JOURNAL OF DEFENCE STUDIES

Naxalite Movement in India: The State's Response

Raman Dixit, an alumnus of R.I.M.C. Dehradun, is a law scholar at N.L.S.I.U. Bangalore.

Government's Perspective

When the Naxal uprising began in 1967, the Indian government looked at it as a law and order problem. It did not analyze the causes of the movement and the extent of mobilization of people. Hence, it believed that it could and would put an end to it in a short span of time using force. “During the outbreak of the armed clashes in Naxalbari, the then Home Minister Y B Chavan, addressing the Lok Sabha on June 13, 1967, described them as mere “lawlessness”1 – a transgression to be repressed and contained. So, while Charu Mazumdar named the 1970's the “Decade of liberation”, the Indian state chose to make it the “decade of repression”.2 The United Front government in West Bengal, confronted by the Naxal violence, was in a dilemma about the nature and scope of its response. It recognized the crucial need to address the problem of monstrous iniquity. As a government it could not let any violent uprising threaten its legitimacy, even if the cause was morally valid.

The government chose to react based on the latter point and so launched a massive police operation that drove the movement underground and brought most of its leaders under police custody within four months of the uprising. The emergency in 1975 was a period of carte-blanche to the state authorities to crush the movement. It lead to the legitimization of violation of human rights by the state. But ironically, the movement arose again in a more violent form after the emergency3. Police excesses like extra-judicial killings and extortion, misappropriation and harassment of the Naxal support base are public secrets, which governments have turned a blind eye to.

The Governments have enacted several lawsto empower themselves to combat Naxals. The West Bengal Government enacted the West Bengal (Prevention of Violent Activities) Act 1970 to arm itself to repress the uprising. No particular national act has been enacted so far specifically to counter the Naxal movement, but various 'anti-terror' acts have been used to curb Naxal violence and too often , to target sympathizers by stamping them as Naxalites.

This trend was followed in several other states also. For instance, in Andhra Pradesh in 1983, the N.T Rama Rao government even liberalized arms licensing to enable people to 'protect' themselves from Naxals4.

However, in-spite of the government's muscle power and legal teeth, the Naxal movement has continued to spread its base because the rural poor and oppressed identify with its ideology. In other words, its inception, ideology, spread and sustenance are deeply rooted in socio-economic factors.

The Naxalite movement came into being as a result of prevailing social and economic issues. In fact, while conducting an enquiry into the uprising, the West Bengal State Secretariat of the CPI(M) stated, “Behind the peasant unrest in Naxalbari lies a deep social malady- malafide transfers, evictions and other anti-people actions of tea gardeners and jotedars.”5 These issues were longstanding and there was no dearth of reform legislation. But the spirit of the law remained confined to paper and the people were left to languish. Therefore, it recognized that the causes were in essence, socio-economic.

All the regions in which the Naxal movement took hold are ones with alarming levels of poverty. In Telangana, in the districts of Karimnagar, Adilabad and Warangal poverty was 95.8% while in the rest of the state it was between 50 and 60 per cent. After independence, the Indian government pursued agricultural policies focused on massively improving output without doing enough to check economic and social disparity. With the commercialization of agriculture, economic disparities widened. The rich got richer and the poor got poorer. The attempt of the government to abolish zamindari created a class of rich peasants from the backward classes6. With the spread of communist ideology, there was greater mobilization of the sharecroppers (bargadars) and landless laborers, who mostly belonged to the so called lower castes and tribes. This polarized the agrarian classes and created an environment of confrontation.

Mr. Kannabiran, President of the Andhra Pradesh Civil Rights Committee, said that the main objective of land reform was social transformation and it should not be collapsed with the question of immediate productivity impact of land reforms7. The failure of land reform was the macro-issue that affected both social and economic conditions of the people.

After independence the Indian government started the protracted and difficult process of abolishing the Zamindari system, to eliminate the role of intermediaries. By the end of the 1950s, the process8 was completed – on paper. This meant that 20 million erstwhile tenants were now landowners. One rough estimate says that area under tenancy9 declined from 42% to around 20% by early 1960s. However, to a large extent this was caused due to eviction of tenants by landlords and not by actual reform in the system. The next part of land reform was tenancy reform. Its objectives were to guarantee security of tenure to tenants, to ensure fair rent rates and to gain rights of ownership of land he/she cultivated, subject to some restrictions, at well below market rates.10 In West Bengal, two major acts for land reform were passed in the 1950s aimed to eliminate intermediaries (zamindars and jotedars) and bring fixed rent tenants into a direct relationship with the state11. It gave the state powers to inquire into land transfers and cancel the transfer if it was not bona fide. Abolition of intermediaries was generally successful. However, numerous loopholes and poor implementation meant that the landlords were able to retain control over large tracks of land. It did not protect the rights of Bargadars (sharecroppers), who were the most deprived section of society.

