An honor killing is the homicide of a member of a family or social group by other members, due to the perpetrators’ belief that the victim has brought shame or dishonor upon the family or community, usually for reasons such as refusing to enter an arranged marriage, being in a relationship that is disapproved by their relatives, having sex outside marriage, becoming the victim of rape, dressing in ways which are deemed inappropriate, or engaging in homosexual relations.^{[1][2][3][4][5]}

Honor killings are especially targeted against women and homosexuals. The practice, which occurs in various cultures, is universally condemned by human rights organizations.

Definitions[edit]

Human Rights Watch defines “honor killings” as follows:

Honor killings are acts of vengeance, usually death, committed by male family members against female family members, who are held to have brought dishonor upon the family.

A woman can be targeted by (individuals within) her family for a variety of reasons, including: refusing to enter into an arranged marriage, being the victim of a sexual assault, seeking a divorce—even from an abusive husband—or (allegedly) committing adultery.

The mere perception that a woman has behaved in a way that “dishonors” her family is sufficient to trigger an attack on her life.^[6]

Men can also be the victims of honor killings by members of the family of a woman with whom they are perceived to have an inappropriate relationship.^[7]  (For example, family members of a girl who married from another religious sect cut-off the sex of the husband)

The loose term “honor killing” applies to killing of both men and women in cultures that practice it.^[8]

Some women who bridge social divides, publicly engage other communities, or adopt some of the customs or the religion of an outside group may be attacked.

In countries that receive immigrants, some otherwise low-status immigrant men and boys have asserted their dominant patriarchal status by inflicting honor killings on women family members who have participated in public life, for example, in feminist and integration politics.^[9]

Extent[edit]

The incidence of honor killings is very difficult to determine and estimates vary widely.

In most countries data on honor killings is not collected systematically, and many of these killings are reported by the families as suicides and registered as such.^[10][11]

Although honor killings are often associated with Asia, especially South Asia and the Middle East, they occur all over the world.^[12][13]

In 2000, the United Nations estimated that 5,000 people were victims of honor killings each year.^[14]

According to BBC, “Women’s advocacy groups suspect that more than 20,000 women are killed worldwide each year.”^[15]

Murder is not the only form of honor crime, other crimes such as acid attacks, abduction, mutilations, beatings occur.

In 2010 the UK police recorded at least 2,823 such crimes.^[16]

Culture[edit]

Sharif Kanaana, professor of anthropology at Birzeit University, says that honor killing is:

A complicated issue that cuts deep into the history of Arab society. .. What the men of the family, clan, or tribe seek control of in a patrilineal society is reproductive power.

Women for the tribe were considered a factory for making men. The honour killing is not a means to control sexual power or behavior. What’s behind it is the issue of fertility, or reproductive power.^[17]

An Amnesty International statement adds:

The regime of honour is unforgiving: women on whom suspicion has fallen are not given an opportunity to defend themselves, and family members have no socially acceptable alternative but to remove the stain on their honour by attacking the woman.^[18]

Carolyn Fluehr-Lobban, an anthropology professor at Rhode Island College, explains how honor killings can be viewed in cultural relativist terms. She writes that the act, or even alleged act, of any female sexual misconduct, upsets moral order for the culture of interest and bloodshed is the only way to remove any shame brought about by the actions and restore social equilibrium.^[19]

Changing cultural and economic status of women has also been used to explain the occurrences of honor killings.

Women in largely patriarchal cultures who have gained economic independence from their families go against their male-dominated culture. Some researchers argue that the shift towards greater responsibility for women and less for their fathers may cause their male family members to act in oppressive and sometimes violent manners in order to regain authority.^[20]

This change of culture can also be seen to have an effect in Western cultures such as Britain where honor killings often arise from women seeking greater independence and adopting seemingly Western values.

For women who trace their ancestry back to the Middle East or South Asia, wearing clothes that are considered Western, having a boyfriend, or refusing to accept an arranged marriage are all offenses that can and have led to an honor killing.^[21]

Cultural implications can often be seen in public and private views of honor killings.

