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UPSC CSE 2024/25

GS-3
MAINS MODULE
By Dr. Shivin Chaudhary
Elements of National Security

Element of National Details


Security

Military Security Protection from Invasion, Terrorism, Cyber attacks


external military
threats

Managing physical Border security, Coastal Security


threats

Economic Security National wealth Economic freedom of state and citizens

Ability to protect Economic sectors

Energy Security Manage uninterrupted Security of international and energy assets


supply of energy

Environmental Security Climate change Internal Displacement, Warming War, Migration

Pollution Transnational in nature

Ethnic Security Avoid sectional conflict Maintain National Integration, Promote national
harmony

Cyber Security Protection of a Developing cyber offence and defence capacity


country's digital
infrastructure

Health Security Disease surveillance Rapid response and emergency preparedness


and early warning
systems

Information Security Protecting citizen's Data Protection Bill


right to privacy

Data as a public good

Protection of information that affects national security

Resource Security Water Conflicts Internal: Cauvery Dispute, External: Indus water
dispute

Political Security Ensuring national sovereignty

Maintaining stability of the government

Honoring human rights of citizens by the state

Geostrategic Security Military co-operation

Strategic autonomy of Defence purchase


Training

Food Security Addressing nutritional poverty

Measures to avoid starvation

Disaster Security Mitigation response

Quick response
National Security Doctrine

What is a National Security Doctrine?

A National Security Doctrine is a set of basic principles, based on the core interests of the
State, that will shape how different elements of national power protect and further the interests
of the Indian Republic. It is a concise summary of a country’s strategic vision and objectives,
intended to prepare the nation to manage future challenges.

In particular, there is a need to focus on the elements of a strategic doctrine which will identify
the general missions and basic principles through which our armed forces, diplomatic and
intelligence communities will seek to attain the national goals.

Quotes

The new frontiers of war, what you call the fourth-generation Ajit Doval
warfare, is the civil society.

“Half-done reforms create new vulnerabilities without solving old Shivshankar Menon
ones. You cannot cross a chasm in two leaps. We are today in a
situation where many of the reforms begun by the former CDS,
General Bipin Rawat are incomplete.”

“Three attempts were made to come out with a national security Shivshankar Menon
strategy, but there was hesitation at the political level. It could have
been because of the accountability it would bring in defence
management for the government.”

“India has a deeply ingrained tradition of strategic restraint arising Stephen P Cohen and
from an ideological rejection of the use of armed force as a tool of Sunil Das Gupta
colonisers. In rejecting colonisation, India has also rejected the
instruments used by colonisers.”

“The absence of a written National Security Strategy (NSS) doesn’t


mean that the country doesn’t have one. If there was no policy, the Chief of Defence Staff
country would not have been successful in revoking the special (CDS) General Anil
status of Jammu and Kashmir under Article 370, or carried out Uri Chauhan
and Balakot strikes.”

Why in the News?

India has initiated the process of formulating a National Security Strategy after years of
discourse and deliberations within the military and strategic community on the need for such a
framework. The National Security Council Secretariat (NSCS) is currently working on a
comprehensive National Security Strategy in consultation with several Central ministries and
departments. A final Cabinet approval will be sought once the strategy is complete.
Need of National Security Doctrine

● Responding effectively to New Domains of Warfare


○ Complex Threats: Growing frequency and sophistication of traditional threats,
and non- traditional threats (cyber attacks, narco-terrorism and eco-terrorism).
○ Technological Advancements: Expansion of the battlefield through advanced
technologies, which nullify traditional military advantages.
○ Grey Zone Warfare: Operations that exist in the ambiguous space between
peace and war, complicating conventional responses.
○ Digital Age: Transformation of the battlespace by digital technologies, requiring
updated strategies and capabilities.
○ Civil Society: The new frontiers of war, what you call the fourth-generation
warfare, is the civil society.- Ajit Doval
○ Proxy Wars: Increased reliance on proxy actors to conduct warfare,
necessitating comprehensive and adaptable security strategies.
● Recommended by Previous Committees:
○ Kargil Review Committee: Proposed integrating India’s security spectrum. It set
up four task forces for reforms, whose recommendations have not been
implemented
○ Naresh Chandra Task Force on Security (2011): Emphasized the need for a
national security strategy at the doctrinal level.
● Essential to Draft Before Theaterisation:
○ Former Indian Army Chief General M.M. Naravane highlighted the need to
establish a national security strategy before implementing theaterisation. He
argued that discussing theaterisation without a clear national security strategy is
like putting the cart before the horse​
● Clarity and Strategic Foresight:
○ Currently, the focus on military, paramilitary, and security/intelligence agencies is
scattered. A national security document could offer clarity and strategic foresight
for the modernization and integration crucial for India’s national security.
● Integration of Threat Perception:
○ Blurring Lines: The distinction between internal and external threats is
increasingly blurred.
○ 2.5 Front War: Former CDS General Bipin Rawat mentioned India’s
preparedness for a two-and-a-half front war, addressing challenges from China
and Pakistan, along with internal security threats
○ Galwan Incident and Intelligence Failures: In 2020, the clash in the Galwan
Valley, a disputed region between India and China, resulted in violent
confrontations and casualties on both sides. This incident is often cited as an
intelligence failure but is more accurately described as a failure in managing
intelligence.
● Absence leads to Half-done Reforms:
○ As per Shivshankar Menon, “Half-done reforms create new vulnerabilities without
solving old ones. You cannot cross a chasm in two leaps. We are today in a
situation where many of the reforms begun by the former CDS, General Bipin
Rawat are incomplete.”
● Enhances Country’s Comprehensive National Power:
○ India’s national security architecture has objectives, yet the absence of a policy
paper hinders addressing the heightened threat matrix. A synergized national
security strategy is crucial, offering comprehensive attention and strategic
foresight. It enhances the capabilities of military, paramilitary, and
security/intelligence agencies, solidifying our Comprehensive National Power.
● Algorithm to aid policymakers:
○ A doctrine enables us to provide a practiced response rather than one which will
be ad hoc and haphazard. It acts like an algorithm that aids policy makers in
making decisions and helps citizens in understanding them. The confusion and
indecision often seen in the political class during crises, due to the absence of
clear-cut and customary responses, is well known. Eg, The IC 814 hijacking
incident.
● Increasing Proxy Wars and Strategic Contestation:
○ US-China/Russia Rivalry: The current environment is witnessing increasing
proxy wars and intense strategic contestation between the US and China/Russia.
○ Afghanistan as Terrorism Epicenter: With the withdrawal of the US,
Afghanistan has reemerged as the epicenter of terrorism. China has no qualms in
maintaining links with Jihadi elements to exploit the situation for its benefit.
○ Pak-China Axis: The Pak-China axis continues to pose serious challenges to
regional stability and security.
○ Impact of Hamas-Israel Conflict: The Hamas-Israel war has energized Jihadi
groups, necessitating a clear assessment and indication of their implications.
● Global Examples:
○ The United States, United Kingdom and Russia: They maintain and regularly
update a National Security Strategy, outlining their security objectives and
strategic priorities.
○ China: China has a Comprehensive National Security strategy, which is
intricately linked to its governance structure, reflecting its broad security
objectives and strategic priorities.
○ Pakistan: Pakistan introduced its National Security Policy 2022-2026, which
outlines its national security objectives and priority areas, aiming to address both
traditional and non-traditional threats.