From 1947 to 1969, as part of land reform implementation in West Bengal, only 300,000 acres of above-ceiling land was redistributed, a little less than 3% of the cropped land in the state.12 The 1961 census estimated that 82 percent of the tenancies in the country were insecure13. Bargadars received no protection until 1970, when the government, woken from stupor by the Naxalbari uprising, amended the West Bengal Land Reforms Act to cover them also13. The legislations themselves were not strong enough and implementation was extremely ineffective.

The Naxalbari upsurge was sparked by the fact that in-spite of the United Front being in power in the state, land reforms were still ineffectual. Its sustenance was fuelled by class and caste tensions and the sense of desperation due to the prevailing economic and social conditions.

To the local administration and the police nothing seemed to be more natural than to see their role as defenders of the vested interests irrespective of the changes in law. More importantly, there was a conspicuous lack of political will14. Hence a socially biased bureaucracy also impeded progress and made the legal system ineffective as a tool for reform.

Social Iniquity and Exploitation

The oppressed classes were not only exploited as sharecroppers and landless labourers by the landlords - they also fell prey to money lenders. The groups constituting the sharecroppers and the landless laborers wanted a new social order with equity and the landed classes wanted to retain the prestige and 16 status that was associated with the zamindars under the old system.15 Also, in India, since there wasn't any distinction between class and caste relationships at that time, class conflict was manifested as caste conflict. The manifestations of the caste struggle as part of the Naxal movement is region specific16. In Srikakulam, a government sponsored study noted that “Chronic poverty and 18 destitution have become the patterns of tribal life”.17

Alienation of Forest Land

Alienation of Tribal land was a major issue that crippled their economic welfare. This was evident in good measure in the Srikakulam Naxal movement. By the time of the uprising only one third of the tribals owned land.18 Alienation happened largely because of the money-lenders' trap but also because of the government's restrictions of access to forest land, traditionally the exclusive domain of the tribals. In implementing government regulations on forest access, government officials resorted to harassment of the tribals19. Loss of access to forest produce which had constituted a significant part of their income and was also an integral part of their way of life, led to deep discontentment among the tribes.

The people who were most affected by the status quo, therefore, were the fuel for the Naxalist fire.

Rural: Tribals and Agricultural Laborers

The policies of the state disturbed the equilibrium in tribal society. Their social structure was also more conducive to mass mobilization. In West Bengal, the bases of the Naxals at Naxalbari, Phansideoa and Kharibari were mainly inhabited by the Santhal, Oraon and Rajbhanshi tribes.20 They were the hardest hit by the agricultural commercialization and the government's forest policy. They also bore the brunt of social oppression. Their egalitarian social organization was very conducive to mass mobilization21. The landless everywhere share the same woes. The Naxal cadres also hailed from the classes of agricultural workers, sharecroppers and tenants.

Urban: Middle Class Youth

The Naxalist movement found enormous support among the educated youth. These young men and women belonged to the petty bourgeoisie. Many of the young Naxalites who went off to the forests were medical and engineering graduates22. Universities became hotbeds of radical ideology. Some went to rural areas to mobilize the people there and some stayed back in Calcutta, perpetrating acts of violence in an attempt to overthrow the state. Ironically, they were precisely the section of the student community who were the most difficult to bring into any kind of student movement and struggle. They shunned politics, disdained going in for the drudgery of mobilizing and organizing fellow students. With the onset of the recession, which signalled the coming of the general crisis of the capitalist path of development, that India had been placed upon for the past two decades, the problem of employment and of careers loomed large for these sections of the student community for the first time23. Their sense of disillusionment and the fiery idealism of youth directed them to Naxalist ideology. The repression of Naxalism during the emergency also attracted a large number of youth to Naxalism as a rebellious reaction to the government's oppression24. Naxalism appealed to each of these groups for different reasons.