In some cultures, honor killings are considered less serious than other murders simply because they arise from long-standing cultural traditions and are thus deemed appropriate or justifiable.^[19]

According to a poll done by the BBC’s Asian network, 1 in 10 of the 500 Hindus, Sikhs, Christians and Muslims surveyed said they would condone any murder of someone who threatened their family’s honor.^[22]

The lawyer and human rights activist Hina Jilani says, “The right to life of women in Pakistan is conditional on their obeying social norms and traditions.”^[23]

Nighat Taufeeq of the women’s resource center Shirkatgah (Lahore, Pakistan) says:

“It is an unholy alliance that works against women: the killers take pride in what they have done, the tribal leaders condone the act and protect the killers and the police connive the cover-up.”^[24]

A July 2008 Turkish study by a team from Dicle University on honor killings in the Southeastern Anatolia Region, the predominantly Kurdish area of Turkey, has so far shown that little if any social stigma is attached to honor killing. It also comments that the practice is not related to a feudal societal structure,

“there are also perpetrators who are well-educated university graduates. Of all those surveyed, 60% are either high school or university graduates or at the very least, literate.”^[25]

Fareena Alam, editor of a Muslim magazine, writes that honor killings which arise in Western cultures such as Britain are a tactic for immigrant families to cope with the alienating consequences of urbanization.

Alam argues that immigrants remain close to the home culture and their relatives because it provides a safety net. She writes that,

“In villages “back home”, a man’s sphere of control was broader, with a large support system. In our cities full of strangers, there is virtually no control over who one’s family members sit, talk or work with.”

Alam argues that it is thus the attempt to regain control and the feelings of alienation that ultimately leads to an honor killing.^[26]

Relation to homosexuality[edit]

There is some evidence that homosexuality can also be perceived as grounds for honor killing by relatives.

In one case, a gay Jordanian man was shot and wounded by his brother.^[27] In another case, a homosexual Turkish student, Ahmet Yildiz, was shot outside a cafe and later died in the hospital.

Sociologists have called this Turkey‘s first publicized gay honor killing.^[28][29]

United Nations High Commissioner for Refugees state that “claims made by LGBT persons often reveal exposure to physical and sexual violence, extended periods of detention, medical abuse, threat of execution and honour killing.”^[30]

Honor killings of victims of rape[edit]

Refusal of an arranged marriage[edit]

Allegations and rumors about a family member[edit]

In certain cultures, an allegation against a woman can be enough to tarnish her family’s reputation, and to trigger an honor killing: the family’s fear of being ostracized by the community is enormous.^[36][37][38]

Causes[edit]

There are multiple causes for which honor killings occur, and numerous factors interact with each other.

Views on women[edit]

Honor killings are often a result of strongly patriarchal views on women, and the position of women in society. In these traditional male dominated societies women are dependent first on their father and then on their husband, whom they are expected to obey.

Women are viewed as property and not as individuals with their own agency. As such, they must submit to male authority figures in the family – failure to do so can result in extreme violence as punishment. Violence is seen as a way of ensuring compliance and preventing rebellion.^[39][40]

A culture of honor and shame[edit]

The concept of family honor is extremely important in many communities.

The family is viewed as the main source of honor and the community highly values the relationship between honor and the family.

Acts by family members which may be considered inappropriate are seen as bringing shame to the family in the eyes of the community. Such acts often include female behaviors that are related to sex outside marriage or way of dressing, but may also include male homosexuality. The family loses face in the community, and may be shunned by relatives.

The only way the shame can be erased is through a killing.^[39][40]

Laws[edit]

Legal frameworks can encourage honor killings.

Such laws include on one side leniency towards such killings, and on the other side criminalization of various behaviors, such as extramarital sex, ‘indecent’ dressing in public places, or homosexual sexual acts, with these laws acting as a way of reassuring perpetrators of honor killings that people engaging in these behaviors deserve punishment.^[41][42]

Religion[edit]

Widney Brown, the advocacy director of Human Rights Watch, said that the practice “goes across cultures and across religions”. Human rights advocates have compared “honor killing” to “crimes of passion” in Latin America (which are sometimes treated extremely leniently) and also to the killing of women for lack of dowry in India.