What will it contain?

● National Interests and Values:


○ Defining National Interests: The National Security Strategy (NSS) must clearly
define national interests, which are specific ideas derived from broader national
values.
○ Translating Concepts into Goals: These interests are then translated into national
goals, focusing efforts on achieving them.
● Strategic Culture and Diplomacy:
○ The NSS needs to clarify that India’s strategic culture prioritizes finding amicable
solutions to problems through diplomatic negotiations rather than seeking wars
but retains the right to use force when necessary, necessitating the substantial
expansion of both traditional and military diplomatic cadres as India rises.
● Communication of Objectives and Deterrence:
○ The NSS must convey messages to allies about the nation's objectives at
regional and global levels and outline redlines to adversaries. This strengthens
deterrence by indicating the steps to be taken if its interests are harmed. For
instance, If Pakistan had been sufficiently forewarned that an attack in Kashmir
could result in an Indian riposte to Lahore, it may have avoided the 1965
misadventure.
● Periodic Updates:
○ The NSS must be periodically updated to reflect the evolving geopolitical
landscape and emerging threats, ensuring that the strategy remains relevant and
effective in addressing current and future challenges.

What has not been done so far?

● According to Former Army Chief General NC Vij (retd, “Only political direction to the
Armed Forces in existence is Raksha Mantri’s operational Directive of 2009. It is now
dated and hence needs to be revised.”
● Political Hesitation: According to Shivshankar Menon, “Three attempts were made to
come out with a national security strategy, but there was hesitation at the political level. It
could have been because of the accountability it would bring in defence management for
the government.”
● Lack of Cohesive Effort: There have been varying views in the strategic community
about why India has not brought out a national security strategy, including the lack of a
cohesive, whole-of-government effort to formulate and implement such a strategy.
● Deliberate Non-Disclosure: Another perspective is that the government has
deliberately chosen not to make its national security objectives public, possibly to
maintain strategic ambiguity and flexibility in its defense and security policies.

Challenges in framing:

● Poor Civil-Military Relationships:


○ Lack of Joint Leadership: The absence of a unified command among the
armed forces leads to each service focusing on its own doctrines without a
cohesive approach.
○ Limited Input in Policy-Making: Service chiefs have operational autonomy but
minimal influence in national policy-making.
● Strategic Restraint:
○ As per Stephen P Cohen and Sunil Das Gupta, “India has a deeply ingrained
tradition of strategic restraint arising from an ideological rejection of the use of
armed force as a tool of colonisers. In rejecting colonisation, India has also
rejected the instruments used by colonisers.”
● Divergent Military Goals:
○ According to Walter Ladwig, Lecturer in International Relations at Oxford
University, the Army seeks to leverage advanced technology to fight
short-duration wars in a nuclear environment; the Navy seeks a potent blue water
role with the introduction of nuclear-armed submarines; the Air Force wants to
extend its strategic reach from the Persian Gulf to the Straits of Malacca. Military
doctrines should be a subset of the national security doctrine, and there is an
urgent need for India to develop a joint war fighting doctrine instead of relying on
single-service doctrines.

Counter-view

“The absence of a written National Security Strategy (NSS) doesn’t mean that the country
doesn’t have one. If there was no policy, the country would not have been successful in revoking
the special status of Jammu and Kashmir under Article 370, or carried out Uri and Balakot
strikes.” : Chief of Defence Staff (CDS) General Anil Chauhan

In 2014, when Ajit Doval assumed the role of National Security Advisor in India, a doctrinal
change took place. Doval introduced a strategic doctrine that now bears his name: the Doval
Doctrine or double squeeze strategy.

Conclusion:

In addition to intensifying geopolitical competition, the threat landscape and security challenges
are expanding into various technological domains, escalating the tempo of grey zone warfare in
an already conflict-ridden geopolitical landscape and making the threats more real and lethal. A
vigilant and adaptive national security craft is essential to safeguard India’s interests in this
complex and dynamic security environment.
Left Wing Extremism

What is Left Wing Extremism?

Left-wing extremism (LWE) is a political ideology that advocates for radical social, political, and
economic change through the abolition of capitalism, the establishment of a socialist or
communist system, and the dismantling of existing power structures. LWE groups often employ
violent tactics to achieve their goals, including bombings, assassinations, and armed
insurrections.

YEAR QUESTION MARKS

Article 244 of Indian Constitution relates to Administration of


2013 Scheduled areas and tribal areas. Analyze the impact of 10
non-implementation of the provisions of fifth schedule on the
growth of Left Wing Extremism.

The persisting drives of the government for development of large


industries in backward areas have resulted in isolating the tribal
2015 population and the farmers who face multiple displacements with 12.5
Malkangiri and Naxalbari foci, discuss the corrective strategies
needed to win the left wing extremism (LWE) doctrine affected
citizens back into the mainstream of social and economic growth.

2018 Left Wing Extremism (LWE) is showing a downward trend, but still
affects many parts of the country. Briefly explain the Government 10
of India’s approach to counter the challenges posed by LWE.

2020 What are the sound determinants of left-wing extremism in


Eastern part of India? What strategy should Government of India, 15
civil administration and security forces adopt to counter the threat
in the affected areas?

2022 Naxalism is a social, economic and developmental issue


manifesting as a violent internal security threat. In this context, 15
discuss the emerging issues and suggest a multilayered strategy
to tackle the menace of Naxalism.

