“You are Bihari, leave from here.” Six words, and minutes later, Pandav Kumar—a 21-year-old food delivery worker from Khagariya, Bihar—was shot dead. The accused, Head Constable Neeraj Balhara of the Delhi Police Special Cell, fired at close range from his service weapon, a Glock pistol.
The incident, which took place in the early morning of April 26 in Delhi’s Jaffarpur Kalan village, followed a verbal altercation between Balhara and Kumar while the latter was returning from a friend’s child’s birthday gathering. According to witnesses and the FIR statement, Balhara—allegedly in an inebriated state—began abusing Kumar and his friends after learning that the group was Bihari. The FIR records him as saying, “You Biharis have created chaos here. Everyone is building houses here and has gathered here, ruining the atmosphere, and we local residents can do nothing. But today I will set things right.”
On the surface, the aftermath of the crime has followed a predictable arc: there has been an arrest, there will be a trial, there has been ex gratia compensation from the Bihar government and outrage from the opposition. The news cycle has settled on the word “shocking”. But Pandav Kumar’s killing cannot be reduced to the psychology of one rogue constable—his prejudice, his intoxication, his failure of restraint. To do so would be to miss what the moment reveals about the deeper structure of modern urban order and the way it lays bare the fault lines of a governance logic that Indian cities have long practised, but rarely acknowledged openly—the people who build the city are the least allowed to belong to it. This piece intends to pause a little longer on those six words.
The paradox of migrant existence
The labour of migrant workers is indispensable to the everyday functioning of Delhi. This is not a rhetorical claim; it is a logistical fact. The city’s gig economy, construction sites, domestic labour market, vegetable mandis and dhabas are staffed overwhelmingly by workers from Bihar, eastern Uttar Pradesh, Jharkhand, and Odisha. They arrive with little, live in rented accommodations in the city’s unofficial settlements, and absorb its most precarious work.
Internal migration in India has exceeded 600 million people, and inter-State migrants constitute a substantial share of the workforce of every major Indian metropolis. In Delhi alone, an estimated 60 per cent of the workforce is migrant. The city’s buildings are constructed and its infrastructure maintained by the very people who have no formal claim to the city they are building. Located at the lower end of the caste and class spectrum, migrant workers form the margins of Indian cities, both territorially and socially. Many live in informal settlements or employer-provided housing that remains insecure and easily withdrawable. They labour outside the reach of most formal protections, and the city’s planning apparatus treats their settlements as temporary inconveniences, perpetually awaiting regularisation or demolition.
The margins are not simply a spatial description but a governance category—a way of ordering the city’s populations into those whose presence is legitimate and those whose presence is conditional. These margins are not incidental to the city; they are constitutive of it. The informality of migrant labour is not a transitional phase on the way to formalisation. It is one of the necessary conditions through which the city functions. Informal workers cost less, absorb greater risk, and can be discarded with minimal institutional consequence. The migrant worker’s precariousness is therefore not a failure of urban planning; it is its product.
This is where Giorgio Agamben’s (1995, Homo Sacer: Sovereign Power and Bare Life) concept of “inclusive exclusion” becomes useful. He argues that sovereign power does not simply exclude certain lives from the political order. Instead, it includes them through their very exclusion—holding them inside the system as a permanent state of exception. These lives are stripped of any legal or political standing and yet are indispensable to the order that has expelled them. Agamben calls this condition “bare life”—life that can be exploited, disciplined, and in extreme cases, even taken, without that act invoking any cognisable wrong in the political, social or moral consciousness of the people.

Jan Suraj party supporters protesting against Pandav Kumar’s killing, in New Delhi on May 3. | Photo Credit: ANI
The migrant worker in the Indian city inhabits something close to this condition. He is not outside the city—he is captured within it, but on terms that deny him full membership. His labour is inside; his personhood is outside. The city extracts one and withholds recognition of the other in the same gesture.
Seen in this light, Neeraj Balhara is not an exception. He is the locus at which this underlying paradox becomes visible – a representative of the formal city acting on a logic the city has always practised but rarely stated so plainly. His sentiment was not symbolic of only a personal pathology. It reflected a structural common sense: that the migrant worker’s presence— his accumulation, his housing, his presence in a residential space after midnight—constitutes a disorder that the city’s legitimate residents are entitled to “correct”.
The aesthetics of belonging: What the city sees
To understand what Balhara saw when he looked at Pandav Kumar and his friends, it is necessary to understand how the contemporary Indian city has come to determine who belongs in it. Asher Ghertner (2015, Rule by Aesthetics: World-Class City Making in Delhi, Oxford University Press) argues that urban governance has shifted from a rule-based rationality to what he calls “aesthetic governmentality”—an order not produced by law, but by appearance. Whether certain populations or spaces align with the visual grammar of the “desired” city marks who and what is perceived to belong in it. Illegality, in this framework, is not determined by the violation of a specific law. It is determined by appearance. What looks out of place can, at any moment, be declared an encroachment and thus removed.
This logic translates at the level of bodies as well. The migrant worker carries his spatial illegality with him—not because he has done anything illegal but because his presence in any register other than service renders him informal, out of place, incongruent.
