Motilal Mallik

Motilal Mallik
মতিলাল মল্লিক
Shaheed Motilal Mallik
Born	1914 Dacca District, Bengal Presidency, British India
Died	15 December 1934(1934-12-15) (aged 19–20) Central Jail, Dacca, Bengal Presidency, British India
Cause of death	Execution by hanging
Nationality	British subject
Other names	Moti
Alma mater	Unknown
Occupation	Revolutionary activist
Organization	Bengal Volunteers
Known for	Being a member of the secretive Bengal Volunteers; accused for killing police informer Ramjan Mian
Movement	Indian independence movement
Criminal penalty	Capital punishment
Parents	Rajkumar Mallik (father) Kalitara Devi (mother)

Motilal Mallik (Bengali: মতিলাল মল্লিক) (1914–1934) was a young Indian revolutionary from Deobhog village near Narayanganj, Dhaka, who died at the age of 20. Born to Rajkumar Mallik, a poor shopkeeper, limited information is available regarding his early life. His association with the Bengal Volunteers came to light during a wave of arrests in 1934, when Governor Sir John Anderson intensified efforts to suppress anti-colonial youth activity by deploying village guards. On 19 April 1934, two revolutionaries, Sukumar Ghosh and Madhusudan Banerjee, visited Motilal’s residence. A confrontation with guards occurred as they were leaving, resulting in the death of Ramjan Mian, one of the guards. While Sukumar and Madhusudan managed to flee, Motilal was taken into custody.

Despite being subjected to harsh interrogation, Motilal declined to disclose any information about his associates. When police officials attempted to pressure his father, Rajkumar Mallik, he refused to persuade his son to cooperate with authorities. A magistrate subsequently cautioned him to prepare for Motilal’s execution. On 15 December 1934, Motilal Mallik was hanged in Dacca Central Jail, becoming one of the youngest individuals executed in connection with the revolutionary movement for Indian independence. Though he had not fired the fatal shot, he was sentenced to death for “constructive murder.” His execution has been cited as an example of how colonial legal mechanisms enabled capital punishment based on indirect involvement, raising questions about the standards of due process under British Raj.

Early life

Motilal Mallik was born to Rajkumar Mallik and Kalitara Devi in Deobhog village, near Narayanganj in Dhaka District, then part of the Bengal Presidency under British India. His father, Rajkumar Mallik, was a village shopkeeper of modest means. Very little is known about his early education or political upbringing, and most details of his early life remain obscure.

Involvement with the Bengal Volunteers

The Bengal Volunteers (B.V) was a clandestine revolutionary organization that rose to prominence in the anti-colonial struggle between 1930 and 1934, following its formative stage which began in 1928. Operating with a high degree of secrecy, the group remained largely undetected by British intelligence, which failed to identify it as a coherent body and instead attributed its activities to isolated "terrorist" actions. Members of the B.V. underwent strict training in discipline, secrecy, and confidentiality. Even under severe interrogation and physical coercion, they consistently refrained from disclosing identities or structural details, thereby maintaining the organization’s operational integrity.

Deobhog branch of BV

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At the time, Deobhog, a village located on the outskirts of Narayanganj, was largely populated by Muslimfamilies, with only a small number of Hindu households. Among the Hindu residents were Motilal Mallik and his brothers, Chunilal and Joygopal, all of whom became affiliated with the local unit of the Bengal Volunteers (BV). By 1934, as most senior members of the organization either went underground or were placed under surveillance, Motilal took on the responsibility of leading the Narayanganj branch of the group.

Motilal Mallik's personality

Motilal Mallik emerged as a prominent and unifying figure in the local community. Known for his energetic demeanour and dedication to the revolutionary cause, he played a key role in drawing several young individuals into the movement. Under his leadership, the local unit undertook grassroots initiatives aimed at fostering trust among villagers, irrespective of religious affiliation. The group extended support to residents, developed close ties within the community, and worked collaboratively with both Hindu and Muslim households, reflecting the inclusive principles that many revolutionary organizations of the period sought to promote.

Repression under Governor John Anderson

During his earlier service in Ireland, John Anderson, 1st Viscount Waverley oversaw the recruitment of World War I veterans into the Black and Tans, a paramilitary force used to suppress revolutionary activity—an approach he later adapted during his tenure as Governor of Bengal. In 1932, the colonial administration enacted a series of laws, including the Bengal Suppression of Terrorist Outrages Act, the Special Powers Ordinance, and the Criminal Law (Arms and Explosives) Act. These statutes granted broad powers of arrest and permitted life imprisonment or capital punishment for individuals found in possession of arms intended for use against British authorities.

