The participation of women passive resisters was a key element of the Satyagraha Campaign of 1913 - 1914. Angered by the Supreme Court judgement in March 1913, in which, Judge Searle refused to recognise Hindu and Muslim marriages, Indian women joined the Campaign for the first time.
When Valliamma Munuswamy Mudaliar was sentenced to prison, she was already a little unwell. Her condition soon began to deteriorate, but she refused the offer made by the authorities to return her to her home. She was not prepared to give up the passive struggle. She was eventually released on 11 February 1914, after a provisional agreement had been signed between General Jan Christiaan Smuts and Mohandas Karamchand Gandhi. She arrived home on 20 February, and on 22 February died.