Honor crimes occur in societies where there is an interplay between discriminatory traditions of justice and statutory law. In some countries, this discrimination is exacerbated by the inclusion of Shari’a, Islamic law, or the concept of zina (sex outside of marriage).^[44]

Tahira Shaid Khan, a professor of women’s issues at Aga Khan University, notes that there is nothing in the Qur’an that permits or sanctions honor killings.^[44] Khan instead blames it on attitudes (across different classes, ethnic and religious groups) that view women as property with no rights of their own as the motivation for honor killings.^[44]

Khan also argues that this view results in violence against women and their being turned “into a commodity which can be exchanged, bought and sold”.^[45]

Relation to the Napoleonic Code and legacy in former French colonies[edit]

Honor killings in history[edit]

As noted by Christian Arab writer, Norma Khouri, honor killings originate from the belief that a woman’s chastity is the property of her families, a cultural norm that comes “from our ancient tribal days, from the Hammurabi and Assyrian tribes of 1200 B.C.”^[48]

Matthew A. Goldstein, J.D. (Arizona), has also noted that honor killings were encouraged in ancient Rome, where male family members who did not take actions against the female adulterers in their family were “actively persecuted”.^[49]

The origin of honor killings and the control of women is evidenced throughout history in the culture and tradition of many regions. The Roman law of pater familias gave complete control to the men of the family for both their children and wives…

Among the Amerindian Aztecs and Incas, adultery was punishable by death.^[49]

Qays bin Asim, ancient leader of Banu Tamim is credited by some historians as the first to kill children on the basis of honor. It is recorded that he murdered all of his daughters to prevent them from ever causing him any kind of dishonor.^[50]

Honor killing by region[edit]

According to the UN in 2002:

The report of the Special Rapporteur… concerning cultural practices in the family that are violent towards women (E/CN.4/2002/83), indicated that honour killings had been reported in Egypt, Jordan, Lebanon, Morocco, Pakistan, theSyrian Arab Republic, Turkey, Yemen, and other Mediterranean and Persian Gulf countries, and that they had also taken place in western countries such as France, Germany and the United Kingdom, within migrant communities.^[51][52]

Europe[edit]

The 2009 European Parliamentary Assembly noted this in their Resolution 1681 which noted the dire need to address honor crimes. The resolution stated that:

“On so-called ‘honor crimes,’ the Parliamentary Assembly notes that the problem, far from diminishing, has worsened, including in Europe. It mainly affects women, who are its most frequent victims, both in Europe and the rest of the world, especially in patriarchal and fundamentalist communities and societies.

For this reason, it asked the Council of Europe member states to ‘draw up and put into effect national action plans to combat violence against women, including violence committed in the name of so-called ‘honor,’ if they have not already done so.”^[55]

A 2006 BBC poll for the Asian network in the UK found that one in ten of the 500 young Asians polled said that they could condone the killing of someone who dishonored their family.^[61]

In the UK, in December 2005, Nazir Afzal, Director, west London, of Britain’s Crown Prosecution Service, stated that the United Kingdom has seen “at least a dozen honour killings” between 2004 and 2005.^[62] While precise figures do not exist for the perpetrators’ cultural backgrounds, Diana Nammi of the UK’s Iranian and Kurdish Women’s Rights Organisation is reported to have said: “about two-thirds are Muslim. Yet they can also be Hinduand Sikh.”^[63]

In 2010, Britain saw a 47% rise of honor-related crimes.

Saudi Arabia[edit]

In 2008 a woman was killed in Saudi Arabia by her father for “chatting” to a man on Facebook. The killing became public only when a Saudi cleric referred to the case, not to condemn it but to criticise Facebook for the strife it caused.^[75]

Lebanon[edit]

There are no exact official numbers about honor killings of women in Lebanon; many honor killings are arranged to look like accidents, but the figure is believed to be 40 to 50 per year.

A 2007 report by Amnesty International said that the Lebanese media in 2001 reported 2 or 3 honor killings per month in Lebanon, although the number is believed to be higher by other independent sources.