Tackling Naxalism

The government has constituted an 'Empowered Group of Ministers' to counter the problem of Naxalism headed by the Home minister and select chief ministers25. The government under the Unlawful Activities Prevention Act (UAPA), 1967 amended in 2004 has banned the Communist Party of India (Marxist-Leninist) - People's War and all its associated formations, and the Maoist Communist Centre (MCC) and its front organizations.26 The government has also constituted a Task force which will comprise of Nodal officers from the Naxal affected areas and officers from the IB, SSB and the CRPF.27 There is also a Coordination Centre that was set up in 1998 headed by the Union home minister with Chief Secretaries and DGPs of the Naxal affected areas for the coordination of steps taken to control Naxal activities28. The government has laid down a clear plan to tackle the left wing extremism. It has formulated a two pronged strategy to solve the problem of Naxalism.

Law and Order approach

Modernizing the Police Force
The government has launched a Police Modernization Scheme in areas affected by Naxal movements. Under this scheme huge sums of money have been provided to the state governments by the central government to modernize their equipment and tactical gear including latest communication, vehicles and infrastructure facility. States have also been told to determine police stations 30 and outposts that are susceptible to Naxal attacks and have to be fortified.29

Due to increased use of IED by the Naxalites and the increased number of casualties the government has decided to provide the forces with Mine Protected Vehicles (MPV).

Central Para Military Forces have been deployed on a long term basis by the government to help the state governments to fight against the Naxals. The states have also been relieved from paying the charges involved in deploying these forces for about 3 years which nearly is about Rs.1100 crores. The government, also to discourage the youth from the path to militancy, has revised the recruiting guidelines to permit 40% recruitment in Central Para Military Forces from areas affected by Naxalism30. The government has also raised a special force of 14,000 personnel consisting of Central Paramilitary Forces, state police and ex- servicemen from areas affected by Naxalism31. At present 36 battalions of Central Para Military 33 Forces are deployed in Naxalite affected areas.32

The government, to strengthen the security network in the states, has set-up the Indian Reserve (IR) battalions. These forces along with providing additional security provide youth with employment opportunities. The Centre has also raised the amount provided to each battalion to Rs.20 crores from the previous Rs.13 crores.33 In April 2006, the government authorized the formation of nine more Indian reserve battalions of 1000 35 personnel each.34

In order to ensure that the activities by the Nepalese Maoists don't affect India, SSB has been deployed along the Indo-Nepal border. They have been given a massive fund of Rs.444 crores for their modernization.35

The revision of the Security Related Expenditure (SRE) Scheme in 2005 which included many security related items which were not included in the Police Modernization Scheme like insurance scheme for police personnel, community policing, expenditure incurred on publicity to counter propaganda of Naxalites, rehabilitation of the Naxals who surrender and the level of imbursement which 37 was raised from 50% to 100%.36 Presently 76 districts in 9 states which are badly affected by Naxal activities are covered in this scheme.37

Plans have been set in motion for the formation of three to four specialized Anti-Maoist Centres at critically important locations at inter-state boundaries which will be equipped with five helicopters each and would be manned by the CRPF and the pilots would be called from the Army/BSF/Air Force. The use of UAV's for reconnaissance missions and collection of intelligence from Naxal affected areas has been authorized by the Centre. Ex-servicemen have also been called for the formation of an auxiliary force which will primarily be supervising the work of detecting mines and explosives laid by Naxalites. Around 4,800 ex-servicemen have already joined the fight and an expected 5,000 are expected to join. The government of Chhattisgarh started the Counter Terrorism and Jungle Warfare College in Kanker imparts training to counter the well trained and motivated guerrilla force of the Naxals, where police personnel are given rigorous training in guerrilla warfare and are made to live in the open and taught how to live off the land. Even the Army who as such are not very interested in getting themselves dragged into tackling Naxalism have been training 16 companies of paramilitary and state personnel in counter Naxalism operations.38

States have also established their own special security force like Andhra Pradesh has formed the Greyhounds which are said to be one of the most effective police force to combat the Naxal problem and the government of Uttar Pradesh has also raised a battalion of the Provisional Armed Constabulary 40 consisting of the local youth.39 Even the Central government has formed the COBRA which is a special force formed to deal with Naxalism in any state.

