When the Sacred Is Bulldozed: Why Recognition of Cultural Heritage Harm Rarely Leads to Repair

International financial institutions (IFIs) have enacted safeguard policies to protect cultural heritage in their operations. But when their accountability systems identify that harm to cultural heritage has occurred, the institutions rarely respond by delivering repair. These lapses reflect a key deficiency in the accountability system: cultural loss is often reduced to a procedural issue, with consultation mistaken for justice and action plans for remedy.

This piece draws on Accountability Console data and three emblematic case studies to show how institutions acknowledge cultural harm but routinely fail to remedy it. The first of these begins in India.

Jharkhand, India: When the Sacred Is Bulldozed

“We are the Adivasi (Indigenous or original inhabitants) Santhal community of Jharkhand, India. Our common cultural resources, livelihood, and autonomy have been affected by the Rural Water Supply and Sanitation Project for Low Income States.”

So begins a letter submitted to the World Bank’s Inspection Panel in September 2018, describing a rupture that remains unrepaired. At the heart of the Santhal and Ho Adivasi communities’ complaint was the construction of a water treatment plant atop a sacred hill in Bagbera, a village on the outskirts of the planned Jamshedpur Urban Agglomeration. The project—part of a $500 million rural water initiative—was financed by the International Development Association, the Bank’s concessional arm.

“The water treatment plant is being constructed on our common community land,” they wrote. “This land has deep historical and cultural significance for the community, and the Scheme will disrupt our way of life and customs.”

In 2016, construction crews arrived without warning. There were no community meetings, no consultation, no disclosure of plans—only police presence. “The first time many community members learned about the Scheme… was the day that machinery was brought to the village in the presence of police.” When residents objected, they say, they were threatened and beaten.

Soon after, the state criminalized their protest. Thirty-nine villagers were charged with offenses ranging from rioting to attempted murder. As of 2022, no evidence had been filed—but the charges remain, cutting off access to employment, government benefits, and police-issued documents.

Despite repeated protest, the apex of the hill—the most sacred point—was razed. Ritual plants disappeared. Grazing land was lost. And the red mud used to bury the dead, purify the living, and mark the home became unreachable.

In 2018, the Panel investigated and found that Management failed to identify and assess culturally significant sites through site-specific environmental and social assessments, contributing to irreversible harm to the communities’ spiritual practices and way of life. While a statewide Tribal Development Plan was prepared, the absence of site-specific instruments meant that directly affected communities lost access to sacred spaces and customary lands without prior consultation or mitigation. Environmental Management Plans were finalized only in June 2019, after major construction milestones, undermining the safeguards’ preventive purpose. These cumulative failures amounted to non-compliance with Bank policies on Environmental Assessment, Indigenous Peoples, and Physical Cultural Resources, and resulted in material harm the Bank failed to prevent or remedy.

In its Management Action Plan, the Bank acknowledged some policy non-compliance but pushed back on some of the Panel’s findings. The Bank committed to reviewing, commenting on, and/or monitoring a range of borrower-led, post-hoc measures, including finalizing and disclosing safeguard instruments, improving grievance mechanisms, restructuring local water governance bodies to include tribal representation, and engaging in “Gram Sabha” or consultative meetings with project-affected communities under tribal leadership. And while these measures may address some non-compliance or policy shortcomings reflected in the complaint, they do not come close to remedying the substance of what was lost.

The Santhals were unequivocal about the remedy they sought. “Being the affected people, we should be allowed to participate in the analysis of the probable alternatives and decision-taking procedures. This treatment plant should be shifted and our ancestral cemetery and holy park should be restored.” Adding, “[w]e are not asking for charity. We are demanding dignity.” But the Bank not only ignored their principal demands—the relocation of the water treatment plant and the restoration of their ancestral cemetery and ritual park—it designed a response that carefully avoided it and treated policy-level engagement as a stand-in for actual remedy.  

Documented Harm, Absent Repair

What happened in Jharkhand is echoed—again and again—across IAM systems. Of the 123 cultural heritage complaints tracked by the Accountability Console, a consistent pattern emerges: institutions document harm, but rarely deliver repair.

Complaints may go through compliance review (to investigate alleged policy non-compliance) or dispute resolution (to mediate solutions). Some pursue both. But neither path reliably delivers restoration of cultural heritage loss. Just 13% of dispute resolution (DR) cases ended with agreements. In compliance cases, only 35% found non-compliance —while nearly half never triggered a review.