On 4 August 2011 the Lebanese parliament agreed by a majority to abolish Article 562, which for years had worked as an excuse for honor killing.^[82][83]

Palestinian Authority[edit]

The Palestinian Authority, using a clause in the Jordanian penal code still in effect in the West Bank, exempts men from punishment for killing a female relative if she has brought dishonor to the family.^[84]

Mahmoud Abbas, President of the Palestinian Authority, promised to change the discriminatory law, but no action had been taken as of 2012. According to UNICEF, in 2000 two-thirds of all killings in the Palestinian territories were honor killings.^[85]

The Palestinian Independent Commission for Human Rights has reported 29 women were killed 2007-2010, whereas 13 women were killed in 2011 and 12 in the first seven months of 2012.^[86]

Iran[edit]

Honour killings occur primarily among tribal minority groups such as Kurds, Loris, Arabs and Baluchis, which are generally more conservative than the Persians. Discriminatory family laws, articles in the Criminal Code that show leniency towards honor killings, and a strongly male dominated society have been cited as causes of honor killings in Iran.^[87]

Iraq[edit]

As many as 133 women were killed in the Iraqi city of Basra alone in 2006—79 for violation of “Islamic teachings” and 47 for honor killings, according to IRIN, the news branch of the U.N.’s Office for the Coordination of Humanitarian Affairs.

Amnesty International says that armed groups, not the government, also kill politically active women and those who did not follow a strict dress code, as well as women who are perceived as human rights defenders.^[88]

A 17-year-old Iraqi Kurdish girl of the Yazidi faith was stoned to death in 2007,^[89] possibly because she was accused of wanting to convert to Islam. The 2007 Yazidi communities bombings may have been retaliations.^[90]

Jordan[edit]

There are still “honor” killings in Jordan. In Jordan there is relatively little sex discrimination compared to most other countries in the region, and women are permitted to vote, but men receive reduced sentences for killing their wives or female family members if they are deemed to have brought dishonor to their family.

Families often get sons under the age of 16—legally minors—to commit honor killings; the juvenile law allows convicted minors to serve time in a juvenile detention center and be released with a clean criminal record at the age of 16.

Rana Husseini, a leading journalist on the topic of honor killings, states that “under the existing law, people found guilty of committing honor killings often receive sentences as light as six months in prison”.^[91] According to UNICEF, there are an average of 23 honor killings per year in Jordan.^[85]

There has been public support in Jordan to amend Articles 340 and 98.

In 1999 King Abdullah created a council to review the sex inequalities in the country. The Council returned with a recommendation to repeal Article 340. “[T]he cabinet approved the recommendation, the measure was presented to parliament twice in November 1999 and January 2000 and in both cases, though approved by the upper house, it failed to pass the elected lower house”.^[91]

In 2001, after parliament was suspended, a number of temporary laws were created which were subject to parliamentary ratification. One of the amendments was that “husbands would no longer be exonerated for killing unfaithful wives, but instead the circumstances would be considered as evidence for mitigating punishments”.

In the interest of sex equality, women were given the same reduction in punishment if found guilty of the crime. But parliament returned to session in 2003 and the new amendments were rejected by the lower house after two successful readings in the upper house.^[91]

A 2013 survey of “856 ninth graders – average age of 15 – from a range of secondary schools across Amman – including private and state, mixed-sex and single gender” showed that attitudes favoring honor killings are present in the “next generation” Jordanians:

“In total, 33.4% of all respondents either “agreed” or “strongly agreed” with situations depicting honour killings. Boys were more than twice as likely to support honour killings: 46.1% of boys and 22.1% of girls agreed with at least two honour killing situations in the questionnaire.”