Social Integration approach:

Social Economic Development
The government started the Backward Districts initiative in 2003-2004 and the Backward Regions Grant Fund (BRGF) under which 55 of the worst affected areas in 9 states were to be provided with funds to the tune of Rs. 2475 crores to tackle the problem of Naxalism. Around 250 districts have been included the BRGF scheme to accelerate socio-economic development in these districts which is to be administered by the Ministry of Panchayati Raj.40 Various state governments have allocated funds to the areas affected by Naxalism. The government of Bengal allocated Rs.50 crores for the underdeveloped rural areas of the state. A separate fund of Rs.5 crores was set aside for Paschimanchal comprising of 74 blocks of Bankpura, Purulia, West Midnapore, Burdwan and Birbhum districts. They also created a separate department for Paschimanchal development to expedite the implementation of poverty42 alleviation programs.41

The government of Karnataka also allocated special funds for development in villages affected by Naxal activities. Grama panchayats were provided with Rs.10 lakhs a year for two years to develop the villages within their jurisdiction. Other grants from the government, zilla and taluk panchayats were also included to be used in the development of these villages.42

The government also requested the planning commission to include other Naxal affected areas under the Scheme of Backward Regions Grant Funds for which Rs.5000 crores have been set apart.43

The government of Chhattisgarh has also announced houses worth Rs.1 lakh and employment to the kin of who got killed in the Maoist violence and the Jharkhand government increased the insurance amount to be given to the kin of jawans to 21.5 lakhs 45 from the 10 lakhs.44

Various schemes launched have been launched by the government like the Pradhan Mantri Gram Sadak Yojana (PMGSY) which offers tremendous opportunities for rural road connectivity. For certain districts affected by Naxalism which have a population of 500 and above in plain areas and 250 and above in tribal areas 3 years perspective plans are being formulated to cover all habitations. The National Rural Employment Guarantee Programme (NREGP) is being implemented in 330 districts affected by Naxalism so as to universalize the demand-driven programme for wage-employment. Other schemes which are in addition to the above mentioned schemes are Bharat Nirman, National Rural Health mission (NRHM), Sarva Shiksha Abhiyan (SSA), Integrated Child Development Services (ICDS) and other income generating and social security schemes of the Ministry of Rural Development, Agriculture, Panchayati Raj and Tribal affairs. The central government will also provide 100 percent assistance in the formation of Ashram schools and hostels for girls and boys in 46 tribal areas.45

States like Jharkhand and Orissa have offered huge incentives to the Naxals who surrender themselves. Further, the government has offered cash equivalent to the price of the weapon surrendered. They will provide them with life insurance cover, vocational training, agricultural land, health and 47 educational facilities for their children.46

The Laws Made by the Government

Rehabilitation and Resettlement Policy, 2007
The main aim of this act is to minimize the displacement of people and to promote non-displacing or least displacing alternatives.47 The Government issued a rehabilitation policy on 11 0ctober 2007 for the easy displacement of people who lose their land for industrial growth. Under this policy land in change for land will be given, job prospective to at least one member of the family, vocational training and housing benefits including houses to people in rural areas and urban areas will be some of the benefits.48

Forest Rights Act, 2006
The Scheduled Tribe and Other Traditional Forest dwellers (Recognition of forest Rights) Act 2006 or the Forest Rights Act recognizes the rights of the scheduled tribes and forest dwellers who have been living in the forests for years but their rights have still not been recognized.49 The Ministry of Environment and Forests has also allowed use of 1 hectare of land for nonforest purposes and conversion of kutcha roads into pukka roads.50

Chhattisgarh Special Public Securities Act, 2006
This bill provides definition of unlawful activities, declaring an organisation unlawful, formation of an advisory board wherever the state government feels the need for its establishment, procedure of the formation of the advisory board, action of the advisory board, penalties viz punishments even for not committing a crime, the power to notify a place being used for unlawful activities and taking occupation of such place thereof and revision/bar against intervention by the courts.51

Are these laws effective?

These laws have in many ways caused a lot of problems to the tribals and the scheduled castes by negating the spirit of the various safeguards available to the scheduled tribes under the constitution and other laws in the country.52 The act providing 'land for land' has become a nightmare for the government and has become a stumbling block for ensuring industralisation. As per the Unlawful activities prevention act (UAPA) the government has banned all organisations that have any connections with any Naxal movements like the MCC or the CPI-M (Marxist-Leninist). There was no need of this bill to tackle Naxalism. This bill was formulated, only to silence the appropriate discord and dissent brewing in the minds of people in the areas affected by Naxalism due to persistent ignorance by the government to their situation. This Bill has also failed to make a distinction between the anti-social, anti-national elements from the people who are 54 peace loving.53

CSPS Bill, 2005 also provides the District Magistrate unconditional powers to notify places which he thinks are being used for unlawful activities without any prior notification. There is no requirement of production of anything as evidence to prove that the said place is being used for unlawful activities. It is just a violation of principles of natural justice as the aggrieved parties don't even get a fair hearing.54 This bill also provides that any revision application has to be filed with the High court only, challenging the validity of the order of the government. This petition has to be filed within 30 days and that no court has the jurisdiction against any decision of the court. Any kind of application or form of revision or injunction by a court or officer except for the High court and the Supreme Court regarding any action to be taken as a follow up to the order of the government has been barred in this Bill.55 So it can be said that this bill was totally uncalled for and has only be brought to act as a blandishment to the people.