Quotes

“We must, however, recognize that naxalism is not merely a law and Dr. Manmohan Singh
order issue. In many areas, the phenomenon of naxalism is directly (Former Prime
related to underdevelopment. It is not a coincidence that it is the Minister)
tribal areas that are the main battleground of left wing extremism
today.”

“The Constitution intends that the land always should remain with Samatha Case
the Tribals.” Judgement
“Those who've taken the path of Naxalism & Terrorism must Hon’ Prime Minister
recognise the power of non-violence. It will make India stronger & Narendra Modi
serve humanity”

“Movement is on its last legs” K. Vijay (Special


Security advisor of
MHA)

Areas of Maoist Presence


Statistics and data from various newspaper and websites

Left Wing Extremism (LWE) / Naxalism in India

Affected States

● LWE Affected States:


○ Chhattisgarh, Jharkhand, Odisha, Bihar, West Bengal, Andhra Pradesh,
Telangana, Maharashtra, Madhya Pradesh, and Kerala.

Violence Statistics

● Casualties (2004-2023):
○ Total: 8,863 people killed.
○ Civilians: Majority are tribals, often branded as ‘police informers’.
● Comparative Statistics:
○ 2004-2014: 17,679 incidents and 6,984 deaths.
○ 2014-2023 (till June 15): 7,649 incidents and 2,020 deaths.
○ Improvement: Incidents reduced by 52% (from 14,862 to 7,130); deaths reduced by
69% (from 6,035 to 1,868).
● Recent Trends (2020):
○ ACLED Records: 20% decrease in organized political violence involving Naxal-Maoist
insurgents.
○ Reported Events: Total events decreased from 295 to 235; fatalities decreased by
nearly 30%.
● Decline in Violent Incidents:
○ 2022: Violent incidents decreased by 77% compared to the peak in 2010.
○ Districts Affected: Reduced from 90 in 2010 to 45.
● Decrease in Casualties:
○ 2022: Deaths reduced by 90% (from 1,005 in 2010 to 98 in 2022).

Evolution of Left Wing Extremism


Phase Description

First Phase ● Initial Outbreak: In 1967, insurgency began in West Bengal, Bihar, and
(1969-1972) Srikakulam district of Andhra Pradesh.
● Naxalbari Incident: A tribal youth's assault in Naxalbari village, West
Bengal, sparked a country-wide controversy, leading to the formation of
the CPI (ML) in 19679 under Charu Majumdar.
● Movement Spread: Rapid spread to rural West Bengal, Bihar, Andhra
Pradesh, and urban Kolkata.
● Suppression: United Front government in West Bengal, with Indira
Gandhi's Congress government, crushed the movement by 1972.

Second Phase ● Emergency Period: Naxalite movement factionalized during the


(1975-2004) Emergency (1975-77).
● Post-Emergency: Four main factions emerged: MCC, PWG, Party Unity,
and CPI-ML (Liberation).
● Strategies: CPI-ML (Liberation) took part in elections, while others like
PWG and MCC focused on armed struggle.
● Merger: In 1998, Party Unity merged with PWG to form CPI-ML (People's
War).
● Regional Control: MCC operated in Bihar/Jharkhand; PWG in northern
Telangana.
● Caste Warfare: Violent clashes in Bihar between lower-caste Dalits
(supported by MCC) and upper-caste vigilante armies (Ranvir Sena,
Sunlight Sena).

Third Phase ● Merger: In 2004, PU, MCC, and PWG merged to form CPI-Maoist with a
(2004-2012) unified command structure.
● Increased Threat: Post-2004, Maoist control expanded, and violence
escalated.
● Counterinsurgency: BJP government in Chhattisgarh and Congress
leader Mahendra Karma launched Salwa Judum (2005-09); Operation
Green Hunt (2009-12) targeted Maoists.
● Major Incident: In 2010, Maoists killed 75 CRPF personnel in
Dantewada, leading to public uproar and stalling of Operation Green Hunt.

Fourth Phase ● Decline in Violence: Levels of violence have declined since 2013, below
(2013-present) the 1990s average.
● Possible Reasons: Successful counterinsurgency efforts like the
Integrated Action Plan, road-building projects, police stations in vulnerable
areas, and NREGA projects.
● Strategic Retreat: Maoist leadership may have adopted a strategy of
tactical retreat to avoid further losses.

Drivers of Naxalism
(As per Report of An Expert Group to Planning Commission and ARC II)

Social and Economic Issues

Unresolved ● The intensity of unrest often arises from unresolved social and economic
Social and issues like land rights, lack of economic opportunities, social discrimination,
Economic and inadequate access to basic services.
Issues

Socio-Econo ● The exploitation of dalits and tribal communities, including forced labor and
mic social discrimination, has fueled Naxalism.
Exploitation ● The movement empowers these communities to assert their rights and
demand respect and dignity, challenging oppressive practices like
untouchability and forced labor.

Livelihood ● Lack of food security and corruption in the Public Distribution System (often
Related non-functional).
Causes ● Disruption of traditional occupations and lack of alternative work opportunities.
● Deprivation of traditional rights in common property resources.
● The Minimum Wages Act has not been implemented. While, Naxals have
ensured payment of decent wages in affected areas.

Land and Agrarian Issues

Land Disputes ● Naxalites target oppressive landholders, driving them away and redistributing
and Agrarian land to the landless.
Distress Eg, in Bihar, Naxalites have helped the landless Musahars take possession of
land, although legal title remains an issue due to administrative resistance.

Failure of ● Land reforms, including the introduction of land ceilings and distribution of
Land Reforms surplus land, have had limited impact due to poor implementation, leading to
persistent landlessness and agrarian distress, creating fertile ground for
Naxalite ideologies.

Land Related ● Evasion of land ceiling laws.


Factors ● Existence of special land tenures enjoying exemptions under ceiling laws.
● Encroachment and occupation of government and community lands (even
water bodies) by powerful sections of society.
● Lack of title to public land cultivated by the landless poor.
● Poor implementation of laws prohibiting transfer of tribal land to non-tribals in
Fifth Schedule areas.
● Non-regularization of traditional land rights.

Displacement and Forced Evictions

Forest Rights ● Traditional usufructuary rights of forest dwellers have been declared illegal,
and leading to their displacement. The Forest Conservation Act of 1980 and
Displacement subsequent regulations have perpetually put forest dwellers on the brink of
eviction. Naxalites have exploited this situation to gain support by opposing
such displacement and advocating for forest rights.