The parents’ education was found to be a significant correlation: “61% of teenagers from the lowest level of educational background showed supportive attitudes towards honour killing, as opposed to only 21.1% where at least one family member has a university degree.^[92][93]

Yemen[edit]

Honor killings are common in Yemen, which is a very conservative society; in some parts of the country traditional tribal customs forbid contact between men and women before marriage.^[94] Yemeni society is strongly male dominated, Yemen being ranked last of 135 countries in the 2012 Global Gender Gap Report.^[95]

It was estimated that about 400 women and girls died in honor killings in 1997 in Yemen.^[96] In 2013, a 15-year-old girl was killed by her father, who burned her to death, because she talked to her fiance before the wedding.^[94][97]

Egypt[edit]

Honor killings in Egypt occur due to reasons such as a woman meeting an unrelated man, even if this is only an allegation; or adultery (real or suspected). The exact number of honor killings is not known, but a report in 1995 estimated about 52 honor killings that year.^[98]

The Americas[edit]

Canada[edit]

A 2007 study by Dr. Amin Muhammad and Dr. Sujay Patel of Memorial University, Canada, investigated how the practice of honor killings has been brought to Canada. The report explained that “When people come and settle in Canada they can bring their traditions and forcefully follow them.

In some cultures, people feel some boundaries are never to be crossed, and if someone would violate those practices or go against it, then killing is justified to them.” The report noted that “In different cultures, they can get away without being punished—the courts actually sanction them under religious contexts”.

The report also said that the people who commit these crimes are usually mentally ill, and that the mental health aspect is often ignored by Western observers because of a lack of understanding of the insufficiently developed state of mental healthcare in developing countries in which honor killings are prevalent.^[99]

Canada has been host to a number of high profile killings, including the murder of Kaur Sidhu,^[100] the murder of Amandeep Atwal,^[101]the double murder of Khatera Sadiqi and her fiance,^[102] and the Shafia family murders.^[102][103]

Honor killings have become such a pressing issue in Canada that the Canadian citizenship study guide mentions it specifically, saying, “Canada’s openness and generosity do not extend to barbaric cultural practices that tolerate spousal abuse, ‘honour killings’, female genital mutilation, forced marriage or other gender-based violence.”^[102]

United States[edit]

The neutrality of this section is disputed. Relevant discussion may be found on the talk page. Please do not remove this message until the dispute is resolved. (July 2013)

Some have argued that the United States is far behind Europe in acknowledging that honor killings are a special form of domestic violence, requiring special training and special programs to protect the young women and girls most likely to be the victim of such practices.^{[dubious – discuss]}

The article suggests that the fear of being labeled “culturally insensitive” often prevents government officials in the United States and the media from identifying and accurately reporting these incidents as “honor killings” when they occur. Failing to accurately describe the problem makes it more difficult to develop public policies to address it.

The article reports that, although there are not many cases of honor killings within the United States, the overwhelming majority of honor killings are perpetrated by Muslims against Muslims (90% of honor killings known to have taken place in Europe and the United States from 1998 to 2008).^[104] In these documented cases the victims were murdered because they were believed to have acted in a way against the religion of the family.

In every case, perpetrators view their victims as violating rules of religious conduct and act without remorse.^[104]

Latin America[edit]

Crimes of passion within Latin America have also been compared to honor killings.^[44] Similar to honor killings, crimes of passion often feature the murder of women by a husband, family member, or boyfriends and the crime is often condoned or sanctioned. In Peru, for example, 70 percent of the murders of women in one year were committed by a husband, boyfriend or lover, and most often jealousy or suspicions of infidelity are cited as the reasons for the murders.^[105]

South Asia[edit]

Afghanistan[edit]

In 2012, Afghanistan recorded 240 cases of honor killings, but the total number is believed to be much higher. Of the reported honor killings, 21% were committed by the victims’ husbands, 7% by their brothers, 4% by their fathers, and the rest by other relatives.^[106][107]

Pakistan[edit]