Which Approach is Better?

The approach which I find as the solution which will solve the problem of Naxalism is the Social Integration. The tribals and scheduled castes that live in the Naxal affected areas have been neglected for the past many decades and now want some attention from the government. Providing them with incentives like giving them right over the forest produce from the forests in which they have been living for generations, providing them with houses etc. is the right modus of solving their basic problems. The main reason for the spread of Naxalism is the exploitation of poor and scheduled castes. The main thing which has to be done is to enforce land ceiling laws, utilization of the funds provided to government to the maximum and political expediency. Use of police forces should be to enforce the land ceiling laws, evict landlords and ensure land to the farmers for cultivation. They should be provided with police protection, and proper rehabilitation for the people who have been displaced should be ensured. Security as well as development has to run hand in hand to counter the Naxal problem.56

The government has to instil faith in the people that they will be governed in a better manner than by the Naxals. The government should include laws in the forest act that only forest dwelling tribes and scheduled castes should be allowed to use the produce of the forest. Proper guarding of financial institutions sanctioning loans to these tribes should be ensured which will help these tribes to realize that the government is with them.57

The Central government should form a separate ministry which will undertake the development of the areas affected by the Naxal activities. The following steps ought to be taken by the government:

Ensure the safety of the civilians by stopping the Salwa Judum campaign and ensuring that no counter insurgency measures are taken by risking the lives of the civilians.
Checking instances of human rights violation by the security forces and the Salwa Judum.
Registering the crimes perpetrated by the security forces, Salwa Judum and the Maoists and bringing them to justice.
Banning of Bal Mandal (The child division of Naxalites) with immediate effect.
Ensuring safety of those who surrendered and those who lived in camps or were related with Salwa Judum activities.58

Using force against the tribals to deter them from joining the Naxals has and will backfire against the government. The government should ensure peace in these areas so that these people don't suffer more than they already have and this can be done only if the government takes proactive measures so as to ensure social justice and inclusive growth for the benefit of the marginalized sections.

Conclusion

The state has to do much more than plan counter-insurgency operations or support violent vigilante groups to suppress the Naxalite movement. After close examination of the historical and ideological origins of the movement, it is clear that the movement thrives on the dissatisfaction of the marginalized and alienates the population. The socio-economic perspective of Naxalism talks about how the rebel movement is shaped due to the failure of the institutional mechanisms and frameworks to deliver socio-economic justice. This article outlines the steps taken by the government, but concedes that it is not enough to over-emphasize the 'law and order' approach

Close examination of the movement will enable to understand that the marginalized take up arms only to break down the insensitive establishment, which has failed to deliver an egalitarian society. The Naxalite leaders may talk about 'deliverance of the proletariat from the neo-liberalist bourgeoisie, and the dawn of New Democracy', but such phrases mean little to the tribals and landless labourers who find themselves at the receiving end of statesponsored and non state-sponsored exploitation. They are in the battle only because of their disillusionment with the status quo.

It is clear that there is a wide chasm between promises and their eventual deliverance. Until the government implements employment, poverty alleviation and land reform programmes, counterinsurgency measures cannot achieve much. Social justice and inclusive growth are the planks on which the government must build its programme. Only with consolidated efforts on the part of the legal and political framework socio-economic reforms can be implemented, and the problem of Naxalism tackled.

