Feminist anxieties about constructing vengeful heroines through rape-revenge narratives in the 1980s circle around eroticizing rape scenes and, hence, per­petuating a victim syndrome while masquerading the revenge as female agency.15 I propose that a historical approach might be helpful here. Com­paring these films to their antecedents—the classic Aradhna-style victim, or the inscription erasure in Teesri Manzil—not only plots elements of continu­ity and change underscoring the industry’s obvious generic impulse for rep­etition and difference but, more important, accounts for a broader discursive context of which these films are a part. Reverence no longer serves as sufficient compensation for the suffering victim woman.

Insaafka Taraazu16 is indeed, as Lalitha Gopalan argues, the “inaugural moment” in rape-revenge films. She, among others (Rajadhyaksha and Wille – men 1995, 416), points to the Mathura rape trial as structuring the context of Insaafka Taraazus reception. In 1979 the Supreme Court overturned a High Court ruling and freed two police constables accused of raping Mathura, a minor, in police custody. In 1978 a Muslim woman, Rameeza Bee, was raped in police custody in Hyderabad, and her husband, a rickshaw puller, was mur­dered for protesting about it. In 1980 Maya Tyagi was raped in Baghpat, Haryana, then stripped naked and walked through the streets by the police. The “rape bill”—the upshot of public shock and women’s rage—became the Anti-Rape Act in 1986 (Kumar 1994,127-42; Kannabiran 1996,32-41),

I wish to stress that context is central to understanding the avenging women subgenre. The Mathura rape trial marks the resurgence of the women’s movement in India, dormant since pre-independence. In this phase women organized spontaneously, not under male leadership; a “grassroots female mil­itancy” (Ehrenreich 1995, 85)17 forced itself onto the national agenda, using rape as a powerful trope in a national discourse on women’s subjugation by individual men and institutions. Nationwide agitations by women coalesced

to demand changes in the “rape laws.” The concatenate effect of this histori­cal moment shapes the latter-day woman’s film.

The maker of Insaafka Taraazu, B. R. Chopra, a reigning auteur in the film industry since the 1950s, has carved a special niche in Hindi cinema in his explorations of gender politics through the vicissitudes of heterosexual love. Chopra’s films often trace the liminal social space women occupy, question­ing permissible moral boundaries, even as he might carefully reinstate them. His other films that stand out in this respect are Gumrah/Deception (1967), Dhund/Fog (1973), and Pati Patni aur Woh/Husband, Wife and the Other (1978). Insaafka Taraazu, hot on the heels of the demand to reopen the Supreme Court’s judgment in the Mathura trial, bears more than an incidental rela­tion to the public discourse the verdict set off. Historically, the event marks the beginning of the (re)entry of a discourse on women’s place in the private and public spheres framed in terms of women’s rights (not reform, “uplift,” or the need to nurture special “feminine virtues”).

The nation underwent a long consciousness-raising process as women challenged and rewrote discriminatory laws on domestic violence, rape, dowry, and the growing incidence of “dowry deaths.” Family courts—instituted solely to relieve conventional courts from the burden of family disputes—and the soaring divorce rates were testimony to the serious “gender trouble” stirred up by women’s grassroots militancy. This ferment in gender relations features in popular films. Women, albeit feminized and sexualized, were once revered for their suffering. As the decades go by, however, they are increasingly capable of violence and taking control.

Insaafka Taraazu was released while the debate was still under way on new legislative measures to punish rape offenders and to replace rape laws first established during British colonial rule. The film’s heroine, Bharati18 (Zeenat Aman), winner of the “Miss India” title, is an independent career woman, working as a model and making good money to support herself and her schoolgirl sister, Nita (Padmini Kolahpure), in an apartment in Bombay. The film begins with Bharati winning a beauty contest determined by popu­lar mandate (i. e., the audience within the film). The man who awards her the highest score, Ramesh Gupta (Raj Babbar), receives the honour of placing the crown on her head.

Ramesh, a long-standing admirer of Bharati, uses his wealth to his advan­tage and makes casual efforts to be with her, while she, self-absorbed and pre­occupied with her fiance Ashok, obliges Ramesh in the routine fashion that a star obliges fans. Slighted by her lack of interest one day when he visits her, Ramesh barges into her room and, in a protracted sequence, attacks her, ties

Women’s Rage

Figure 29 Scene from Insaafka Taraazu/Scales of Justice, 1980 (with permission of Screen).

her down, and repeatedly rapes her. Bharati falls unconscious, and somewhere towards the end of this sequence her sister Nita comes home, sees Ramesh on top of Bharati, and flees the house, fearful and confused.

