt officials has been placed last in this list even though it often receives the greatest emphasis from anti-corruption crusaders. This is because enforcement, while necessary, will remain ineffective in tackling the magnitude of the problem in the absence of systematic reform. At the present time, community activism can yield better long-term results when directed towards crafting a more responsive system than simply pursuing a few high-profile enforcement cases.
Similarly, continuing to harp on corruption as simply a moral problem without addressing first the issues of systemic reform exacerbates the problem of corruption rather than helping it. This is because if the problem is that we are corrupt, it becomes very difficult to change anything, since it is obviously very difficult to change who we are as people. It is no surprise that in the light of this belief, very few people in India believe that we can fix the problem of corruption. Realizing that much of it is a problem of the system can be an empowering and actionable idea, even while the road may be long.
It is worth remembering that, even with all the problems in the Indian system, it still survives and functions because there remain a remarkable number of honest people trying to do their jobs, despite all the difficulties and disincentives. It is this honesty that we must build on and nourish as we create a blueprint for deep, systematic changes.
Beyond Systematic Corruption: Re-Examining Individual Morality
While in this article we have discussed the systematic origins of petty corruption, this is not meant to imply that values are not important. It also does not imply that fixing the system will create some kind of utopia, where no corruption or criminality will occur. However well functioning the system, there will always remain criminals and outliers – no society is free from that. A dysfunctional system, however, makes it easier for criminal tendencies to come to the fore. Also, the survival of the parallel system, profitable to vested interests, is always in conflict with those that seek to uphold the primary system and not play by the rules of the secondary one. Thus the parallel system creates its own forms of extra-legal enforcement, where criminal elements readily find room, to ensure its survival.
Reforming the system can go a long way towards a different relationship between the people and the state, where it makes sense for most people to play by the rules. However, as we mentioned earlier, even societies like the US where rules are generally not set up in opposition to the people, the problem of corruption remains. Also, in any situation, there are always criminal elements that will tend towards making the quick buck irrespective of the system. Reform of the system is unlikely to change these people, but it changes the tolerance of the system towards these elements.
To tackle these kinds of corruption, which goes beyond systematic reform, we would need to return to the question of values that president Kalam spoke about, literally what a society learns tovalue. If excessive, unbalanced materialism becomes the over-arching value, with all means considered legitimate to get it and no training in self-control, then it is inevitable that there will be corruption in society. But tackling this is a question of inner transformation, where it is recognized that the legitimate human strivings for artha and kama need to be guided by dharma.
Certainly in the traditional Indian context, the teachers and the parents transmitted values. The teacher was interestingly called acharya, a word that is based on the root achar, or conduct. Thus the transmission of values was by personal example and conduct of the teacher, not by “moral science” lessons. Values were embedded in the role models of daily life.
The other form of transmittal of values is via stories and exemplars. Stories that were told by grandparents and parents during childhood also have a positive role in the creation of values. Finally, the example set by parents as well as those portrayed as “successful” role models to emulate is certainly also important. In the contemporary world, mass media is a very powerful force in the creation of samskara. In a responsible society, mass media would recognize this role rather than view its role solely as “anything goes” entertainment, blindly aping western mores or measuring its success in purely materialistic terms. But this is ultimately a matter of awakening to responsibility, not ham-handed government censorship.
So, once the systematic problems are tackled, we will be at the level of the “developed” world in terms of corruption. As we mentioned earlier, the developed world is certainly no exemplar as far as morality goes. To go beyond this, one comes back to the messages of the rishis on inner transformation. This inner transformation is ultimately what can enable us to go beyond greed, avarice and a consumerism that obsessively seeks satisfaction outside oneself to move towards “santosh”, a santosh that is ultimately the basis for the elimination of all corruption.
Notes:
[3]For a picture of Indian society in pre-colonial and early British times, the mult-volume Collected Works of Shri Dharampal are highly recommended.
[4]An interesting example is the fact that prevalent spousal killing for insurance money in the United States is not dissimilar with spousal killing for “dowry” in India. The former is not tracked or studied as a crime attributed to “culture” in the US while the latter is studied solely in that category in India. Similarly, “abortion” is treated in liberal discourse in the US as a matter of “a woman's right to choose”, while in Indian liberal discourse it is labeled as “foeticide”, to emphasize its relation to murder, and studied as a culture-attributed crime. Similarly, marriages under 18 are studied as the phenomenon of “child marriage” in India and labeled as “evil” in scholarly writing. A similar phenomenon is studied as “teenage marriage” in the US. Interestingly, even in the case of “child marriage” in India, the consummation of the marriage almost invariably happens post-puberty in India so the phenomena are not dissimilar. Interestingly, states such as Massachusetts have a legal age of marriage as low as 12, and nearly 15% of marriages in the US took place in the 15-17 age group (1970 figures).
[6]This example was first given to me by Prof. S. N. Balagangadhara in a discussion. His inspirational insight into this topic is gratefully acknowledged.