In Pakistan honor killings are known locally as karo-kari. An Amnesty International report noted “the failure of the authorities to prevent these killings by investigating and punishing the perpetrators.”^[108] Recent cases include that of three teenage girls who were buried alive after refusing arranged marriages.^[109] Another case was that of Taslim Khatoon Solangi, 17, of Hajna Shah village in Khairpur district, which was widely reported after her father, 57-year-old Gul Sher Solangi, publicized the case. He alleged his eight-months-pregnant daughter was tortured and killed on 7 March on the orders of her father-in-law, who accused her of carrying a child conceived out of wedlock.^[110][111] Statistically, honor killings have a high level of support in Pakistan’s rural society, despite widespread condemnation from human rights groups.^[112] In 2002 alone over 382 people, about 245 women and 137 men, became victims of honor killings in the Sindh province of Pakistan.^[113] Over the course of six years, more than 4,000 women have died as victims of honor killings in Pakistan from 1999 to 2004.^[114] In 2005 the average annual number of honor killings for the whole nation was stated to be more than 10,000 per year.^[115] According to women’s rights advocates, the concepts of women as property, and of honor, are so deeply entrenched in the social, political and economic fabric of Pakistan that the government mostly ignores the regular occurrences of women being killed and maimed by their families.”^[116] Frequently, women killed in honor killings are recorded as having committed suicide or died in accidents.^[116]

It is noted by sociologists that honor killings do not necessarily have to do with religion, but rather the cultures in different regions.^[117]Savitri Goonesekere qualifies this claim, saying that Islamic leaders in Pakistan use religious justifications for sanctioning honor killings.^[118]

Furthermore, most honor killings were encompassed by the 1990 Qisas and Diyat Ordinance, which permits the individual and his or her family to retain control over a crime, including the right to determine whether to report the crime, prosecute the offend, or demanddiyat (or compensation). Since most honour killings are committed by a close relative, if and when the case reaches a court of law, the victim’s family may ‘pardon’ the murderer, or be pressured to accept diyat (financial compensation). The murderer then goes free.^[119]Once such a pardon has been secured, the state has no further writ on the matter although often the killers are relatives of the victim.

India[edit]

Honor killings have been reported in northern regions of India, mainly in the Indian states of Punjab, Rajasthan, Haryana, Uttar Pradesh, as a result of people marrying without their family’s acceptance, and sometimes for marrying outside their caste or religion. In contrast, honor killings are rare to non-existent in South India and the western Indian states of Maharashtra and Gujarat. In some other parts of India, notably West Bengal, honor killings ceased about a century ago, largely due to the activism and influence of reformists such asVivekananda, Ramakrishna, Vidyasagar and Raja Ram Mohan Roy.^[120]

The Indian state of Punjab has a large number of honor killings. According to data compiled by the Punjab Police, 34 honor killings were reported in the state between 2008 and 2010: 10 in 2008, 20 in 2009, and four in 2010.^[121]

Haryana is also notorious for incidents of honor killing, mainly in the upper caste of society, among rajputs and jaats.^[54][122] Bhagalpurin the eastern Indian state of Bihar has also been notorious for honor killings.^[123] Recent cases include a 16-year-old girl, Imrana, fromBhojpur who was set on fire inside her house in a case of what the police called ‘moral vigilantism’. The victim had screamed for help for about 20 minutes before neighbours arrived, only to find her smouldering body. She was admitted to a local hospital, where she later died from her injuries.^[124] In May 2008, Jayvirsingh Bhadodiya shot his daughter Vandana Bhadodiya and struck her on the head with an axe.^[125] In June 2010 some incidents were reported even from Delhi.

In a landmark judgment in March 2010, Karnal district court ordered the execution of five perpetrators of an honor killing in Kaithal, andimprisoning for life the khap (local caste-based council) chief who ordered the killings of Manoj Banwala (23) and Babli (19), a man and woman of the same clan who eloped and married in June 2007. Despite having been given police protection on court orders, they were kidnapped; their mutilated bodies were found a week later in an irrigation canal.^{[126][127][128]}

In 1990 the National Commission for Women set up a statutory body in order to address the issues of honor killings among some ethnic groups in North India. This body reviewed constitutional, legal and other provisions as well as challenges women face. The NCW’s activism has contributed significantly towards the reduction of honor killings in rural areas of North India.^[129] According to Pakistani activists Hina Jilani and Eman M. Ahmed, Indian women are considerably better protected against honor killings by Indian law and government than Pakistani women, and they have suggested that governments of countries affected by honor killings use Indian law as a model in order to prevent honor killings in their respective societies.^[118]

