Although Hallaq has shown convincingly that, contrary to the common perception of many Western scholars, the gates of ijtihād were never closed as such in the medieval Sunni schools,1 the fact remains that the notion of closure remains entrenched amongst the Muslim ‘ulamā as well as the general populace. This constitutes one of the greatest impediments to any scholar outside the folds of the traditionalist religious cliques to proffer new hermeneutics or methodology or even a single opinion in substantive law.2 Whereas it is reasonable that an enterprise such as ijtihād be undertaken by one who possesses a reasonable degree of competence for it, there is no textual evidence to suggest that the ijtihād of a competent scholar (as Abū Hanīfah [81 - 150 / 700 - 767] or Mālik ibn Anas [94 - 179 / 716 - 795] or others) or even that of a whole school or of all the traditional schools is infallible.3 In Sunni jurisprudence, the notion that the ijmā‘ of the community and its scholars in matters pertaining to interpretation and ijtihād has epistemological certitude in religion, and thus, by implication, an authority equivalent to that of the Qur’ān and the sunnah is quite shaky.4 When this notion of consensus first gained religious character in the second/eighth century, the proponents of the idea, with an essentially deontological epistemology, had to look to the Qur’ān and hadīth for textual evidence that would accord ijmā‘ the epistemological value they claimed for it.5 As it happened, few of the verses adduced were relevant,6 nor was there any real consensus on the interpretation of these verses. For instance, Q.4:115, which, according to Hallaq, is one of the most relevant verses, is open to various interpretations.7 The idea of consensus here is based on an interpretation of the words wa yatabi‘ ghayr sabīl al-mu’minīn (and those who follow ways other than those of the believers). Apart from the fact that these words have been interpreted in different ways by the earliest exegetes, it is plain to see from the context that the words were originally used to refer to those opponents of the Prophet who, as the context implies, were bent upon maligning him, and who, despite the manifest truth of the Prophet’s religious authority, had chosen a course different from that of the Muslims.8 Having found that the Qur’ānic basis for their thesis weak, the proponents of ijmā‘ then turned to the sunnah for support, only to find that there was nothing sufficiently concurrent (mutawātir) to offer conclusive evidence there either.9 The next obvious step was to investigate the hadīth, most of which were in the form of isolated narrations (akhbār ahād). These akhbār ahād, according to Sunni principles of jurisprudence (usūl al-fiqh), were themselves probable (zannī) in varying degrees.10 Quite obviously, probability, regardless of its degree, could not form the epistemological foundation of certitude; therefore, the jurists came up with a novel concept around the fourth/tenth and fifth/centuries: that of concurrence of meaning (tawātur ma‘nawī), which they adduced as conclusive evidence based on inductive corroboration.11 ‘Āmidī (d.631/1233) gives an interesting example to explain this concept: we might construe a man’s glances at a woman as indicative of his love for her with only a slight degree of probability, but when there are other indicants, we might gain enough knowledge to say with a reasonable degree of certainty that the man is indeed in love with the woman.12 In the same manner, we can gain certain and immediate knowledge on the basis of a sufficient number of traditions, even if each of them may individually be false.13 There are, however, a number of problems with this kind of argumentation. Firstly, the basic problem in this epistemology is not the certainty with respect to what the words in certain narrations mean but whether the words themselves can be traced back to the Prophet (sws) with certitude.14 Since the words of the narrations in question cannot themselves be traced back to the Prophet (sws) with absolute certainty in Sunni epistemology, it would be logically inconsistent to assert that certitude of meaning derived from something that itself does not have epistemological certitude can lend certitude to an entirely new concept, that is ijmā‘. In other words, the meaning itself could only be traced back to the Prophet (sws) on the basis of tawātur if the meaning too had been reified by the Prophet (sws) himself in the form of words and had been passed on to the Muslim community by his immediate companions through their established tawātur of transmission.15 Therefore, in terms of logical consistency, the question is whether the most important basis of Sunni ijtihād and interpretation, that is ijmā‘ – despite having immense force of tradition – is essentially based on circular argument: a very ingeniously constructed case of petitio principii.16 Another argument is that tawātur itself actually depends on custom (‘ādah) and that the companions of the Prophet (sws) would not have accepted so many ahādīth pertaining to ijmā‘ if agreement on the tawātur of these ahādīth had not been there right