How India's transnational repression cases expose unequal accountability across borders

Simonetta Fornasiero

Fifteen years before a guilty plea in New York exposed an Indian government employee’s alleged role in a plot to assassinate a Sikh activist, the body of a 15-year-old Bangladeshi girl hung from the India-Bangladesh border fence for hours.

Felani Khatun was shot dead by India’s Border Security Force on January 7, 2011, as she crossed the frontier with her father near Kurigram. The image of her body caught in the wire became one of Bangladesh’s most searing symbols of its unequal relationship with its larger neighbour. Yet the years that followed brought neither a final sense of justice for her family nor an end to such killings.

The scale extends far beyond the cases that became national symbols. Ain o Salish Kendra data show that the BSF shot and killed 285 Bangladeshi civilians between 2014 and February 2026, an average of nearly 24 a year. A further ten Bangladeshis were killed in BSF-linked border violence during the first half of 2026, according to the rights organisation.

That history gives Bangladesh a distinct vantage point from which to view the cases of Hardeep Singh Nijjar in Canada and Gurpatwant Singh Pannun in the United States. For Ottawa and Washington, these cases opened a relatively new debate over alleged Indian transnational repression. For Bangladeshis, the central issue is older and closer to home. When Indian security interests collide with the lives and rights of people beyond India’s borders, who is powerful enough to demand accountability?

The answer, so far, appears to depend heavily on where the victim is found.

The reckoning

In February 2026, Nikhil Gupta pleaded guilty in a Manhattan federal court to murder-for-hire and related charges in a plot targeting Pannun, a US citizen and prominent advocate of a separate Sikh state. According to the US Justice Department, Gupta acted at the direction of Vikash Yadav, who worked for the Indian government from the Cabinet Secretariat, which houses the Research and Analysis Wing (RAW), India’s main external intelligence agency. Prosecutors said Yadav supplied information about the target and agreed to a $100,000 payment. The supposed hitman was an undercover US law-enforcement officer.

The plea does not establish that Prime Minister Narendra Modi or his cabinet authorised the operation. Nor does it prove the outstanding charge against Yadav, who has not been arrested. It does, however, establish Gupta’s criminal participation and give judicial weight to the US allegation that an Indian government employee directed the plot. India has described the episode as the misconduct of an individual acting outside state policy.

The Canadian picture is more complicated. Nijjar, a Canadian Sikh activist, was shot dead outside a gurdwara in British Columbia in June 2023. Canada’s then prime minister, Justin Trudeau, later spoke of credible allegations of Indian state involvement, which New Delhi denied. In July 2026, U.S. and Canadian authorities announced charges against Lawrence Bishnoi and members of an alleged transnational criminal network in connection with Nijjar’s murder and other crimes. The Royal Canadian Mounted Police said the charges announced at that stage did not produce evidence linking Indian government officials to them.

Bangladesh’s own experience with the murder of student leader Sharif Osman Hadi provides a different but instructive comparison. Hadi was shot in Dhaka in December 2025, and Bangladeshi investigators say the principal suspects fled to India, where they were subsequently arrested. There is no public evidence that the Indian state directed Hadi’s killing. The parallel lies instead in what followed: although India and Bangladesh agreed in April 2026 that the suspects would be returned under their extradition treaty, by July Dhaka said it had completed the required legal and diplomatic formalities and was still awaiting India’s approval. The case became another test of how readily accountability can stall when evidence and suspects cross into a more powerful neighbour’s jurisdiction.

That was not a judicial exoneration of India. The prosecution of alleged gang members and the wider inquiry into foreign interference are separate questions. Canadian officials had previously alleged that Indian representatives used the Bishnoi network to intimidate or attack Sikh separatists. The defensible conclusion is not that Canada cleared India while the United States condemned it. It is that the public evidence has developed differently in the two jurisdictions, and that the Pannun case has gone further in establishing an operational link to an Indian official.

As Meenakshi Ganguly, deputy Asia director at Human Rights Watch, notes, “There are also serious concerns about transnational repression targeting diaspora Indians or foreign nationals, including those of Indian origin, for criticising the Modi administration.”

Lack of accountability

Bangladesh should resist the temptation to collapse every case into a single conspiracy. BSF shootings at the frontier arise from border enforcement, alleged smuggling and irregular crossings, but that legal distinction must not erase the question of impunity. A suspected border offence is not a death sentence, and every fatal shooting requires an independent investigation capable of producing accountability.