Displacement ● Eviction from lands traditionally used by tribals. (40% of those displaced)
and Forced ● Displacements caused by irrigation and power projects without adequate
Evictions arrangements for rehabilitation.
● Large-scale land acquisition for ‘public purposes’ without appropriate
compensation or rehabilitation.

Governance Issues

Inadequate ● Misgovernance, corruption, and the lack of effective local governance have
Governance contributed to the rise of Naxalism. The 73rd Amendment, which aimed to
and empower local bodies, has largely remained unfulfilled, and co-optation of
Corruption local leaders into the corrupt political system has belied genuine
empowerment.

Governance ● Corruption and poor provision/non-provision of essential public services


Related including primary health care and education.
Factors ● Incompetent, ill-trained, and poorly motivated public personnel who are mostly
absent from their place of posting.
● Misuse of powers by the police and violations of the norms of law.
● Perversion of electoral politics and unsatisfactory working of local government
institutions.

Police and State Repression

Police ● Arbitrary police action, harassment by forest department personnel, and brutal
Harassment suppression of agitations supported by Naxalites have intensified resentment.
and State The administration's focus on curbing Naxalite influence often overlooks the
Repression legitimate grievances of the affected populations, exacerbating the conflict.
Social Exclusion and Cultural Alienation

Cultural and ● The alienation of tribal communities from their traditional lands and cultural
Social practices due to state policies and commercial exploitation has created
Alienation deep-seated discontent. The failure to recognize and address the unique
cultural and social needs of these communities has driven them towards
extremist movements.

Social ● Denial of dignity.


Exclusion ● Continued practice, in some areas, of untouchability in various forms.
● Poor implementation of special laws on prevention of atrocities, protection of
civil rights, and abolition of bonded labor, etc.
Eg, Naxal violence in Karimnagar (1980) against forced labour

Psychological Empowerment

Psychological ● The Naxalite movement has provided psychological empowerment to the


Empowerment oppressed, particularly among the youth, who find a sense of power and
identity in the movement. This empowerment comes from challenging the
authority of traditional power holders and participating in a movement that
promises justice and equality.

Approach For Countering LWE

Category Scheme

Physical Special Infrastructure Scheme: Construction of fortified Police Stations; Extended till
Infrastructure 2026

LWE Mobile Tower Project by Department of Telecom

USOF supported scheme in mobile connectivity


In uncovered aspirational districts

NETRA (Micro-Unmanned Aerial Vehicles): Used by CRPF

Assistance to Central Agencies for LWE management

GIS Mapping
School, post offices, health facilities, roads

Rail Services in Bastar

Road Connectivity Project for LWE (Ministry of Rural Development)

Road Requirement Plan-I

Institutional Security Related Expenditure (SRE) Scheme


Measures
Unified Command setup in States of Chhattisgarh, Jharkhand, Odisha and West
Bengal

Special Central Assistance (SCA) for most LWE affected districts for 30 most LWE
affected districts

Civic Action Programme (CAP): To bridge gaps between Security Forces and local
people through personal interaction

Multi Agency Center

State Multi Agency Center: Jagdalpur, Gaya

● Black Panther
● COBRA
● Bastariya Battalion

Operation
Anaconda Jharkhand
C-60 force
(Gadchiroli district) Gadchiroli
India Reserve
Battalions to States Security

Social Tribal Youth Exchange programmes: Organised by Nehru Yuva Kendra Sangathan
Measures (NYKS)

Roshni: Digital literacy and mentorship initiative

Going Online as Leaders (GOAL): Facebook initiative

Livelihood Colleges: Vocational Training

Eklavya Model Residential Schools

11 LWE districts did not have KVs sanctioned by Ministry of Education


Education
Comprehensive Survey of Government’s Approach

● As per Seventh Schedule of the Constitution of India, subjects of 'Police' and ‘Public
order' are with the State Governments. The Government of India has been
supplementing the efforts of States affected by left wing extremism. The Government of
India has adopted an integrated and holistic approach to deal with the Left Wing
Extremist (LWE) insurgency by addressing the areas of security and development and
also promoting good governance simultaneously. To achieve this, a 'National Policy and
Action Plan to Address Left Wing Extremism' has been put in place that adopts a
multi-pronged strategy in the areas of security, development, ensuring rights &
entitlements of local communities, etc

● Security front: The GoI assists the LWE affected State Government by providing
Central Armed Police Forces battalions, training, funds for modernization of State police
forces, equipment & arms, sharing of intelligence, construction of Fortified Police
Stations etc;

● Development side: Government of India (GoI) has taken several specific initiatives in
LWE affected States, with special thrust on expansion of road network, improving
telecommunication connectivity, skilling and financial inclusion.

Development front: apart from flagship schemes of Government of India (GoI) several
specific initiatives have been taken in LWE affected States, with special thrust on
expansion of road network, improving Telecomm connectivity, skill development and
financial inclusion.

● Dominant narratives understand Left Wing Extremism as a law and order problem. We
have continued with historically used three-pronged strategy:
○ Use of force: The use of necessary military force to counter the aggressiveness
of insurgents.
○ Address the grievances of alienated people: By infrastructure upgrades.
○ Address the political demands: With fixed timelines for political deliverables.

● There is a need to adopt a top-down approach, led by the army, instead of a bottom-up
approach. This will create opportunities for army officers as it will allow senior officers
with experience in counter-insurgency operations, ranging from colonels to generals, to
be deployed.

● Empowering security personnel with the ability to use "quick-fix solutions" to address
threats to their safety.

● Assessing experimented strategies: Adopting low-key level strategy (adopted in


North-East) in contrast to the "hammer and tongs" strategy used by the Sri Lankan
forces against the LTTE.

● Government should get the forces to participate in and collectively address a problem
(Maoist insurgency) that cannot have a knee-jerk approach.
● ‘Clear, hold and develop’ strategy can also be implemented, which uses development
as a tool to win back the support of the tribal population, who overwhelmingly appear to
sympathize with the extremists.