When Bharati reports the incident and presses charges, her lawyer warns that loopholes in the anti-rape laws make it virtually impossible to prove the rapist’s guilt. In fact the defendant’s lawyer easily reinterprets the sequence of events, casting severe doubts on her lack of “consent,” the critical issue in all rape litigation. Bharati loses the lawsuit even though her lawyer is a commit­ted and competent woman, and despite the trial’s widespread publicity. Shunned by advertising companies that can no longer afford to have her name associated with their products, and by her prospective in-laws, who cannot cope with the adverse publicity associated with her, Bharati leaves Bombay.

Dispirited and depressed, she relocates with her sister in Pune (a city close to Bombay) and takes a low-paid job as a secretary in a store selling firearms. Nita, meanwhile, interviews for a job with a prestigious firm, but the interview turns into a nightmare when the firm’s proprietor, the interviewer, is none other than Ramesh, who traps her in a room, humiliates her, and rapes her too. When Nita returns home and collapses, Bharati responds by taking a gun from the store, following Ramesh to his office, and killing him at close range, in cold blood, and in full view of his colleagues.

Bharati is arrested and tried. She refuses to hire a lawyer, choosing instead to defend herself. The court fails to recognize her due to the transformation in her appearance. In an impassioned speech about the miscarriage of justice for women, she reminds the court that she is Bharati, the model who was once raped by Ramesh Gupta. The failure to punish her rapist then, she argues, had only encouraged him to victimize another woman. In a dramatic end to the court proceedings, the judge, impressed by Bharati’s arguments, sets her free.

In Insaafka Taraazu the victim becomes vengeful and victorious not only against the man who victimizes her but also against the entire misogynist juridical system. The film examines the ramifications of rape: the fact that it is nothing but an assertion of male aggression and power; that the rape gets rehearsed both literally and figuratively in a court trial meant to punish the rapist; that the rapist gets off due to lack of conclusive evidence; that the vic­tim faces social ostracism along with acute depression and trauma in the after­math; and that the crowning act of injustice is the court setting the rapist free. The film truly centres on the woman’s narrative: the rapist’s character is not elaborated beyond the fact that he is a well-to-do, “normal,” even pleasant person, someone whose violence leaves an unsuspecting Bharati and the audi­ence shocked and dismayed.19

The narrative structure explores two possible responses to rape that pop­ular films have deployed. First, recourse to the legal process turns out to be a farce that leads to yet another woman becoming a rape victim. Second, the film valorizes a wonderful revenge fantasy: direct action and punishment followed by success in court. In the first courtroom proceedings, Insaafka Taraazu is unequivocal in condemning the juridical-legal system. As the woman lawyer tells Bharati at the outset: “It is very hard to establish rape. That is why so many rapists go unpunished. And whether or not the rapist is punished, one thing is certain, the woman definitely gets a bad name….You may not know this, but for a woman, a court case involving rape is not very different from rape.” At the same time the lawyer invokes “shame” and “honour,” qualities at stake for the shareef aurat (good woman).

Bharati’s response is firm—“I now neither care about society, nor about getting a bad name”—but she is less tough than she thinks. The defence attor­ney’s reinterpretation of her as a model, along with a photo series of her with Ramesh, resembles Barthes’s principle of writerly texts (1974,3-9).20 Her pho­tographs, he argues, demonstrate the inner logic of an alluring sex object and a “modern” woman’s permissive lifestyle. The defendant’s lawyer badgers her for her “improper” conduct, which is demonstrated by her choosing a profes­

sion in which she displays her body. When Ramesh is set free for lack of suf­ficient evidence, Bharati sinks into a depression, unable to cope either with the publicity following the debacle in court or with a job requiring her to suffuse consumer products with her charm.