In June 2010, scrutinizing the increasing number of honor killings, the Supreme Court of India issued notices to the Central Government and six states including Uttar Pradesh, Punjab, Haryana and Rajasthan to take preventive measures against honor killings.^[130]

Alarmed by the rise of honor killings, the Government planned to bring a bill in the Monsoon Session of Parliament July 2010^{[dated info]}to provide for deterrent punishment for ‘honor’ killings.^[131]

In June 2012, a man chopped off his 20-year-old daughter’s head with a sword in Rajasthan after learning that she was dating men.^[132][133] According to police officer, “Omkar Singh told the police that his daughter Manju had relations with several men. He had asked her to mend her ways several times in the past. However, she did not pay heed. Out of pure rage, he chopped off her head with the sword.”^[134]

A young couple who were planning to marry were brutally murdered in Garnauthi village, state of Haryana on 18 September 2013 due to having a love affair. The woman, Nidhi, was beaten to death and the man, Dharmender, was dismembered alive. People in the village and neighbouring villages approved of the killings.^[135]

In national legal codes[edit]

Legislation on this issues varies, but today the vast majority of countries no longer allow a husband to legally kill a wife for adultery (although adultery itself continues to be punishable by death in some countries) or to commit other forms of honor killings.

However, in many places, adultery and other “immoral” sexual behaviors by female family members can be considered mitigating circumstances in case when they are killed, leading to significantly shorter sentences.

In the Western world, a country that is often associated with “crimes of passion” and adultery related violence is France, and indeed, recent surveys have shown French public to be more accepting of these practices than the public in other countries.

One 2008 Gallup survey compared the views of the French, German and British public and those of French, German and British Muslims on several social issues: 4% of French public said “honor killings” were “morally acceptable” and 8% of French public said “crimes of passion” were “morally acceptable”.

Honor killings were seen as acceptable by 1% of German public and also 1% of British public; crimes of passion were seen as acceptable by 1% of German public and 2% of British public. Among Muslims 5% in Paris, 3% in Berlin and 3% in London saw honor killings as acceptable, and 4% in Paris (less than French public), 1% in Berlin and 3% in London saw crimes of passion as acceptable.^[136]

According to the report of the United Nations Special Rapporteur submitted to the 58th session of the United Nations Commission on Human Rights in 2002 concerning cultural practices in the family that reflect violence against women (E/CN.4/2002/83):

The Special Rapporteur indicated that there had been contradictory decisions with regard to the honour defense in Brazil, and that legislative provisions allowing for partial or complete defense in that context could be found in the penal codes of Argentina,Ecuador, Egypt, Guatemala, Iran, Israel, Jordan, Peru, Syria, Venezuela and the Palestinian National Authority.^[51]

The legal aspects of honor killings in different countries are discussed below:

• Jordan: Part of article 340 of the Penal Code states that “he who discovers his wife or one of his female relatives committing adultery and kills, wounds, or injures one of them, is exempted from any penalty.”^[137] This has twice been put forward for cancellation by the government, but was retained by the Lower House of the Parliament, in 2003: a year in which at least seven honor killings took place.^[138] Article 98 of the Penal Code is often cited alongside Article 340 in cases of honor killings. “Article 98 stipulates that a reduced sentence is applied to a person who kills another person in a ‘fit of fury'”.^[91]
• Morocco: Revisions to Morocco’s criminal code in 2003 helped improve women’s legal status by eliminating unequal sentencing in adultery cases. Article 418 of the penal code granted extenuating circumstances to a husband who kills, injures, or beats his wife or her partner, or both, when catching them in flagrante delicto while committing adultery. While this article has not been repealed, the penalty for committing this crime is at least now the same for both genders.^{[citation needed]}
• In Brazil, an explicit defense to murder in case of adultery has never been part of the criminal code, but a defense of “honor” (not part of the criminal code) has been widely used by lawyers in such cases to obtain acquittals. Although this defense has been generally rejected in modern parts of the country (such as big cities) since the 1950s, it has been very successful in the interior of the country. In 1991 Brazil’s Supreme Court explicitly rejected the “honour” defense as having no basis in Brazilian law.^[139]
• Haiti: In 2005, the laws were changed, abolishing the right of a husband to be excused for murdering his wife due to adultery. Adultery was also decriminalized.^[140][141]
• Syria: In 2009, Article 548 of the Syrian Law code was amended. Beforehand, the article waived any punishment for males who committed murder on a female family member for inappropriate sex acts.^[142] Article 548 states that “He who catches his wife or one of his ascendants, descendants or sister committing adultery (flagrante delicto) or illegitimate sexual acts with another and he killed or injured one or both of them benefits from a reduced penalty, that should not be less than 2 years in prison in case of a killing.” Article 192 states that a judge may opt for reduced punishments (such as short-term imprisonment) if the killing was done with an honorable intent. In addition to this, Article 242 says that a judge may reduce a sentence for murders that were done in rage and caused by an illegal act committed by the victim.^[142]
• Italy: Article 133 and 62 of the Italian Penal Code offer the possibility of reduced sentencing and punishment for crimes that occur within the offender’s cultural norms. In the case of honor killings and other honor related crimes, these articles could possibly allow for honor killing offenders to ask a reduced punishment. Italian Parliament member Souad Sbai suggested in 2010 that Italy amend these articles so that honor killings do not have extra protection under Italian law.^{[citation needed]}
• Turkey: In Turkey, persons found guilty of this crime are sentenced to life in prison.^[143] There are well documented cases, where Turkish courts have sentenced whole families to life imprisonment for an honor killing. The most recent was on 13 January 2009, where a Turkish Court sentenced five members of the same Kurdish family to life imprisonment for the honor killing of Naile Erdas, 16, who got pregnant as a result of rape.^[144]
• Pakistan: Honor killings are known as karo kari (Sindhi: ڪارو ڪاري) (Urdu: کاروکاری‎). The practice is supposed to be prosecuted under ordinary killing, but in practice police and prosecutors often ignore it.^[145] Often a man must simply claim the killing was for his honor and he will go free. Nilofar Bakhtiar, advisor to Prime Minister Shaukat Aziz, stated that in 2003, as many as 1,261 women were killed in honor killings.^[146] The Hudood Ordinances of Pakistan, enacted in 1979 by then ruler General Zia-ul-Haq, created laws that realigned Pakistani rule with Islamic law.
• The law had the effect of reducing the legal protections for women, especially regarding sex outside of the marriage. Women who made accusations of rape, after this law, were required to provide four male witnesses. If unable to do this, the alleged rape could not be prosecuted in the courts. Because the woman had admitted to sex outside of marriage, however, she could be punished for having sex outside of the marriage, a punishment that ranged from stoning to public lashing. This law made it that much more risky for women to come forward with accusations of rape. In 2006, the Women’s Protection Bill amended these Hudood Ordinances by removing four male witnesses as a requirement for rape allegations.^[147]
• On 8 December 2004, under international and domestic pressure, Pakistan enacted a law that made honor killings punishable by a prison term of seven years, or by the death penalty in the most extreme cases.^[148] Women’s rights organizations were, however, wary of this law as it stops short of outlawing the practice of allowing killers to buy their freedom by paying compensation to the victim’s relatives. Women’s rights groups claimed that in most cases it is the victim’s immediate relatives who are the killers, so inherently the new law is just whitewash. It did not alter the provisions whereby the accused could negotiate pardon with the victim’s family under the Islamic provisions.
• In March 2005, the Pakistani parliament rejected a bill which sought to strengthen the law against the practice of honor killing.^[149] However, the bill was brought up again, and in November 2006, it passed.^[150] It is doubtful whether or not the law would actually help women.^[151]

• Egypt: A number of studies on honor crimes by The Centre of Islamic and Middle Eastern Law, at the School of Oriental and African Studies in London, includes one which reports on Egypt’s legal system, noting a gender bias in favor of men in general, and notably article 17 of the Penal Code: judicial discretion to allow reduced punishment in certain circumstance, often used in honor killings case.^[152]