The figures show why this is not merely a historical grievance. Ain o Salish Kendra recorded 34 Bangladeshis killed in BSF firing or torture in 2025 — 24 in shootings and 10 allegedly following physical torture, while further deaths were reported in 2026, including two Bangladeshis killed along the Kasba border in May. In September 2024, Bangladeshi schoolgirl Swarna Das was shot near the Moulvibazar border. Like Felani, her age and the circumstances of her death transformed an otherwise routine diplomatic protest into a national symbol. Yet repeated pledges by Indian and Bangladeshi border commanders to reduce killings to zero have not produced zero deaths.

“The BSF does not operate beyond borders. But it has used excessive force to attack unarmed people, mostly Bangladeshi irregular migrants, and in some cases cattle rustlers or smugglers,” Ganguly says. “In our investigations, we have found that the troops used disproportionate force, and that the authorities failed to hold people to account for these violations.”

Lethal measures

That deterrent logic took an especially troubling form in March 2026. An internal BSF memo reportedly asked field units to assess the feasibility of using venomous snakes and crocodiles in riverine stretches where fencing is difficult, saying the proposal was “in line with Home Minister Amit Shah’s directions”. The idea had not been implemented, and former BSF director general Prakash Singh called it “silly”, warning that reptiles could not distinguish between Bangladeshis and Indians living near the border. Even as a proposal, however, it illustrates the human rights danger of treating irregular migration as a threat to be repelled through potentially lethal means rather than a matter for arrest, verification and due process.

The Indian record shows that the accountability problem is not confined to one frontier. In Manipur, petitioners asked India’s Supreme Court to investigate 1,528 alleged extrajudicial executions committed over several decades; the court held that even security forces operating under special powers could not claim immunity for excessive or retaliatory force. In Kashmir’s 2010 Machil case, soldiers were convicted by a military court of killing three civilians and presenting them as militants, although later legal developments showed how fragile such accountability could be. These cases do not prove responsibility for Nijjar, Pannun or any specific Bangladeshi death. They reveal a long institutional struggle over lethal force and effective scrutiny of security personnel.

“It is the Indian government’s lack of political will to end, or at least reduce, the number of killings at the border,” says Ali Riaz, distinguished professor of political science at Illinois State University. “It also sends a message about the unequal relationship and demonstrates a perception within the Indian establishment that Bangladeshi lives matter less.”

Power asymmetry

The contrast with the United States is stark. Washington had the jurisdiction, investigative reach and political leverage to run an undercover operation, extradite Gupta, put evidence before a federal court and secure a guilty plea. Bangladesh has no comparable leverage over Indian personnel. Its tools are diplomatic protests, border-force meetings and demands for Indian investigations — mechanisms that depend heavily on the cooperation of the same state whose agents are accused.

The unresolved effort to extradite Sheikh Hasina sharpens the same point. India and Bangladesh signed an extradition treaty in 2013 and amended it in 2016 to facilitate the transfer of fugitives. Dhaka has repeatedly sought Hasina’s return from India and renewed its formal request in April 2026 after she was convicted and sentenced to death in absentia over the 2024 crackdown. India has said it is examining the request under its legal procedures, while Bangladesh said in August that it was still awaiting a response. The treaty permits refusal where an offence is considered political or an accusation is not made in good faith, so delay alone does not establish a treaty violation. It does, however, demonstrate how political judgment can determine whether a formal legal framework produces accountability in practice.

That asymmetry was especially visible during Sheikh Hasina’s rule, when exceptionally close strategic ties with New Delhi often encouraged Dhaka to manage border deaths as irritants within a valuable relationship rather than as a sustained accountability crisis. The political rupture after Hasina’s fall has sharpened public criticism of India, but anger alone will not protect border communities.

“Unfortunately, Bangladesh has little leverage in this regard,” Riaz says. “But power asymmetry should not determine the relationship between two neighbours; it should be based on mutual respect and dignity.”

Riaz argues that India’s conduct violates international law and norms, and that responsibility does not rest with Dhaka alone.

“It is also incumbent on members of Indian civil society and human rights organisations to speak up and hold their government accountable, as it is on the international community,” he points out.

The cost of unequal relationship

Bangladesh needs a consistent policy built around transparent casualty data, prompt joint investigations, published findings, compensation for families and an agreed protocol restricting firearms to situations involving an imminent threat to life. Dhaka should press for measurable bilateral commitments and invite independent rights scrutiny.

The Nijjar and Pannun cases may not resolve every allegation against India, but they do reveal what accountability looks like when the affected state has the power to insist on it. A US court could convert intelligence into admissible evidence and a criminal conviction. On the Bangladesh border, families have too often received a body, a protest note and another promise of restraint.

Felani’s image endures because it captures the human cost of an unequal relationship in which security claims repeatedly outran legal accountability. If the Pannun prosecution has established anything of wider significance, it is that strategic partnership need not require silence when a state official is implicated in lethal wrongdoing. Bangladesh should demand no less for its own citizens.