Under Anderson’s governance, the Village Guards were established as a local auxiliary force, largely comprising individuals with prior criminal records. Their primary role was to survey and curb nationalist activities, particularly in rural areas of Bengal. According to historian Dr. R. C. Majumdar, Anderson’s administration made use of “goons and ruffians” as informants and enforcement agents in these operations.

The Village Guards, operating with the backing of the administration, were often accused of acting without accountability. Reports of arbitrary actions and harassment of villagers became increasingly common, contributing to rising tensions between the force and suspected revolutionary networks. These tensions occasionally led to violent confrontations.

The Deobhog clash (10 April 1934)

On the night of 10 April 1934, three members of the Bengal Volunteers—Sukumar Ghosh, Madhusudan Banerjee, and Motilal Mallik—met discreetly in a rural area to discuss the security of local BV operatives and formulate strategies to counter the recent deployment of village guard units by the colonial administration. After concluding the meeting, Sukumar and Madhusudan prepared to return to their base of operations in Narayanganj.

While passing through Baburail village, the group was noticed by four local men—Muzaffar Ali, Ramjan Mia, Alfazuddin, and Guljar Shah—who were on watch near a nearby residence. Acting on rumours of suspicious movements, the village guards approached and attempted to detain the three individuals. The BV members were dressed in plain clothes and barefoot, likely for purposes of stealth. When questioned, Motilal, who was locally known, sought to de-escalate the situation by explaining that the other two were simply visiting him.

From left: Motilal Mallik, Sukumar Ghosh, and Madhusudan Bannerjee.

Clash with police village guards

As the village guards attempted to search the three men, the encounter escalated. Ramjan Mia and Muzaffar Ali each seized one of the two unfamiliar individuals. In response, Sukumar Ghosh and Madhusudan Banerjee drew revolvers and fired at close range before fleeing the scene. Ramjan was fatally shot in the neck, while Muzaffar sustained a serious abdominal injury. Despite his condition, Ramjan briefly pursued the fleeing men before collapsing and succumbing to his wounds. Motilal, who attempted to draw a dagger, was apprehended by Guljar Shah with assistance from local residents Ismail Ali and Ali Mia.

A search of Motilal’s person yielded a dagger, a knuckle-duster, and a bundle containing three Balaclava style monkey caps. These items were considered evidence of plans for armed action, and the monkey caps, in particular, were associated with revolutionary activity due to their use in concealing identity during covert operations.

Motilal's arrest

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Within a short time, local constables arrived at the scene, and Motilal Mallik was taken into custody. Muzaffar Ali, despite his injuries, was transported to a hospital for medical treatment, while other individuals proceeded to file a First Information Report (FIR) at the Narayanganj thana at approximately 2:45 a.m. Subsequently, the Sub-Inspector recovered Ramjan Mia’s body, along with a torch, reportedly dropped by the fleeing assailants, and a spent bullet, which was recovered near the location of the incident. A local resident, Sayyid Akkas, proceeded to the nearby police station, located approximately a quarter mile from the scene, to report the incident. By 2:45 a.m., Officer-in-Charge Habibur Rahman had begun documenting preliminary details. Motilal Mallik was brought to the station by 3:15 a.m., along with the recovered weapons and disguise caps. A postmortem examination confirmed that Ramjan Mia had been shot at close range, with the bullet passing through his neck and lung. Muzaffar Ali, who later recovered, was found to have sustained a similar gunshot wound, fired from a distance of approximately 1 to 3 feet. A third shot was reportedly fired during the assailants' escape, according to eyewitness Afiruddin, as they fled eastward into the surrounding area.

From left: The newspapers deliberately portrayed the Deobhog clash as a communal conflict between Hindus and Muslims, whereas in reality, it was a confrontation between revolutionary activists and police guards.

Investigation and trial

The initial police investigation recovered several items of physical evidence, including a dagger, knuckle-duster, monkey cap, and a torch, reportedly dropped by the fleeing attackers. A bullet discovered near Ismail Ali's house matched the one retrieved from Ramjan Mia's body, supporting the claim that the fatal shot had been fired at the scene, rather than during a pursuit.