from the beginning.17 Where did this tawātur vanish in history then? That, the argument holds, is not pertinent to the reasoning as the question is merely a historical one.18 There are three flaws in this argument. Firstly, even if the notion that the companions accepted the ahādīth with which the later jurists justified ijmā‘ is taken as fact, it does not negate the possibility that the companions accepted them for what they were: akhbār ahād. It does not necessarily prove that they granted them the status of mutawātirah in religion. Secondly, there is no evidence to suggest that the companions were unanimous in their understanding of the meanings of these akhbār in the same sense as has been given to these narrations by the jurists. Even if it could be proved that the companions were unanimous in their understanding, it does not prove that the same meaning was afforded to these narratives by the Prophet himself. For that, the Prophet (sws) would have used “words”, which then should have been transmitted by the tawātur of the companions. Thirdly, it is impossible to imagine that a mutāwatir source would just evaporate into thin air in the history of a continued tradition. Even if forced eradication of such a source had taken place (for example by some administrative decree), it would be inconceivable that an event of such import would itself not have been reported by tawātur.19
Apart from these major flaws in the foundational argument of the certitude granted to ijmā‘, there are many other inconsistencies in the whole Sunni construct as well as argumentation.20 Much the same approach is reflected in the argumentation related to tawātur and hadīth. Whereas tawātur in Sunni epistemology leads to absolute certitude (as in the case of certain readings of the Qur’ān in Sunni concepts,21 which tawātur is therefore termed as tawātur lafzī), the same could never be said of the words reported in akhbār ahād.22 Yet, the akhbār ahād are used at times to derive legal directives extraneous to the Qur’ān itself.23 To resolve this contradiction, the concept of ijmā‘ in interpretation and ijtihād was proffered, which, as we already shown, is essentially based on what it seeks to prove. Even though al-Asadabādī’s argument resolves the circularity to the extent of the argumentation,24 the issue of historical fallacy and other logical inconsistencies still remain in the whole construct.25 Therefore, though the construct did serve useful administrative function, the infallibility afforded to it by its proponents had shaky foundations.
The reason for this discussion is, that in stark contradiction to Sunni theory (which does not allow ijtihād in usūl or matters already resolved by the ijmā‘ of Sunni schools), scholars, reformers, and revivalists as Fazlur Rahman, Ghāmidī and Mawdūdī -- to name only a few – have defied tradition in terms of new ijtihād both in usūl and in matters of substantive law already resolved through ijmā‘. The reason is quite simple: ijmā‘, as a form of human reasoning, never had the infallibility that the founding fathers of this concept gave it. Many anomalies have been created by laws and interpretations based on ijmā‘.26 Similarly, many required changes are impeded by it.27 Reformers in every age have shown great ingenuity and skill in finding their way out of the labyrinth created by these problems by still holding on to the concept of the authoritativeness of ijmā‘.28 In other instances, the solutions were downright subterfuges – intentional or unintentional.29 Mawdūdī himself found a way out by accepting only a certain kind of ijmā‘ as absolutely authoritative, which ijmā‘, by definition, is one that in most cases of interpretation and ijtihād can rarely be established historically.30 In many other cases, he relies on the principle of necessity (as we have seen in Chapter 2) to overcome the obstacles to the realization of his weltanschauung placed in his way by traditional interpretation. Ghāmidī, on the other hand, goes to the extent of denying outright the infallibility of ijmā‘ on any interpretation or any ijtihād, even if arrived at by the companions of the Prophet (sws).31 To him, the only infallible source of religion is the Prophet (sws), who disseminated it in the form of the Qur’ān and the sunnah.32 It is only the ijmā‘ or tawātur of the companions in the transmission of these sources that Ghāmidī considers as having an established (yaqīnī) basis in religion.33 In other words, since the Qur’ān and the sunnah were transmitted through tawātur, Ghāmidī accepts them as the assured “content” of religion that requires human interpretation.34 As far as interpretation of this content and ijtihād on its basis are concerned, they do not have the infallibility to be precluded from the scope of investigation, critique, or repudiation.35 This is a major epistemological break from the tradition, and its implications are manifold as well as deep. Simply put, it means that, in Ghāmidī’s opinion, there is nothing in the sharī’ah to prohibit any competent scholar from giving opinions on matters and principles in interpretation or ijtihād already resolved earlier through the mechanism of ‘ijmā‘.