It is the second time around, when Nita gets raped by Ramesh Gupta for daring to testify against him in court, that Bharati takes direct action. Nita, mak­ing a career as a stenographer, is no model selling her body. As Bharati’s lawyer states before she takes up the case, “A woman has to stand up some day and say she has the right to say, ‘No,’ and no man can touch her without her con­sent.” Yet the first half of the film obfuscates this point, particularly through Ramesh’s lawyer’s vociferous argument in court. By posing extraneous issues such as Bharati’s professional career as a model and the sexualization of her body that inheres to that career, the film implies a difficulty in demarcating consent from a woman’s prior conduct (Balasubrahmanyan 1990,107-53; Kannabiran 1996,32-41).21

Compared to both Bharati’s and Nita’s brutal rapes, involving terror, pain, humiliation, and a tortured aftermath, Bharati’s swift action against Ramesh seems painless. The film does not escalate the horror and cruelty in which Hollywood slasher films and, to a lesser extent, latter-day rape-revenge Hindi films indulge.22 What the film carefully implants, however, is a woman char­acter, once a victim but now ready to fight back. It is she (initially through a female lawyer) who takes up the fight, not her boyfriend, the police, or her father. It is worth noting that Bharati’s maternal vengeance here is on behalf of her sister.

The weakest point in the film is the last sequence, in which Bharati makes her impassioned speech in court against rape. She likens women to temples of worship: each time a woman is violated, she says, a religious shrine is des­ecrated. In the montage of visuals that accompany her soliloquy, we witness a church, a Hindu temple, and a mosque crumbling. The allusion to women as symbols of (men’s) religious communities is disconcerting, if not down­right dangerous. While the film text elsewhere attempts to undermine patri­archal ideology, here it suddenly falls into the trap of rejecting rape not because it is a uniquely perverse assertion of men’s power but because women, the victims, are likened to religious shrines. The film suddenly and unex­pectedly concludes with an insidious thesis on rape. Rather than laying bare the connection between rape and patriarchy, it ends up invoking extant patri­archal discourses within Hindu tradition that place women in binary posi­tions as the devi or dasi (goddess or slave). Holding women up as objects of reverence is posited as a counterpoint to rape rather than as a continuum within patriarchal discourse. This aspect of the film is more reprehensible than is the depiction of rape that Indian feminists protested, which I discuss later.

Clearly, despite the film ending with a tirade about reverence for women, what was new in Insaaf was that the woman, a victim such as those in the genre of Hindi films from Mother India to Aradhana, turned into a vigilante. In the 1980s the avenging woman figure became a trend: the “angry woman,” replacing the “angry man” of the 1970s. Carol Clover (1993,76), in the Amer­ican context, points to the appearance of “rape-revenge” films as popular cul­ture’s response to the women’s movement—feminism’s gift to popular cul­ture: “The marriage of rape to revenge was made in movie heaven… .Ironically enough, it was a marriage for which the matchmaker was the women’s move­ment, for in terms more or less explicitly feminist, rape became not only a deed deserving of brutal retribution, but a deed that women themselves (not cops, boyfriends, or fathers) undertook to redress.”

It was perhaps this innovation, the introduction of rape to the revenge schema, already a staple of popular Hindi cinema, that made Insaaf ka Taraazu popular, spawning a veritable new subgenre. It led the way to fusing themes of sexual violence/rape—a handy (though not exclusive) trope23 with which to excoriate and expose the pervasive violence (between classes) and corrup­tion (within institutions) that humiliated heroines avenge. Although rape appeared in earlier films it was never at the centre of the narrative, and even when it was salient, allusions to its reality were carefully repressed. The rape threat, hovering in the margin of pre-i98os films like Teesri Manzil, is seized upon and made central in the 1980s. Women exterminating men appeared in earlier films, such as Mother India and Mamta/Maternal Love (1966) (Thomas 1989).24 However, in these films women’s fury and power service conservative patriarchal ideals apotheosizing motherhood. Here women are objects of rev­erential fervour rather than agents exacting revenge in the name of wom­ankind.

Judged by its production values, Insaaf ka Taraazu is unusually poor, which comes as a surprise, given that the film was made by B. R. Chopra, a seasoned director. Aman’s method acting, meant to convey a post-rape depres­sive stupor, lacks credibility. The song sequences fill out a parsimonious story­line, in contrast with Hindi cinema’s usual multiple subplots that weave together during three hours of screen time. Furthermore, the long takes, vir­tually static camera, and flat three-key lighting make the film visually unin­teresting.