Balhara’s response in this sense was not only ideological, it was based on an aesthetic sensibility. It was shaped by certain appearances: Bihari men at a birthday gathering, speaking their own language on a public road, simply being somewhere after midnight as persons rather than as service providers. The term “Bihari”— deployed as an insult in this context—renders certain bodies as socially and visually undesirable: labouring, lower-caste, informally housed, audible in the wrong language at the wrong hour.
Pandav Kumar was—by the city’s aesthetic logic—already “out of place” even before Balhara spoke a word. His response to being abused—asking Balhara to stop—was a transgression, a refusal to accept the verdict of his own (perceived) illegality, a refusal that cost him his life.
Who the city mourns: Politics of public grief
The public response to Pandav Kumar’s killing is itself instructive. There have been no candlelight marches, no sustained prime-time outrage, no middle-class mobilisation of the kind that followed the Nirbhaya case in 2012 or the killing of a young Pune couple in 2024 by a businessman’s son who was driving his Porsche in an intoxicated state. Those cases produced a recognisable grief—because the victims were legible to dominant middle-class sensibilities, their lives were proximate enough to the urban middle-class members to place themselves in the victims’ position.
Pandav Kumar’s life was not proximate in this sense. He was a Bihari migrant, sustaining his livelihood through platform delivery work, returning from a birthday in a village lane at 2 am. His death produced political statements and ex gratia announcements. It did not produce grief.

Family and friends of Pandav Kumar protesting in Delhi on May 3. | Photo Credit: ANI
This distinction is not incidental. Judith Butler in her work on precarious life (2009, Frames of War: When Is Life Grievable?, Verso), argues that “grievability” is not a natural response to death but is rather a politically distributed condition. Certain lives are recognised, in advance, as worth protecting: they appear in the news as full persons, with names, families, futures, photographs. Others appear, if at all, as expendable casualties: as numbers, as categories, as unfortunate incidents that prompt announcements rather than mourning. The migrant worker, already rendered invisible as a person by the city’s economic and spatial order, encounters this invisibility in death as well. His life was not framed as “grievable” because it was never fully recognised as a life. He was only a function, a service, a body that showed up and delivered but was never meant to belong. Pandav Kumar was expendable even before Neeraj Balhara pulled the trigger. The silence afterwards confirmed it.
The futures that are not counted
This incident also requires us to move beyond the popular discourse which often frames the migrant worker’s life only as a story of deprivation and struggle. While this framing is worthy of attention and has its own merit in planning and policy debates, it tends to treat economic and material hardship as an endpoint of the story. It leaves out the everyday assertions and resistances that those who are marginalised exercise to create certain futures.
Veena Das, in her work on low-income neighbourhoods in Delhi (Life and Words: Violence and the Descent into the Ordinary, 2007), asks us to think about the poor beyond mere subsistence, towards what she calls the “collective maps of aspiration”—ways in which people on the margins generate aspirations that go beyond, and sometimes against, the social positions assigned to them. The poor are not defined only by their need of survival. They also make choices. They imagine futures. They build—incrementally, contingently, against uncertainty—towards lives that are not yet there but might be.
Pandav Kumar was doing exactly this. His family had come to Delhi from Khagariya in Bihar almost two decades ago. They lived five to a room in Uttam Nagar: Kumar; his parents; his younger brother, who also suffers from bone tuberculosis; and his 5-year-old niece, whom Pandav had brought to Delhi after his elder sister died in disputed circumstances. As sole breadwinner of the family, Kumar paid the rent, supported the household, saved for his brother’s treatment, planned for his niece’s education, steadily acquired small appliances on instalments—all by himself. He was building a life piece by piece out of whatever the present allowed—one EMI and one expense at a time – trying to create an aspired future in a city that was indifferent.
Das’ insight is that this kind of building—provisional, precarious, interrupted by contingency—is not a lesser form of aspiration. It is aspiration in its most honest form. Every instalment is a bet on a future that has not yet been guaranteed.
Kumar’s killing exposes the violence that occurs when these private futures— assembled carefully, with no safety net—meet city’s indifference. The city has no imagination of Kumar’s future. He was legible to it only as a delivery worker: a function, not a person. When he stepped outside that function—as a friend at a birthday gathering, as a Bihari man speaking with his friends on a public street—the city, in the form of Neeraj Balhara, told him he did not belong.
The city we keep building
Neeraj Balhara will face trial. That is necessary. It is not sufficient. The trial will deal with one man and one bullet. It will not deal with the labour codes that left Pandav Kumar without formal protection, or the housing policy that confined his family of five to a single room, or the institutional culture that made a Special Cell constable feel entitled to “correct” the presence of Bihari men on a public road.
These are not questions that criminal law is designed to answer. But they are the questions this death actually poses. Accountability here means asking what kind of city we are willing to keep building—one that needs its migrant workers in order to function but has no mechanism through which their lives, aspirations, or personhood can become legible to its planners, its politicians, or its police. Or one that begins— in its laws, its planning, its public culture—to treat the migrant worker not as a provisional body to be deployed and discarded, but as a person with a claim on the city he helps build.
The answer to this question is not a verdict. It is a set of choices, about labour law, urban planning, and public culture of a city that has for too long treated certain lives as instrumental and certain futures as dispensable.
Priyanka Mittal is a researcher at Lokniti-CSDS. The views expressed here are personal and do not reflect the views of any institution.
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