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1. Hallaq, “Was the Gate of
ijtihād Closed?” 3-41; reprinted in Wael B. Hallaq, Law and Legal Theory in
Classical and Medieval Islam, (Hampshire: Variorum, 1994), V. For views
contrary to Hallaq’s in Western scholarship, see Schacht, Introduction to
the Islamic law, 69-75. Cf. Coulson, A History of Islamic Law, 202-203.
2. In this regard, for a representative example of the tradionalist view in Pakistan, see Muhammad Taqī Uthmānī, Taqlīd kī Shara‘ī Hathiyyat (The Position and Value of Taqlīd in the Sharī‘ah) (Karachi: Maktabah Dar al-‘Ulūm, 1992).
3. See Hallaq, “Was the Gate of ijtihād Closed?” 5-7 for the rather lax and flexible conditions for a mujtahid in the early medieval period of Muslim history (see, especially, the conditions laid down by Ghazālī. Marcia K. Hermansen has shown that even Shah Walī Allāh (whose importance as a mujtahid – mujtahid muntasib in Hermansen’s estimation -- in the Indian/Pakistani context cannot be doubted) accepted the possibility of going outside the four schools on specific cases, though generally his emphasis was on following them. See the Preface in Shah Walī Allāh, The Conclusive Argument from God: Shāh Walī Allāh of Delhi’s Hujjat Allāh al-Bālighah, trans. Marcia K. Hermansen (Leiden: E.J. Brill, 1996), xxxii. However, the conditions he sets forth for the loftiest ijtihād in hadīth disciplines are also worth noting as they include ‘ilm ladunī (inspired knowledge from God) and asrār wahbī (bestowed secrets), apart from excellence in virtually all other fields of religious learning. He then goes on to suggest that all these abilities are present in his person. Ibid., 6-10. Although many exegetes suggest, on the basis of the interpretation of some ahādīth, that the person (usually called Khidr) whom the Qur’ān refers to as the recipient of ‘ilm ladunī (Q. 18:65) was not a nabī, yet it is interesting to note the arguments given by Islāhī, who claims that this person must have been a nabī as it would not have made any sense for the Prophet Moses to go to a non-nabī for religious guidance. Amīn Ahsan Islāhī, Tadabbur-i Qur’ān, 3rd ed., vol. 4 (Lahore: Farān Foundation, 1988), 606. Mawdūdī suggests that this person was one of the angels of God as the tasks he performed included taking the life of an innocent boy, which task could only have been assigned to an angel or some other similar being. Abū al-A‘lā Mawdūdī, Tafhīm al-Qur’ān, vol.2 (reprint Lahore: Maktaba-i Ta‘mīr-i Insānīyat, 1972), 40-42. Ghāmidī also holds the same opinion. Jāvēd Ahmad Ghāmidī, personal interview, 15 October 2003. Shāh Walī Allāh’s reference to ‘ilm ladunī as a trait of those worthy of hadīth scrutiny is ironic in that, in the context of the given verse, the person referred to appears to have been more knowledgeable and aware of God's intent than the Prophet Moses.
4. See Wael B. Hallaq, “On the Authoritativeness of Sunni Consensus,” International Journal of Middle East Studies 18. (New York, 1986): 427; reprinted in Wael B. Hallaq, Law and Legal Theory in Classical and Medieval Islam. (Hampshire: Variorum, 1994), VIII. Here, we are referring to ijmā‘ in matter relating to interpretation and ijtihād. Transmission of the “content” of religion (as in the foundation text – the Qur’an or religious custom – the sunnah) through ijmā‘ and tawātur (concurrent transmission) of the whole community is a separate matter altogether. Even some contemporary scholars fully endorse the idea of certitude for the “content” in this case. (See, for example, Jāvēd Ahmad Ghāmidī, Mīzān (Lahore: al-Mawrid, 2009), 13-15.
4. See ibid., 428.
5. See ibid., 428.
6. For a list of some of the usually quoted Qur'ānic verses and ahādīth , see Baqā, Usūl-i Fiqh awr Shāh Walī Allāh, 295-297.
7. “And whoso opposes the Messenger after the guidance had been manifested unto him, and follows other than the believers’ way, We appoint for him that which he himself had turned, and expose him unto Hell -- hapless journey’s end!” (Q.4:115). Translation from Hallaq, A History of Islamic Legal Theories, 75.