1. S. Banerjee , “ Naxalbari: Between Past and Future” , 37(22), Economic and Political Weekly, June 2002, 2115 at 2115, Source : http://www.jstor.org/stable/4412182 (Last accessed on 10/01/2010).
2. R. Ravikanti,””People's war” and state response: The Naxalite Movement in Telangana”, University of British Columbia, September 1995, at 33 Source: https://dspace.library.ubc.ca/handle/2429/3955(Last accessed on
10/01/2010).
3. Ibid. at 63.S
4. Supra note 20 at 89.
5. Supra note 19 at 33.
6. G. R. Sahay, “Naxalism, caste-based militias and human security: lessons from Bihar”, Centre for Development
Studies, July 2008, at 4 Source:http://www.arts.monash.edu/mai/asaa/gaurangsahay.pdf (Last accessed on 10/01/2010).
7. T. Haque and G. Parthasarathy , “ Land Reform and Rural Development: Highlights of a National Seminar”,27(8), Economic and Political zWeekly, February 1992, at 395, Source:http://www.jstor.org/stable/4397623( Last Accessed on : 10/01/2010 ).
8. B. Chandra et al, India Since Independence (New Delhi, Penguin Books, 2000)at 408.
9. Ibid. at 409.
10. Supranote 26 at 528.
11. West Bengal Estate Acquisition Act,1953. See in West Bengal Laws Vol.6. at 7.
12. T. Hanstad and J. Brown, “Land Reform Law and Implementation in West Bengal:Lessons and Recommendations”, December 2001 , Ruralz Development Institute , Source :
http://www.rdiland.org/PDF/PDF_Reports/RDI_112.pdf (Last accessed on 10/01/2010).
13. Ibid
14. P.K.Datta, “Land reforms administration in West Bengal”(New Delhi, Daya Publishing Company, 1980),at 5.
15. Supranote 24, at 4.
16. Supra note 20 at 43.
17. Supra note 20 at 33.
18. Supra note 20 at 41.
19. Supra note 20 at 41.
20. Supra note 20 at 28.
21. Supra note 20 at 28.
22. M.Sen, “The Naxalites and Naxalism”, 6(3/5), Economic and Political Weekly, January 1971, 195 at 197, Source:
http://www.jstor.org/stable/4381533(Last accessed on 10/01/2010).
23. Ibid
24. Supra note 20 , at 63.
25. V. Anand, “Dealing with Naxalism”, 27(11&12),World Focus, (2006) at 30.
26. “Adivasis of Chhattisgarh- Victims of the Naxalite movement and Salwa Judum”, Asian Centre for Human Rights, at 49.
27. P. Singh, “Naxal Threat and State Response”. Source:
http://hrm.iimb.ernet.in/cpp/pdf NAXAL_THREAT_AND_STATE_RESPONSE(IIM).pdf (Last accessed on 12th January, 2010) at 4.
28. Ibid
29. “Status Paper on the Naxal Problem as on March 13 2006”, Ministry of Home affairs. Source:
http://www.satp.org/satporgtp/countries/india/document/papers/06Mar13_Na... (Last accessed on 13th January, 2010).
30. Ibid
31. “Naxal Conflict in 2006”, Asian Centre for Human Rights, at 23.
32. “Status Paper on Internal Security Situation as on Sep 1 2008”, Ministry of Home Affairs. Source:
http://www.mha.nic.in/pdfs/STTSPPR (Last accessed on 1st August, 2009) at 38.
33. Supra note 64.
34. Supra note 60 at 31.
35. Supra note 64.
36. Supra note 64.
37. Supra note 62 at 3.
38. Supra note 69.
39. Supra note 66 at 24.
40. Supra note 60 also see Supra note 62.
41. Supra note 66.
42. Supra note 66.
43. Supra note 60.
44. Supra note 66 at 24.
45. Supra note 67 at 39.
46. Supra note 66 at 24 to 25.
47. S. Dharmadhikary, “Resettlement policy: promising start, and a let down”, Source:
http://www.indiatogether.org/2007/nov/hrt-randrpol.htm (Last accessed on 13th January, 2010).
48. Supra note 62.
49. Supra note 62.
50. Supra note 64.
51. Supra note 61 at 49 to 62.
52. “Indigenous Issues”, Asian Indigenous and Tribal People Network (AITPN), Source: http://www.aitpn.org/Issues/II-09-06-Forest.pdf (Last accessed on 13th January, 2010) at 3; see also N. Nayak, “Naxalism in Chhattisgarh: Down, not wiped out”, Source:
http://www.idsa.in/publications/stratcomments/NiharNayak300107.htm (Last accessed on 13th January,
2010).
53. Supra note 61.
54. Supra note 61 at 61 to 62.
55. Supra note 61 at 62 to 63.
56. Supra note 60 at 32; see also Lt. Gen Eric A. Vas [Retd], “Naxalism: National Security Implications”, Source: http://inpad.org/res104.html (Last accessed 13th January, 2010).
57. Ibid
58. Supra note 66 at 27 to 28.

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