During interrogation, Motilal Mallik initially remained silent, later claiming that he had been attacked and had lost consciousness. At trial, his defence argued that the weapons had been planted and that Motilal had no knowledge of the incident. His counsel contended that there was no direct evidence linking him to the shooting or proving that he had prior awareness of his companions' intent to use firearms

However, Muzaffar Ali and Guljar Shah, both eyewitnesses to the incident, testified against Motilal. Their statements were corroborated by Saday Akkas, Ismail Ali, Afiruddin, and the literate constable who received both the accused and the recovered items at the police station. The case was tried by a Special Tribunal established under the Bengal Criminal Law Amendment Act (1925). The court applied Section 34 of the Indian Penal Code, concluding that the shared intent among Motilal and his companions was sufficient to establish culpability for murder, even though he had not personally fired a weapon.

In a particularly notable observation, the tribunal stated:

“The act of the man who fired the fatal shot was, in the eye of the law, just as much the act of Motilal, as if the latter had fired the shot with his own hand.”

The court considered the presence of disguise caps, the group’s armed readiness, and Motilal’s false alibi as evidence of premeditated collective intent. The fact that the two armed men escaped while Motilal, a known local figure, was apprehended was interpreted as part of a coordinated plan—his familiarity in the area was believed to have enabled him to act as a decoy, allowing the others to flee.

Despite undergoing repeated interrogation and reportedly severe physical coercion, Motilal Mallik refused to divulge the identities of his associates. His continued silence posed a significant obstacle for investigators, who remained without definitive leads regarding the two other revolutionaries, both of whom were believed to be in hiding.

Death sentence

On appeal, the case was reviewed by a Division Bench of the Calcutta High Court, comprising Chief Justice J. Patterson and Justice Cunliffe.

Following his arrest, Motilal Mallik was formally charged under multiple legal provisions:

• Section 302 IPC, read with Section 34 IPC – murder with common intention
• Section 19-E of the Arms Act – possession of a dagger
• Section 20-A of the Arms Act, as amended by Bengal Act VII of 1934, read with Section 34 IPC
• Section 19-A of the Arms Act, as amended by Bengal Act XXI of 1932, read with Section 34 IPC
• Section 120-B IPC, read with the above provisions – criminal conspiracy

On 9 August 1934, both judges upheld the conviction and confirmed the death sentence under Section 302/34 IPC.

While recognizing that Motilal was 20 years old, the court did not consider his age a mitigating factor. The bench observed:

“A man of twenty is of a sufficient age to be fully able to realize the nature of his acts.”

Chief Justice Patterson concluded that Motilal's moral culpability was equivalent to that of the person who had fired the fatal shot. Justice Cunliffe concurred, stating:

“To my mind there can be no other inference to draw from their being together and armed in the way they were armed... their joint criminal intention... was not only to defend themselves to the utmost with their weapons, if attacked, but... to commit some definite robbery under arms.”

Although the defence argued that Motilal may not have been aware of the planned violence, the court held that he had not attempted to prevent the incident, flee the scene, or warn others—factors which might have suggested a withdrawal from a shared intent. The dagger found on his person was described by the court as:

“a most murderous weapon.”

On 15 December 1934, at 6:00 a.m., Motilal Mallik was executed by hanging in Old Dhaka Central Jail. He was the last revolutionary to be executed in that facility during the period of British colonial rule, and one of only two revolutionaries hanged there. The first was Kalipada Mukherjee, who had been convicted in the assassination of Magistrate Kamakhya Prasad Sen.

Clockwise from top left: Condemned cells & gallows at Old Dhaka Central Jail.

Legal context and controversy

The case of Motilal Mallik (also recorded as Matilal Mallik) has been cited in legal and historical analyses as an example of the application of constructive liability and the use of expanded colonial statutes to impose capital punishment. Although Motilal was apprehended at the scene of the Deobhog incident, in possession of a dagger and knuckle-duster, he did not discharge a firearm nor was he found to have physically harmed anyone during the encounter. However, his presence alongside the two-armed assailants, coupled with the possession of weapons and his failure to disengage from the situation, was interpreted by the court as evidence of common intention to commit murder. This interpretation formed the basis for his conviction under Section 302 IPC, read with Section 34 IPC, and notably, Section 20-A of the Arms Act, which had recently been amended to permit the imposition of the death penalty for certain firearms-related offenses.