8. Amīn Ahsan Islāhī, Tadabbur-i Qur’ān, vol. 2 (reprint Lahore: Fārān Foundation, 1988), 381-383. Similarly, it is difficult to see how the verses Q.16:43 and Q. 21:07 (“… Ask ahl al-dhikr if you do not know”) could be detached from the original meanings ascribed to the text in early tafsīr works (as by Ibn ‘Abbās in Ibn Kathīr’s Tafsīr). If the word originally meant “the People of the Book” on the occasion of its revelation, what qarīnah (contextual factor) changes the denotation to mean something entirely different? Even a simple translation of the verse will show what the context is (for example, 16: 43 from the Majestic Qur’ān – Nawwawī and Ibn Khuldūn Foundations): “The messengers We sent before you [O Muhammad] were only men to whom we gave the revelation. Ask the People of the Reminder if you do not know.” The footnote to this translation gives the active participle of the verb “ask” as the pagan Arabs and the explanation of “the People of the reminder” as the Jews (that is the People of the Book). The translation clearly shows that the verse was telling the pagan Arabs that if they thought it strange that the Prophet of Allāh was a human being (and not some angel or something of that sort), they should ask the People of the Book (the Jews) whether the messengers before the Prophet were men or not. In relation to the given context of the verse, if one fully believed that Muhammad (sws) was the Prophet despite being human, why would he still need to ask anything? Clearly, even the directive is rhetorical. However, textual analyses of this verse or of other pertinent verses is not the objective of this essay at this stage. It suffices to show here that there was no consensus on meanings in pertinent verses often quoted in this regard.
9. Wael B. Hallaq, A History of Islamic Legal Theories, 76.
10. Ibid. See also Hallaq, “The Authenticity of Prophetic hadīth: A Pseudo-problem,” 75-90.
11. See Hallaq, “On the Authoritativeness of Sunni Consensus,” 436-448. There are a number of statements attributed to the Prophet in this regard, e.g. “My ummah [community] will not come together on an error.” For more, see: Husayn H. Hassān, usūl al-fiqh (Arabic), (Cairo: Dār al-Nahdat al-‘Arabiyyah,1970), 297. Again, textual critiques on the meanings constructed may be done but is not the object here. For example, does the statement of hadīth translated above necessitate that what exists as a construct outside consensus in interpretation (if at all such consensus in this regard took place and/or remained unchallenged) was bound to be erroneous? Considering that to be so is clearly fallacious. If there is a difference, there is no consensus. “If there has been a consensus (depending on what we mean by the term in terms of time period and people involved), there is certitude and inerrancy of interpretation.” If the above two statements are considered as true, it still does not follow that, when there is a difference of opinion rather than consensus, none of the interpretations could be correct.
12. Sayf al-Dīn al-Āmidī, Al-Ihkām fī Usul al-Ahkām, 3 vols. (Cairo, 1968), vol.1, 237-238; cited in Wael B. Hallaq, “On the Authoritativeness of Sunni Consensus,” 444-445.
13. Sayf al-Dīn al-Āmidī, Al-Ihkām fī Usul al-Ahkām, 164, 238; cited in Wael B. Hallaq, “On the Authoritativeness of Sunni Consensus,” 444-445.
14. In Sufi epistemology, absolute religious certitude can be had directly from the Theophany, the Prophet’s soul, the souls of other prophets, or angels. This is the kind of certitude that, in the words of al-Ghazālī (
450 - 505 / 1058 - 1111), leaves no room for doubt (lā yubqī fīhi rayb). Abū Hāmid al-Ghazālī), Al-Munqidh min al-Dalāl, 6-7, 11. Such certitude in religious guidance is often tantamount to an addition to the sharī‘ah. Ironically, Ahmadīs were declared as non-Muslims in Pakistan for accepting similar claims by Mirzā Ghulām Ahmad Qādiyānī, who also declared himself a prophet of sorts. See Yohanan Friedmann, Prophecy Continuous: Aspects of Ahmadī Thought and its Medieval Background (Berkeley: University of California Press, 1989), 83-145. The Shi‘ite community also grants certitude of religious knowledge to the ma‘sūm imāms. See Rahman, Islam, 173-175. Throughout Muslim history—and even today—the concept of such certitude -- whether through the Shi’ite concept of ma‘sūm imāms or the Sunni concept of ijmā‘ -- has also been an important basis for the legitimacy of claims to political, legal and social authority.15. Jāvēd Ahmad Ghāmidī, personal interview, 20 August 2003.