Multi pronged Strategy (as discussed in ARC II, Latest MHA Annual Report)

Building ● In seriously disturbed areas where agencies involved with


Capacity of development work find it difficult to operate, there may be a case
Security Forces for temporarily entrusting some development Capacity Building for
(including the Conflict Resolution work to the security forces. This approach was
Police) tried successfully in West Bengal, where the local police helped in
ensuring that schools and health institutions functioned effectively.
● To enhance the capacity of the security forces to act effectively
and firmly but within constitutional bounds, it is necessary that
standard operational procedures and protocols are laid down in
specific terms and detail.
● Formation of specially trained special task forces on the pattern of
the Greyhounds in Andhra Pradesh also form an important
element of the strategy to build capacity in the police machinery
for tackling left extremism.

Building ● Institutional capacity needs to be strengthened within the line


Capacity of departments, particularly within their field formations in tribal
Administrative areas by introducing appropriate management practices to deal
Institutions with the specific needs of marginalised groups and to make
deployment of personnel qualified to cater to area specific needs.
● It is necessary to constitute an Oversight Committee to monitor
the implementation of the FRA, 2006. This committee should
include individuals such as tribals, those committed to forest
conservation and wildlife preservation, and individuals with a
strong social commitment to these causes.

Capacity ● State Governments should give such officers the benefit of being
Building among trained at national level institutions like the LBS National Academy
Government of Administration to professionally equip them to serve in tribal
Personnel areas. Such officers could then bring their exposure and unique
experience in the making of public policies, strategies and
schemes for the development of these areas and the well being of
its citizens.
● There is need for a national policy which could provide for
reimbursing State Governments for the additional resources that
may be required to make it attractive for officers to voluntarily opt
for serving under difficult conditions in such areas.
● The system of periodic official inspections and review of
organisational performance needs to be revitalised.

Capacity ● The Panchayats (Extension to the Scheduled Areas) Act, 1996


Building in needs to be effectively implemented to bridge the governance
Local Bodies deficit in these areas.
Capacity ● Since they have the potential to act as a bridge between the
Building in Civil extremists and the government and in educating the people about
Society the futility of violence and preventing aggravation of the situation
Organisations by ventilating public grievances within the legal-democratic
framework.
● Ways and means of involving such organisations in conflict
management can be also taken up.

Cutting the ● This work can be entrusted temporarily to organisations like the
Source of Border Roads Organisation and other governmental agencies
Finances for which can execute these works directly.
Naxalites ● An effective anti-extortion and economic offences wing that can
curtail if not totally dry up the funding sources to extremists, has to
be constituted.

Way Forward
(As suggested by Second ARC Report and Latest MHA Annual Report)

N: Negotiations for ● While agreeing with the spirit of the


Conflict SAMADHAN strategy’, negotiations
Resolution with the extremist outfits should be an
important mode of conflict resolution.

A: Administrative ● There is a strong case for ‘back to the basics’ in the matter of
Monitoring administrative monitoring and supervision. The system of periodic official
Enhancement inspections and review of organisational performances needs to be
revitalised. It must be recognised that a major reason for such practices
falling in disuse in ‘disturbed areas’ is the apprehension of senior
functionaries about their personal safety while on tour. It is advisable
that the need to provide suitable security to the senior administrative
and technical officers while on tour, is taken into account in working out
requirements for security forces in areas affected by serious violence.

X: eXtension of ● For effective implementation of the Scheduled Tribes and other


Legal Frameworks Traditional Forest Dwellers (Recognition of Rights) Act, 2006,
multidisciplinary Oversight Committees may be constituted to ensure
that the implementation of this ameliorative legislation does not
adversely affect the local ecosystems.

A: Augmenting ● There is need to enhance the capacity of the security forces to act
Security Forces effectively and firmly, but in conformity with constitutional bounds; it is
necessary that standard operational procedures and protocols are laid
down in specific terms and detail.

L: Learning and ● Training and reorientation including sensitising the police and
Sensitization paramilitary personnel to the root causes of the disturbances that they
Initiatives are seeking to curb, are necessary.

I: Implementation ● Performance of the States in amending their Panchayati Raj Acts and
Monitoring other regulations to bring them in line with the provisions of the
Panchayats (Extension to the Scheduled Areas) Act, 1996 (PESA) and
in implementing these provisions may be monitored and incentivised by
the Union Ministry of Panchayati Raj.

S: Strengthening ● Establishing and strengthening local level police stations, adequately


Local Police staffed by local recruits, in the extremist affected regions should be an
Strategy important component of the policing strategy for tackling left extremism.

M: Maximizing ● For implementing large infrastructure projects, particularly road


Infrastructure networks, that are strongly opposed by the extremists or are used to
Security extort funds from local contractors, the use of specialised Government
agencies like the Border Roads Organisation in place of contractors may
be considered as a temporary measure.

Conclusion:

As per the Expert Group Report by the Former Planning Commission, “The rights and
entitlements of the people underlying these issues find expression in the Constitution, the laws
enacted by the various Governments and the policy declarations. The administration should not
have waited for the Naxalite movement to remind it of its obligations towards the people in these
matters. But at least now that the reminder has been given, it should begin rectifying its own
deficiencies. It should be recognised that such a responsibility would lie upon the Indian State
even if the Naxalites were not there, and even in regions where the Naxalite movement does
not exist.”
Case Study: Naxalbari and Pavagada (To be Explained in Class)

Case Study: The Misadventure of Salwa Judum

Salwa Judum, which translates to "Peace March" or "Purification Hunt," in the Gondi language
was a controversial state-sponsored vigilante movement formed in 2005 in Chhattisgarh, India.

Formation and ● Salwa Judum was initiated in 2005 as a reaction against Naxalites.
Support ● The movement was supported by the state government and was
seen as a continuation of an earlier anti-Maoist campaign called Jan
Jagran Abhiyan (1991), which had collapsed.
● The state facilitated the signing of police and military mining
agreements to support Salwa Judum, with backing from corporations
like Tata and Essar, which were interested in the region's mineral
resources.

● By 2008, Chhattisgarh had branded certain members of Salwa


Operations Judum as Special Police Officers (SPOs) or Koya Commandos,
and Tactics providing them with support to adopt and apply counter-insurgency
tactics.
● Many volunteers of Salwa Judum were former Maoists, utilizing their
knowledge of Maoist tactics against their former comrades.

● Salwa Judum is accused of numerous human rights violations,


Impact and including the burning of over 600 villages as part of their
Allegations counter-insurgency measures.
● The conflict and violence led to significant displacement, with around
300,000 people being forced to migrate.
● The operation resulted in a large number of deaths, with reports
suggesting 98 deaths among SPOs and up to 800 deaths overall
due to the conflict.
● One of the most notorious incidents associated with the Salwa
Judum period was the Darbha Ghat massacre, highlighting the
intense violence and unrest in the region.