Of all closed, or completed cases, only 34% were “Closed with Outputs”—meaning only that a compliance report or a dispute resolution agreement resulted from the process, and not necessarily that remedy was substantive or implemented. Another 34% of completed cases closed without generating a compliance report or dispute resolution agreement.

Even when institutions commit to action, most promises fall short. Across these 123 cases, 427 commitments were made—but only 255 have been completed. From compliance review, just 6.3% of commitments were fulfilled; from dispute resolution, 7.5%. The rest remain “planned,” in progress, or abandoned.

But the more revealing failure lies in what kind of remedy is promised. Of the 427 commitments, 100 (23.5%) address operations management, 85 (19.8%) involve consultation, while 61 (14.2%) focus on monitoring—that is, internal policy changes, additional engagement meetings, or procedural oversight. By contrast, only 44 commitments (10.4%) directly address cultural heritage—like restoring sacred spaces or preserving ancestral sites. Even fewer relate to compensation (5%), resettlement, or rights recognition (each <3%). Of those 44 cultural heritage commitments, only 2 are marked complete—both from mediated settlements.

These statistics underline a fundamental gap between the Development Financial Institution’s (DFIs) conception of the indispensable significance of cultural heritage, appreciation of the intergenerational harm communities suffer from its destruction or desecration, and what it takes to remedy it and those of the affected communities. For these communities, actual remedy often includes restoring what was lost, safeguarding tangible cultural heritage from any and every damage, or re-establishing cultural practices ruptured as a result of harm in ways that align with their values. For DFIs, it too often means a revised action plan, a stakeholder meeting, or a memo.

As the Inter-American Development Bank (IDB) acknowledges in its guidance note Managing the Impacts of IDB Projects on Cultural Heritage, cultural heritage is not merely a historical artifact or property—it is a living system of meaning, social cohesion, and identity. This understanding of the centrality of cultural heritage to a people’s self-conception is echoed by Dr. Dacia Viejo Rose, an associate professor of Heritage and the Politics of the Past and Director of the Cambridge Heritage Research Centre at Cambridge University. In a 2022 article about the deliberate destruction of cultural heritage during wartime and how (not) to repair it, Dr. Rose writes that “Today [cultural] heritage is understood by critical heritage scholars as a process of meaning-making with constantly evolving associative values that make it highly political.” 

In practice, this understanding is often flattened or ignored. DFIs may recognize that harm occurred, but stop short of doing anything to repair it. This failure cuts deepest when the loss severs the ties that hold a community, or an entire people, together. It is especially damaging because the harm is not confined to a loss of a physical structure. It strikes at something deeper: a community’s sense of self. It strikes at how communal identity is practiced, honored, transmitted, and made real. The physical structures become living conduits through which communities affirm who they are, where they come from, and what binds them together (aspirations, values, beliefs, e.t.c.). When those spaces are harmed, a rupture that’s often irreversible occurs. And the result? An interference with the mechanisms a community uses to reproduce itself socially and culturally. Ultimately, people lose access not just to the tangible, but to the intangible: ways of knowing, relating, and belonging that give that entity life, meaning, and purpose. 

Further, IFIs remain poorly equipped to apprehend harm that is not easily commodified. Rooted in development logics that prize growth, utility, and quantification, IFIs struggle to locate meaning in the immaterial. Valuation methodologies flounder when asked to price the loss of a cultural heritage property. Risk matrices are designed to capture environmental or economic hazards—not cultural unmooring. The result is a profound misalignment between how affected communities experience cultural harm and how institutions assess and respond to it. As noted in IDB’s guidance, this produces a “technical vs. sacred” divide. Cultural harms are re-coded as intangible, tangential, or secondary—susceptible to mitigation rather than prevention, consultation rather than restitution. Cultural sites become negotiable. Dispensable. 

Other cases echo this dynamic.