16. C. Snouck Hurgronje, N.J. Coulson, and Joseph Schacht also held similar opinions. George Hourani tried to show that ijmā‘ does not rest on a petitio principii, but conceded that there is no sound basis for consensus in Islam. See Hallaq, “On the Authoritativeness of Sunni Consensus,” 428-430. Hallaq has attempted to refute most of these opinions. Ibid., 427-454.
17. One of the earliest writers to give this argument was the Mu‘tazilī jurist and theologian ‘Abd al-Jabbār al-Asadabādī (d.415
/ 1024). See Hallaq, “On the Authoritativeness of Sunni Consensus,” 434-439.18. Ibid.
19. This aspect of my argument needs further elaboration, which I hope to do in a detailed article.
20. Take the legal procedure for evidence as an example. In Sunni legal theory, four men must have witnessed a case of fornication for the offenders to be sentenced to the hadd (Qur’ānic punishment) of a hundred stripes. See Thomas Patrick Hughes, A Dictionary of Islam, (reprint Lahore: Kazi Publications 1885), 111-112. Supposing the crime of fornication has been proved by circumstantial evidence, the sentence of ta‘zīr (non-Qur’ānic punishment for a crime proved through “less reliable” sources) rather than hadd is applied owing to “inferior evidence” in terms of Sunni epistemology. The question is that if the crime has been proved to the extent that the sentence has to be given, and if “inductive corroboration” is evidence enough for certitude in epistemology, why shouldn’t the punishment of hadd be prescribed (for fornication) on its basis, especially in consideration of the fact that in no place in the Qur’ān, or even in the hadīth, is there any specification for a distinction to be made on this basis. As Ghāmidī puts it, such distinction is an absurdity in law. Either a crime is proved in a court of law or it is not. If it is proved, why not hadd? If it is not proved, why even ta‘zīr? Mitigation in punishment is granted primarily on the basis of the lower severity of the crime, not on the basis of a weakness in evidence. If the evidence for a specific crime is less conclusive than the admissible limit, then the punishment for that crime cannot be given at all. If it is within the admissible limit, then it is injustice on the part of a legal system not to give the punishment originally prescribed for that crime. Ghāmidī, Burhān (Lahore: Dānish Sarā, 2000), 32-33. In Pakistani law, based on Sunni legal theory, even if a hundred of the most reliable and pious Muslim women in the world give the most sound testimony in a case of rape committed in broad daylight, their evidence will not lead to hadd in the absence of the required number of male witnesses. The question is whatever happened to inductive corroboration here? Quite clearly, the whole procedure is based on jurists’ hadīth based interpretation of certain Qur’ānic verses rather than on consideration of what can logically comprise conclusive or even reasonably acceptable evidence.
21. Ahmad ‘Alī al-Imām quotes a number of Muslim authorities to suggest that the seven readings compiled by Ibn Mujāhid are authentic. Al-Imām, Variant Readings of the Qur'ān, 125-130. Ghāmidī’s associate, Shehzad Saleem, cites a number of early Muslim authorities to show that, except for one usually referred to as the reading of Hafs from ‘Āsim), the rest are mashhūr at best but not mutawātir. Shehzad Saleem, “Collection and Transmission of the Qur'ān,” Renaissance 10 (Lahore, February 2000): 5-54. Ghāmidī regards only this reading as mutawātir going back to the Prophet himself. Ghāmidī, Mīzān, 23-33. With somewhat different reasoning and argumentation, this view is close to that of John Burton's on the collection of the Qur'ān. Burton, Collection of the Qur’ān, 226-240. See also John Burton, “Collection of the Qur’ān” in Encyclopaedia of the Qur’ān (Leiden: E.J. Brill, 2001). For a synopsis of critiques on the traditional Muslim view in Western literature, see John Gilchrist, Jam‘al-Qur’ān: Codification of the Qur’ān Text, (Warley, U.K.: T.M.F.M.T., 1989). See also Herald Motzki, “The Collection of the Qur’ān A Reconsideration of Western Views in Light of Recent Methodological Developments,” in Fachzeitschrift Der Deutschen Morgenlandischen Gesellschaft. (Berlin, Walter de Gruyter GmbH & Co., 2001), 1-34; and John Wansbrough, Quranic Studies: Sources and Methods of Scriptural Interpretation. (Oxford: Oxford University Press, 1977).