Painting of young Motilal Mallik by Artist Subho Dhar, it is now kept at Mahajati Sadan, Kolkata.

Mockery of law

Prior to its amendment, the Arms Act generally prescribed penalties of up to two or three years of rigorous imprisonment and did not typically permit capital punishment. However, under legislative changes introduced in 1932, the Act was modified to enable enhanced sentencing—including the death penalty—in cases where the possession of arms or participation in an armed operation was interpreted as evidence of intent to commit murder, even in instances where the accused had not personally used a firearm.

These provisions formed the legal foundation for the imposition of the death sentence on Motilal Mallik, despite undisputed findings that he had not discharged a weapon. The Calcutta High Court upheld the Special Tribunal’s ruling, relying on the legal doctrine that:

"When a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone."

This application of constructive liability became the basis for executing an individual who had not directly committed murder or inflicted physical harm, but who had been deemed to share a common intention with those who had. Subsequent legal commentary has noted that the expansive use of Section 34 IPC in conjunction with the amended Arms Act allowed the colonial administration to impose the highest degree of punishment on individuals affiliated with revolutionary organizations such as the Bengal Volunteers (B.V.), even in the absence of direct evidence of personal participation in acts of violence.

Legacy

Motilal Mallik's refusal to disclose any information during interrogation—including under reported use of torture methods such as needle-pricking of fingers and solitary confinement—prevented the authorities from identifying other individuals or uncovering the structure of the Bengal Volunteers. The organization's operations remained largely opaque to British intelligence. The Bengal Volunteers functioned with a high degree of discipline and internal secrecy. Unlike isolated revolutionary actors, they constituted a coordinated underground network. Even at the time of his death, Motilal did not reveal any details, effectively preserving the group’s internal structure and maintaining its operational confidentiality.

Pressure on Motilal's father

An additional dimension to the case involved Rajkumar Mallik, father of Motilal, who was reportedly offered a sum of ten thousand rupees and the promise of a British-sponsored education in England for his son, in exchange for securing a confession and turning state witness. His response was recorded as:

“As a father, should I teach my son to betray? Forgive me, but this is impossible for me.”

When informed that his son faced the death penalty, he is said to have folded his hands and replied:

“So be it. It's all His will. Whatever is in His heart, He knows. But knowingly commit an unjust act? Never. I'd rather believe from today that I've given my son to the nation's cause than partake in such immorality.”

This incident has been cited in various accounts to illustrate the moral tensions between colonial legal authority and personal or national ethical frameworks during the freedom movement. Though Motilal Mallik’s name did not attain wide national prominence, the legal proceedings and execution in his case have been interpreted by some historians as an example of how colonial law was used to suppress revolutionary activity. The broad application of constructive liability and amended statutes, such as the Arms Act, enabled capital punishment even in the absence of direct physical involvement in the act of violence.

In retrospective analysis, the execution of Motilal Mallik has come to represent the high personal cost of ideological commitment during a period when legal mechanisms were strategically adapted to dismantle underground resistance networks, and association with revolutionary activity could be grounds for the severest penalty.

Aftermath and retaliation attempt

Following the execution of Motilal Mallik, a group of Bengal Volunteers, including Sukumar Ghosh and Madhusudan Banerjee, conspired to assassinate Governor Sir John Anderson, whom they regarded as responsible for the enactment of repressive colonial laws and for authorizing Mallik’s death sentence. They were joined by Bhabani Prasad Bhattacharya, Manoranjan Banerjee, and Ujjwala Majumdar in planning the attempt, which was to be carried out in Darjeeling under the assumption that security around the Governor would be more relaxed in the hill station. The assassination attempt ultimately failed. Sukumar Ghosh and Madhusudan Banerjee were arrested, convicted, and sentenced to twelve years of rigorous imprisonment, after which they were deported to the Cellular Jail in the Andaman Islands.

See also

• Supati Roy
• Prafulla Dutta
• Satya Gupta
• John Anderson, 1st Viscount Waverley

Bibliography

• Hemendranath Dasgupta, Bharater Biplab Kahini, II & III, Calcutta, 1948;
• Ramesh Chandra Majumdar, History of the Freedom Movement in India, III, Calcutta 1963;
• Bengal Volunteers by Madhumanti Sengupta
• Roll of Honour by Kalicharan Ghosh
• Ami Subhash Bolchi by Shailesh Dey
• Emperor vs Motilal Mallik Calcutta High court, 1 October, 1934