Extraterritorial Assassination in Azad Kashmir: When a teacher Becomes a “Terrorist” After Death.
On 21 May 2026, Arjumand Gulzar Dar—known to his students in Gojra, Muzaffarabad, as Hamza Burhan—finished his morning duties as a school principal and stepped outside. He never reached his vehicle. Motorcycle-borne gunmen shot him dead at close range. To the community that knew him, he was a civilian educator who had crossed into Pakistan-administered Kashmir in 2018 to pursue medical education, built a quiet life, and took up teaching.
BY Muhammad Waleed Akhtar
No militant group claimed responsibility for his murder. India’s Ministry of Home Affairs had designated him a terrorist under the Unlawful Activities Prevention Act in April 2022, alleging links to the Al-Badr militant group and involvement in the 2019 Pulwama attack. Those allegations deserve scrutiny, not because they are credible, but because they expose how easily a civilian can be retrofitted into a legal target after an extrajudicial execution.
The factual problems with India’s narrative are immediate and severe. The Pulwama attack, which killed forty Indian CRPF personnel, was publicly claimed by Jaish-e-Mohammed—not Al-Badr. The then-governor of Jammu and Kashmir publicly revealed the security failures and domestic motives behind that bombing, disclosures that sit uneasily with New Delhi’s subsequent attempt to pin operational
mastermind status on a former medical student living openly as a schoolteacher in Muzaffarabad. Dar was never prosecuted, never convicted, and never afforded the judicial process India’s own legal system theoretically guarantees. He was a civilian living under civilian cover, known to his neighbors not as a combatant but as an educator who had arrived in 2018 seeking medical education and remained to teach.
Although the Indian government has never officially claimed responsibility for the Muzaffarabad killing, its domestic media ecosystem did the celebrating for it. Within hours, Indian news networks broadcast the assassination as breaking news, framing it as a strategic victory and lionizing the operatives who gunned down an unarmed man outside his school. That triumphalism betrays the reality: this was not the neutralization of an active battlefield commander, but the methodical murder of a civilian in a third-country territory, treated as entertainment for a domestic audience.
The Muzaffarabad killing does not stand alone. It is the latest node in a documented campaign of extraterritorial murder attributed to Indian intelligence services. In April 2024, The Guardian reported that India had allegedly orchestrated up to twenty assassinations inside Pakistan since 2020, employing recruited local proxies and deploying a consistent signature: motorcycle gunmen, close-range execution, no claim of responsibility. In December 2024, The Washington Post described India’s alleged methodical assassination program targeting individuals in Pakistan. Foreign Policy magazine in January 2024 placed India firmly within a growing club of states conducting targeted killings beyond their borders.
The program extends even further: Canadian authorities have linked Indian intelligence to the murder of Sikh activist Hardeep Singh Nijjar on Canadian soil, and U.S. prosecutors have alleged an Indian government role in a foiled plot to assassinate a dual-national lawyer in New York. From Rawalpindi to Surrey to Manhattan, the pattern is documented, consistent, and attributed by credible international reporting to a deliberate strategic campaign of extraterritorial murder.
Indian authorities advance a position that deserves engagement only to be dismantled. They maintain that such operations constitute necessary self-defense against terrorism emanating from Pakistan, that Pakistan’s alleged support for militant groups creates an obligation to act where the host state will not, and that pre-emptive neutralization prevents future attacks. What it cannot survive, however, is application to the specific legal tests that govern the use of force between states—particularly when the target is a civilian whose connection to the cited attack is contradicted by the very group that claimed it.
UN Charter Article 2(4) prohibits the use of force against the territorial integrity of any state. Article 51 permits self-defense only in response to an armed attack, subject to necessity and proportionality. The Caroline incident of 1837 established the customary standard that remains foundational: self-defense must be, in US Secretary of State Daniel Webster’s formulation, instant, overwhelming, leaving no choice of means, and no moment for deliberation. The killing of a school principal seven years after the attack he allegedly supported—an attack claimed by an entirely different organization—satisfies no element of that standard.
The ICJ’s judgment in Nicaragua v. United States in 1986 remains the controlling authority. The Court rejected Washington’s self-defense justification because the alleged threat did not constitute an armed attack of sufficient gravity and necessity and proportionality tests were not met. UN Special Rapporteur Philip Alston stated in 2010 that targeted killings in another state’s territory without consent constitute violations of sovereignty.
His successor Christof Heyns concluded in 2013 that such operations in many cases amount to extrajudicial executions. Even under the expansive framework the Israeli Supreme Court articulated in 2006, targeted killings require that the target be directly participating in hostilities at the relevant time and that capture be demonstrably infeasible. A man leaving a school building, with no weapon, no combat function, and no imminent operational role, satisfies neither condition.
Proponents invoke the unwilling or unable doctrine, which holds that a state may use force against non-state actors in another state’s territory if that state cannot suppress the threat. It has not achieved settled customary international law status. The majority of Global South states and UN bodies reject it as a mechanism through which powerful states circumvent sovereignty protections the Charter was designed to guarantee.
Applying it to a sustained campaign of motorcycle assassinations against individuals living openly under civilian cover—without publicly available evidence of imminence in each specific case, and in the case of Dar, without credible evidence of combatant status at all—stretches even its most permissive articulation beyond defensible limits.
Russia’s poisoning of Alexander Litvinenko in London in 2006 and Sergei Skripal in 2018 were condemned internationally as sovereignty violations. Israel’s extraterritorial killing program has been repeatedly criticized by UN Special Rapporteurs as operating outside permissible boundaries when conducted far from active battlefields. The United States conducted hundreds of drone strikes under self-defense frameworks that UN bodies described as insufficiently grounded in necessity.
India now marches in this same procession, but with a crucial distinction: it demands that international law protect its own sovereignty from cross-border militancy while simultaneously treating the territory of its neighbors as a free-fire zone for motorcycle death squads. A state that participates in this pattern is not applying a principle. It is claiming exemption from one.
International law provides legitimate mechanisms for accountability against terrorism: extradition, mutual legal assistance, prosecution through competent tribunals and diplomatic pressure on host states. The question is not whether terrorism demands a response. It does. The question is whether substituting assassination for legal process—whether designating a medical student-turned-principal a terrorist years after an attack claimed by another group, then celebrating his murder on primetime television—produces durable security or merely relocates the lawlessness it claims to oppose.
From the Caroline precedent through the Nicaragua judgment to the consistent assessments of UN Special Rapporteurs, the legal framework provides a clear answer. States that reject it are not operating in a grey zone. They are operating outside the rules they invoke for their own protection, and in the case of Arjumand Gulzar Dar, they are operating outside the basic human requirement to distinguish a civilian from a combatant.
The writer is researcher at Kashmir Institute of International Relations (KIIR).