22. See Hallaq, “The Authenticity of Prophetic hadīth: A Pseudo-problem,” 75-90.
23. As in the case of the concept of naskh dūn al-tilāwah (abrogation without the reading) on account of the ahādīth related to Prophetic practice of stoning to death for certain crimes of sexual activity. For relevant details, see John Burton, The Collection of the Qur’ān (Cambridge: Cambridge University Press, 1977), 226-240. See also John Burton, “Abrogation” in Encyclopaedia of the Qur’ān (Leiden: E.J. Brill, 2001).
24. See footnote 17.
25. As I have attempted to show here.
26. For instance, in the case of the inheritance of kalāla relatives, while readjusting the proportion of certain shares, jurists rely on some form of ‘awl (proportionate decrease), which is necessitated by virtue of the fact that, vis-à-vis the interpreted verses of the Qur’ān, the divided parts of the whole add up to more than one. The corollary is obvious: we can accept either the omniscience of God or the infallibility of ijmā‘ in interpretation and ijtihād. See Ibn Rushd al-Hafīd, Bidāyat al-Mujtahid wa Nihāyat al-Muqtasid, vol.2 (Beirut: Dār al-Ma‘rifah, 1997) 161-163. See also N.J. Coulson, Succession in the Muslim Family Law (Cambridge: Cambridge University Press, 1971), 65-78.
27. In the context of Pakistan, for examples of attempts at change thwarted by the ‘ulamā on this pretext, see Alamgir Muhammad Serajuddin, Sharī‘ah Law and Society: Tradition and Change in South Asia, (Oxford: Oxford University Press, 1999).
28. For many examples of this, see Hallaq, A History of Islamic Legal Theories, 96-254. See also idem “Non-Analogical Arguments in Sunni Juridical Qiyas, Arabica 36 (1989): 286-306; reprinted in Wael B. Hallaq, Law and Legal Theory in Classical and Medieval Islam, V. Idem “The Primacy of the Qur'ān in Shātibi’s Legal Theory,” Islamic Studies Presented to Charles J. Adams eds. W.B. Hallaq and D.P. Little (Leiden, 1991); reprinted in Wael B. Hallaq, Law and Legal Theory in Classical and Medieval Islam, XI. Idem “usūl al-fiqh: Beyond Tradition,” Journal of Islamic studies 3 (1992): 172-202; reprinted in Wael B. Hallaq, Law and Legal Theory in Classical and Medieval Islam, XII.
29. For instance, the concept of tamlīk in Hanafī fiqh for the payment of zakāh whereby the money must be given in possession of an individual recipient. To receive money for the madrasah, the individual orphans studying there are made to donate their share to the madrasa. For a critique of the concept of tamlīk, see Amīn Ahsan Islāhī, Tawdīhāt (1956; reprint Lahore: Islamic Publications Ltd., 1985), 107-173.
30. That is ijmā‘ of the whole Muslim community rather than that of scholars alone.
31. Jāvēd Ahmad Ghāmidī, personal interview, 20 August 2003. To Ghāmidī, the term al-sahābah (the companions) refers to only those followers of the Prophet (sws) who participated closely with him in his mission to a reasonable extent and remained committed to him and his cause in the vicissitudes of his struggle. Ghāmidī takes this idea from Islāhī. Islāhī, Mabādī-i- Tadabur i-hadīth, 78-87.
32. Ghāmidī, Mīzān, 9-11. Ghāmidī makes a clear distinction between the sunnah of the Prophet (sws) in religion and the hadīth. Among their many differences, one lies in the mode of transmission. This sunnah, in Ghāmidī’s opinion, is transmitted through ijmā‘ or tawātur whereas the hadīth is transmitted through akhbār ahād. Also, the term ijmā‘ and tawātur in this context have meanings in Ghāmidī’s works somewhat different from the sense in which jurists use these terms.
33. Ghāmidī, Mīzān, 9-11.
34. Ibid.
35. Ghāmidī, personal interview, 20 August 2003.