Kohli

I. Background

Kohli was born in Kuwait on October 13, 1980, of Indian parents and is a citizen of India. Her parents were contract workers in Kuwait and in 1990, during the Gulf War, the fam- ily moved back to India. In 1992, her parents returned to Kuwait, but Kohli remained in India with her grandmother to finish her schooling.

Kohli testified that in 1996 while in school she became a member of a human rights association which was interested in human rights and particularly opposed the practices of sati1 1 The New Oxford American Dictionary 1712 (2003) defines sati as “the former Hindu practice of a widow immolating herself on her husband’s funeral pyre.” 650 KOHLI v. GONZALES and dowry. Kohli attended meetings and made fliers. About five months after she joined the association, she attended a small rally of eight to ten people. The police came and told them to stop and took down their school identification num- bers, names and addresses. Kohli and her associates then dis- persed.

A month and a half later Kohli attended a bigger rally near a supermarket with about fifteen members of the association. They handed out flyers to about ten women. Again the…