Supreme Court’s ban on Salwa Judum (Nandini Sundar and Ors. v. State of
Chhattisgarh Case)

Major Issues

Excessive ● The SPOs were appointed under the Chhattisgarh Police Act, 2007.
delegation The Act said little, leaving far too much in the hands of the
from the executive.
legislature to ● No details or limitations were provided on the number of SPOs who
the executive could be appointed, their qualifications, their training, or their duties.

Appointment ● SPOs were playing a major combat role in counter-insurgency


of the SPOs operations, and that their brief was not limited to non-combative
assignments.
● Youngsters, with poor training, were being recruited by the State to
engage in dangerous and deadly operations. They lacked both the
legal and professional education necessary for their tasks.

Rights of SPOs ● The SPOs were expected to perform all the duties of police officers
but were paid only an honorarium. This, and the arbitrary and
vague nature of their appointment and functioning, was held to
violate the equal protection guarantee in Article 14 of the
Constitution.
● Article 21, the right to life clause, was also said to be violated, as
the State displayed insensitivity towards the lives of SPOs, placing
them in danger without giving them the necessary education and
support they needed.
Theme I: Left Wing Extremism as a Result of Non-Implementation of Fifth Schedule

As per the Second ARC Report, “There is no doubt that the policies initiated under PESA will
contribute in inculcating a sense of participation and purpose within the village community -
something that would surely make them less susceptible to subversive agendas. The problem,
however, is that PESA is an 'indicative legislation'; it lays down certain guidelines whose
implementation depends on the States carrying out specific amendments (or enacting exclusive
legislations) in their Panchayati Raj and other Acts. While many States have taken preliminary
action on the lines suggested in PESA, there is a general impression that its implementation is,
by and large, unsatisfactory.”

Dimensions Provisions

Administration ● The President of India can declare any area as a Scheduled Area after
of Scheduled consulting the Governor of the state.
Areas ● The Governor can make regulations for the peace and good governance
of any Scheduled Area in the state.
● These regulations may prohibit or restrict the transfer of land by or among
members of the Scheduled Tribes, regulate the allotment of land to
members of the Scheduled Tribes, and regulate the business of
money-lending to the Scheduled Tribes.

Tribes ● States with Scheduled Areas must establish a council; Council advises on
Advisory welfare and advancement of Scheduled Tribes.
Council ● It consists of up to 20 members with three-fourths being representatives of
Scheduled Tribes.

Special ● The Governor can direct that any particular act of Parliament or of the
Provisions for Legislature of the state shall not apply to a Scheduled Area or shall apply
the Welfare of with modifications and exceptions.
Scheduled ● The Governor has the power to repeal or amend any existing law in its
Tribes application to a Scheduled Area if it is necessary for the peace and good
governance of the area.

Reports to the ● The Governor of each state having Scheduled Areas must annually or as
President required by the President make a report to the President regarding the
administration of these areas.
● The Union Government must ensure that the provisions of the Fifth
Schedule are effectively implemented.

Linkages with development of LWE due to non-implementation of Fifth SChedule (Xaxa,


Mungekar, Bhuria Commission Reports)

Application of ● Some areas with tribal majority do not have Vth Schedule Status.
Laws in ● All laws are routinely extended and aren't adapted to tribal sensitivity
Scheduled and issues.
Areas ● After the adoption of the Constitution, the general Laws got extended
to the Scheduled Areas in routine and the community system of
governance got excluded from the legal frame. The traditional
system of governance in the Scheduled Areas that used to be the
community's exclusive domain thus lost its legitimacy and was
weakened with the passage of time.
● The Governor's office doesn’t have the capacity to deal with these
matters.

Land
Alienation
Madhya ● MP Land Regulation rules of 1959 are still in place
(not without
Pradesh which authorizes transfer of land to non-tribals.
the consent
of Gram Chattisgarh ● The state government still does not prohibit
Sabha) acquisition of land on minute loan default of tribal.

Rajasthan ● The state government does not recognise


traditional authority.
● District administration can overturn Gram Sabha’s
decision.

Reports to ● Casual Exercise: The Reports from Governors are casual, irregular
the President and unattended. As a result, this mechanism has not been used the
way it was intended. (Mungekar Commission Report)
● Not sending reports on time: According to the Bhuria Commission
Report (2002-2004), at the time of their writing, the States of Andhra
Pradesh and Madhya Pradesh did not send their reports from
1999-2000, while Maharashtra and Orissa had not sent theirs from
2000-2001 onward.
● Non performance of Administrative Duties: A confidential report
sent to the President by the National Commission for Scheduled
Tribes (accessed by Down to Earth magazine in 2013) has also
complained of the failure of Governors in performing their
administrative duties to ensure selfgovernance in tribal areas.

Tribal ● Tokenistic nature of meetings: The members of the TAC have few
Advisory powers even in terms of what can be discussed at the Council
Council meetings.
Eg, the Chhattisgarh TAC rules states that, apart from matters
referred to it by the Governor, “No issue shall be taken up for
discussion and included in the proceedings and no proposals shall
be passed in a meeting unless the issue has been mentioned in the
notice for the meeting.”
● Even when issues are taken up by the TAC, it has been noted that
there is rarely any sustained and consistent engagement with the
matter in the form of follow-ups and field visits. As per the minutes of
their meetings, none of the TACs discussed the issue of land
alienation among tribals between the years 2005 and 2011.

The failure of implementation has cleared a governance vacuum that is usually filled by the
Maoists.

As per Mungekar Committee, “particularisation, not generalisation', and 'discretion, not rule by
rote' comprise the moving spirit of this frame. It is the law that must be adapted to the specific
situation of each group, however small and minuscule, rather than forcing the simple people to
adapt to a frame that they do not know and are not in a position to appreciate.”

As per the Supreme Court in the Samatha Case, “the purpose of the Fifth and Sixth
Schedules to the Constitution is to prevent exploitation of truthful, inarticulate and
innocent Tribals and to empower them socially, educationally, economically and
politically. The Constitution intends that the land always should remain with the Tribals.”

Theme II: Women in Red Corridor

Expression of Gender Motivates in Red Corridor:

● Dominant presence of women in Maoist cadres: Women occupy 60% of total Maoist
cadres and almost all operational and tactical positions responsible for sustaining Maoist
rebellion.