Samoa and Côte d'Ivoire: The Pattern Repeats

In Samoa, the Asian Development Bank’s effort to promote leasing of customary land raised early and sustained concerns from matai (customary leaders) and civil society groups. While framed as an economic development project, the initiative threatened to unravel collective land governance and spiritual ties to ancestral territory. Complainants cited the exclusion of diaspora Samoans, consultation processes dominated by state-aligned trustee matai, and legal reforms that enabled land alienation without culturally grounded safeguards. Although the Bank’s facilitator acknowledged the centrality of land to Samoan identity, the consultation design sidelined complainants from shaping the process. When it became clear that the process was managing concerns rather than addressing them, complainants withdrew. The Bank closed the case with procedural outputs and no substantive shift. A compliance review was later declined—not because the harm was disproven, but because the legal reforms implicated were deemed sovereign, and therefore beyond the Bank’s jurisdiction. This jurisdictional limit—not the absence of cultural heritage harm—foreclosed a deeper accountability process. The CRP decision left unresolved the central harm raised by the complainants: the erosion of spiritual and communal ties to land through legal frameworks catalyzed, at least in part, by ADB engagement.

In Côte d’Ivoire, the African Development Bank’s Abidjan Urban Transport Project triggered a complaint when a proposed access road threatened to destroy the ancestral home of Adjamé’s village founder, the current chief’s residence, and sacred ritual structures vital to spiritual life and traditional governance. Despite repeated warnings, project authorities refused to reroute the road, withheld planning documents, and conducted only limited consultation with traditional leaders. The environmental and social impact assessment acknowledged potential harm but emphasized environmental mitigation over cultural protection. Through mediation, the Bank disclosed documents, offered temporary housing, and resolved compensation issues—but the spiritual core of the complaint went untouched. No preservation plan for sacred sites was adopted. The case was closed with outputs. The shrines, homes, and ritual grounds were not preserved. The harm, though formally processed, was never repaired.

The Development Finance System Wasn’t Built for Repair

Each of these cases reveals the same disjuncture: cultural heritage harm is acknowledged, but left unrepaired. Institutions document the loss, but they do not reverse it. They record that ancestral homes were demolished, that ritual sites were disturbed, that ties to land and identity were severed—but they stop short of making communities whole. “Remedy” arrives in the form of memos, reports, or closing statements, yet the harm remains.

This is a failure to understand the nature of what was harmed in the first place. Too often, institutions treat cultural heritage harm as a technical issue to be managed—not as a rupture in the lived and ongoing relationship between people, heritage, culture, and their immediate surroundings. They translate it into policy terms, offer consultations after decisions are finalized, and mistake bureaucratic activity for meaningful redress. The result is a process that checks boxes but does not restore what was lost.

What Real Remedy Requires

To bridge this gap, Development Finance Institutions (DFIs) must reject the idea that cultural heritage harm can be remedied through process alone. Remedy is not a meeting. It is not a disclosure document. It is not a safeguard matrix updated after the fact. Remedy means that what was harmed is made whole—or that every effort is made to come as close to wholeness as possible. And the only people who can define what that looks like are the ones who experienced the harm. 

That requires a different kind of commitment—one grounded in the values and worldviews of the communities themselves. First, avoidance must become the default in project design. Cultural heritage sites—ritual spaces, ancestral homes, cemeteries—should be treated as immovable, not as variables in an engineering plan. This responsibility lies with DFIs. What can be rerouted or redesigned must be. Do not mitigate what can be avoided.

Second, consultation must begin before blueprints exist. Engagement cannot be an afterthought. When consultation happens after design, it is not participation—it is notification. DFIs must ensure that communities are involved from the very beginning, before harm is baked into the project.

Third, living heritage must be treated as infrastructure. Not metaphorically—structurally. Ceremonial landscapes, storytelling traditions, and place-based practices are how communities live, relate, and remember. They must be protected with the same seriousness as roads, pipelines, and treatment plants.

Fourth, IAMs must center community-defined harm and remedy. Remedy cannot be imposed. It must reflect the values and priorities of those harmed. IAMs must create space for communities to define what was lost—and what it would take to restore dignity.

Fifth, financing must be contingent on redress. DFIs should pause disbursements where cultural heritage harm is credibly alleged and unresolved. Remedy must be specific, time-bound, and verifiable—not aspirational.

Finally, monitoring must be reoriented toward meaning. IAMs should not measure success by institutional timelines or outputs. They should ask one question above all: did the people who were harmed feel they were made whole?

Communities know what remedy looks like. Institutions must learn to listen—and follow their lead.