● Moist appeal rooted in commitment towards women's rights: This is reflected in its
all-women squads such as the Krantikari Adivasi Mahila Sangathan (KAMS). These
women-led campaigns against various forms of gender-based violence, including forced
marriage, abduction, outcasting menstruating women, bigamy, domestic violence, and
police brutality. The overarching grievance of women in the movement is that of gender
inequality.

● Increased crimes against women: The National Crime Records Bureau 2019 data
shows that Andhra Pradesh, Chhattisgarh, Jharkhand, Madhya Pradesh, and Odisha
registered 84,938 such crimes. Tribal women, in particular, have been victims of 69.6%
of violence against women over the past decade. Police brutality and impunity often
push women towards Maoism, creating a cycle of violence.

● Increasing layers of inequality: The layers of inequality in the Red Corridor are
numerous, with SC/ST women bearing the brunt of gender, caste, and class subjugation.
○ SC/ST women form 40% of the Maoist forces but account for 90% of its martyrs.
○ SC/ST women disproportionately suffer mass displacement and loss of
livelihood, as 75.8% of India's mineral production currently comes from their
ancestral lands.

● Marginalisation of the rural economy: It leaves women poorer than men of the same
households. Therefore, many women perceive Maoism as a means of relief from poverty
and unemployment.

Issues with Women in Red Corridor:

● Structural Violence: Women subjected to the same structural violence they fight
against.
● Representation: Comprise 35-40% of total members but have negligible representation
in the central committee (1 out of 20 members).
● Menstrual Health: Lack of mainstream access to menstrual leave and hygiene products
such as sanitary napkins, soap, and water.
● Health Issues: High prevalence of anemia and protein deficiency among women.
Forced to be on constant alert, carrying a gun at all times.
● Reproductive Rights: Forced vasectomy and abortions; no opportunity for family life.
● Sexual Exploitation: Sexual exploitation and violence; issues often addressed
inadequately in people's courts.

Way forward

● Gender-sensitive policies: which offers women better alternatives than joining cadres.
● Re-work hard-power security responses: With an adequate focus on ground realities
and focus on the welfare of Adivasis.
● Priority must be to diminish motivations, not demean them: The driving factors
should not only be understood as incentives behind the violence but potential solutions
for peaceful outcomes.
Theme III: Non-Implementation of Forest Policies

Evolution of Forest Policies


Forest Rights Act, 2006

The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act,
2006 recognizes and vests forest rights and occupation rights in Forest Dwelling Scheduled
Tribes (FDST) and Other Traditional Forest Dwellers (OTFD).

Features of Forest Rights Act, 2006

● Identifies four types of rights:


a. Title Rights - for a maximum of 4 hectares only for the land already being
cultivated.
b. Use Rights - to extract Minor Forest Produce (MFP), grazing areas, pastoralist
routes.
c. Relief and Development Rights - in case of forced displacement or illegal
eviction.
d. Forest Management Rights
● Who can claim these rights?
○ Forest Dwelling Scheduled Tribes (FDST) and Other Traditional Forest Dwellers
(OTFD)
○ Any member who has at least 3 generations (or 75 years) prior to 13th December
2005 primarily resided in these lands for bonafide livelihood needs.
● Gram Sabha's Authority: Gram Sabha has the authority to initiate the process for
determining the nature and extent of individual or community forest rights.
● Three-tier structure:
a. Gram Sabha
b. SDM Committee
c. District level Committee
● Free and informed consent of Gram Sabha is required in case of notifying National Parks
(NP) and Wildlife Sanctuaries (WLS).

Issues with implementation

Gaps at the ● Confusion over terms such as "primarily resides in," "bonafide
policy level livelihood."
● Lack of clarity, especially over the position of Primitive Vulnerable
Tribal Groups (PVTGs).
● Conflict: Confusion due to Forest Conservation Rules (FCR)
2022 which don't require the collector to obtain the consent of
Gram Sabha before preliminary approval.
● Divergence of land for infrastructure creation: Status of
Forest Report by Parliamentary Standing Committee on
Science, Environment & Forests – 2400 sq. km diverted under
Forest Conservation Act, 1980
● Pendency: According to a report by the Ministry of Tribal
Gaps in Affairs (MoTA), only 40% claims were recognized.
implementation ● Forest Department's Resistance: To recognize Community
Forest Rights (CFR),
Eg, In Sarguja district 27 CFR titles were claimed and conferred,
but not recognized by the Forest Department (FD).

Grounds of ● Wrong interpretation of OTFD definition and dependence clause.


claim rejection ● Lack of evidence, GPS surveys, absence of proof.
● Claims on grounds where land is disputed,
Eg, Chhattisgarh: "orange areas" are disputed between revenue
and forest departments. (SCSTRTI Report, 2013)
● Need for forest rights sensitization (SC/ST/OBC).

● No eviction until the process of recognition and verification of


Violation of rights is complete.
clauses Eg, In Thane, evictions without due process.
● Serious flaws in the constitution of Forest Rights Committees in
many states.

Adequate implementation of the act requires sensitization on the part of the authorities
concerned. Recently, a joint communication by MoEF and MoTA was sent to all state
governments for the expedited implementation of the act.
set of basic principles
What is it?
concise summary of a country’s strategic
vision and objectives

The new frontiers of war, what you call the


fourth-generation warfare, is the civil
society.: Ajit Doval
Quotes
Three attempts were made to come out with
a national security strategy, but there was
hesitation at the political level.:
Shivshankar Menon

India has initiated the process of


News formulating a National Security Strategy

National
Security Complex Threats

Doctrine Technological
Advancements
Responding
effectively to New
Grey Zone Warfare
Domains of
Warfare
Digital Age

Civil Society

Proxy Wars

Recommended by Kargil Review Committee


Previous
Committees Naresh Chandra Task
Force on Security (2011)

Essential to Draft Before Theaterisation

Need Clarity and Strategic Foresight

Blurring Lines
Integration of
Threat 2.5 Front War
Perception
Galwan Incident and
Intelligence Failures

Absence leads to Half-done Reforms

Enhances Country’s Comprehensive


National Power

Algorithm to aid policymakers

Increasing Proxy Wars and Strategic


Contestation
Strategic Culture and Diplomacy

National Interests and Values

What will Communication of Objectives and


it contain? Deterrence

Periodic Updates

Raksha Mantri’s operational


Directive of 2009. It is now dated
and hence needs to be revised.
What has
not been Political Hesitation: Shivshankar Menon
done so far?
Lack of Cohesive Effort

National Deliberate Non-Disclosure

Security
Doctrine Poor Civil-
Lack of Joint
Leadership
Military
Relationships Limited Input
in Policy-
Making
Challenges
Strategic Restraint

Divergent Military Goals

General Anil Chauhan 's view

Counter-view
Doval Doctrine
We must, however, recognize that naxalism
is not merely a law and order issue.: Dr.
Manmohan Singh (Former Prime Minister)
Quotes
“The Constitution intends that the land
always should remain with the Tribals.”:
Samatha Case Judgement

Left Wing
Extremism

ACLED Records: 20% decrease in organized


political violence involving Naxal-Maoist
insurgents.
Recent Trends (2020):
Reported Events: Total events decreased
from 295 to 235; fatalities decreased by
nearly 30%.
Data
2022: Violent incidents decreased by 77%
compared to the peak in 2010.
Decline in Violent Incidents:
Districts Affected: Reduced from 90 in 2010
to 45.

First Phase (1969-1972) Naxalbari Incident, Rapid Spread

Emergency Period, Merger: Party Unity


Second Phase (1975-2004)
merged with PWG to form CPI-ML
Evolution
Creation of unified command structure,
Third Phase (2004-2012)
COIN

Fourth Phase (2013-present) Decline in Violence


Unresolved Social and Economic
Issues
Social
and
Socio-Economic Exploitation
Econom
ic Issues
Land and Agrarian Issues

Land Disputes and Agrarian


Distress
Liveliho
od
Failure of Land Reforms
Related
Causes
Land Related Factors

Displaceme Forest Rights and Displacement


nt and
Forced Displacement and Forced
Drivers
Evictions Evictions
of
Naxalism
Inadequate Governance and
Governan Corruption
ce Issues
Governance Related Factors

Police and State Repression

Social
Exclusion Cultural and Social Alienation
and
Cultural Social Exclusion
Alienation

Psychological Empowerment

Building Capacity of Security


Forces (including the Police)

Multi Building Capacity of


Pronged Administrative Institutions
Strategy
Left Wing (As per Capacity Building among
Extremism ARC II,
MHA
Government Personnel

Annual Capacity Building in Local Bodies


Report)
Capacity Building in Civil Society
Organisations

Cutting the Source of Finances for


Naxalites

Initiatives from Table

N: Negotiations for Conflict


Resolution

A: Administrative Monitoring
Enhancement

X: eXtension of Legal Frameworks

A: Augmenting Security Forces

Way L: Learning and Sensitization


Forward Initiatives

I: Implementation Monitoring

S: Strengthening Local Police


Strategy

M: Maximizing Infrastructure
Security
No Vth Schedule Status
Application of
Routine law extension, ignores
Laws in
tribal issues
Scheduled Areas
Traditional governance weakened

Governor's office lacks capacity

Madhya Pradesh: Land transfer to non-


tribals allowed
Land Alienation
Chhattisgarh: No prohibition on minor loan
(Gram Sabha
default acquisition
LWE and Consent)
Rajasthan: Traditional authority unrecognized,
Vth Gram Sabha decisions overturned
Schedule
Casual, irregular reports

Delayed reports (1999-2000, 2000-


Reports to the President
2001)

Administrative duties neglected

Tokenistic meetings

Tribal Advisory Council Limited discussion powers

No follow-ups, field visits


Dominant
Women: 60% of total cadres
presence of
women in Maoist
Key operational, tactical positions
cadres:

Krantikari Adivasi Mahila


Maoist appeal Sangathan (KAMS)
rooted in
commitment Gender-based violence campaigns
towards women's
rights: Issues: Forced marriage,
abduction, bigamy,
domestic violence, police
brutality

NCRB 2019: 84,938 cases

Increased crimes 69.6% violence against tribal


Presence
against women: women

Cycle of violence, police


brutality, impunity

Increasing
SC/ST women: 40% Maoist forces,
layers of
90% martyrs
inequality:

Displacement
75.8% mineral production from
, livelihood
ancestral lands
loss

Marginalisation Women poorer than men


of the rural
economy: Maoism seen as relief from
poverty, unemployment
Women
and LWE Structural Violence: Same violence they fight against

35-40% members, negligible


Representation: central committee presence (1 out
Issues of 20)
with
Women Menstrual Health: Lack of access to hygiene products
in Red
Corridor: Health Issues: High anemia, protein deficiency

Forced vasectomy, abortions


Reproductive Rights:
No family life opportunity

Gender-sensitive policies

Re-work hard-power security


Way forward
responses

Diminish motivations, not


demean them
Title Rights

Use Rights
Four types of rights:
Relief and Development Rights

Forest Management Rights

FDST

Who can claim these rights? OTFD

Members residing for 3


generations (75 years) before 13th
December 2005 for bonafide
Provisions livelihood

Initiate process for determining


Gram Sabha's Authority:
forest rights

Gram Sabha

Three-tier structure: SDM Committee

District Level Committee

Free and informed consent of


Gram Sabha for National Parks
Consent Requirement:
(NP) and Wildlife Sanctuaries
(WLS)
Forest
Rights
Confusion over terms: "primarily
Act, 2006 resides in," "bonafide livelihood"

Lack of clarity for Primitive Vulnerable


Tribal Groups (PVTGs)
Gaps at the policy level:
Conflict with Forest Conservation Rules (FCR)
2022: No Gram Sabha consent needed before
preliminary approval

Land divergence for infrastructure: 2400 sq. km


diverted under Forest Conservation Act, 1980

Pendency: Only 40% claims recognized


(Ministry of Tribal Affairs report)
Issues
Forest Example: Sarguja district, 27 CFR
Department' titles claimed, conferred but not
s Resistance: recognized by Forest Department

Grounds of
Wrong interpretation of OTFD
claim
definition and dependence clause
rejection:

Gaps in implementation: Lack of evidence, GPS surveys, absence of proof

Claims Example: Chhattisgarh "orange


on areas" disputed between revenue
disputed and forest departments (SCSTRTI
land Report, 2013)

No eviction
Example:
until
Thane,
recognition and
evictions
verification
without due
Violatio process
process
n of complete
clauses:
Flaws in Forest Rights Committees'
constitution in many states

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