By Asit Das
The Armed Forces (Special Powers) Act of 1958 (AFSPA) is one of the most draconian legislations used by the Indian rulers to enslave and oppress people under the garb of fighting separatism. For the past sixty years, the North East states, and for almost two decades, Kashmir, have been virtually under army rule. This rule by the army has had a drastic effect on the daily life of the average citizen residing in the North East and Kashmir.
In addition to a de-facto state of abrogation of fundamental rights in the above mentioned areas, the misery of citizens of these regions is further compounded by the large scale encroachment by the army on their lands and resources. AFSPA violates the fundamental constitutional rights of right to life, liberty, freedom of speech and expression, peaceful assembly, free movement, practice of any profession, and protection against arbitrary arrest and freedom of religion, as enshrined in Articles 21, 14, 19, 22 and 25 of the Constitution.
AFSPA has been used in these regions to inflict thousands of deaths, custodial deaths and rape, torture, encirclement of the civilian population, sadistic combing operations, looting of private citizen’s property etc. Thousands of youth have simply disappeared.
Draconian laws are antithetical to modern democracy since they overturn the fundamental tenets of modern jurisprudence on which democracy rests – a person is presumed to be innocent till proven guilty. Draconian laws thereby makes it difficult for persons booked under it to redress their grievances and get relief, such as bail. It grants extraordinary power to the investigating agencies to elicit confessions. Thus the Act empowers the investigating agencies to easily frame a person whom they suspect to be guilty.
The provisions of the Act provide special powers to state Governors, whereby they can, on their own discretion, and without informing the elected political representatives, by notification in the official Gazette, declare the whole or part of the state or union territory to be a disturbed area. Bypassing duly elected and representative political authority is tantamount to de facto imposition of emergency.
More disturbingly, even while it provides the armed forces with such absolute powers, it also provides them with immunity from any legal accountability. Even though the Act is in operation in the states and union territories of the country, the elected bodies cannot initiate legal proceedings let alone administrative action against armed forces without prior sanction of the Central Government (License to Kill, INSAF, 2005).
Provisions of the Act: A Critical Reading
Section 1 defines the title of the Act.
Section 2 (a) limits the jurisdiction of the Act to the seven states of the North East; it has also been extended to Kashmir.
(b) Defines “disturbed area” as area notified under Section 3 to be a disturbed area.
Section 3 states that if the Governor of a state or Central Government is of the opinion that an area is in such a disturbed or dangerous state that the use of armed forces in aid of civil authority is necessary, then either of them can declare it to be a disturbed area by notification in the Gazette.
Section 4 gives the following special powers to any commissioned officer, warrant officer or non commissioned officer of the armed forces in a disturbed area:
(a) If in his opinion, it is necessary for maintenance for public order to fire even to the extent of causing death or otherwise use force against a person who is acting in contravention of an order prohibiting the assembly of five or more persons or the carrying of weapons or of things capable of being used as weapon.
(b) If in his opinion, it is necessary to destroy any arms dump or fortified position, any shelter from which armed attacks are made or are likely to be made, and any structure used as training camp for armed volunteers or as a hideout for armed volunteers or as a hideout for armed gangs or absconders.
(c) Arrest without warrant any person who has committed a cognizable offence and to use whatever force is necessary to affect the arrest.
(d) To enter and search without warrant any premises to make an arrest or to recover any person wrongfully confined or to recover any arms, ammunition, explosive substance or suspected stolen property.
Section 5 makes it mandatory for the Army to hand a person arrested under the Act to the nearest police station with the least possible delay.
Section 6 lays down that prosecution, suit or other legal proceedings can be instituted against a person acting under the Act only after getting previous sanctions of the central government.
A cursory reading of AFSPA reveals that the Act is an act of legitimizing the involvement of the military in the domestic space, not supplementing but replacing ‘civil power’. The military character of the Act is reflected in multiple ways. AFSPA allows ‘use of armed forces’, defined as ‘military forces and the air forces operating as land forces’ and ‘any other armed forces’ of ‘the union’ (section 3) in the domestic space.
Section 2 (c) of the Act also clearly shows the close affinity between AFSPA and those laws governing the military such as the Army Act (1950). It reads, ‘All other words and expressions used herein but not defined in the Air Force Act 1950, or the Army Act 1950, shall have the meaning respectively assigned to them in those Acts’.
In six sections, being one of the shortest Acts to be passed in the history of the Indian legislation, it unmasks the military paradigm involved. For example, what constitutes the ‘disturbed and dangerous condition’ for an area to be declared a ‘disturbed area’ is not defined at all (Section 3). All that is required is it to be declared a ‘disturbed area’. It is as good as declaring war. In fact, the principle of war is unmistakable here. Just like declaring war, once an area is declared as ‘disturbed area’, the personnel of the ‘armed forces’ simultaneously acquire powers to use ‘force as may be necessary’ based on their ‘opinion’ and ‘suspicion’ to effect ‘arrest without warrant’ or fire upon or otherwise use force, even causing death. (Section 4).
The presumption of hostile intent as the legitimate basis for the ‘armed forces’ to take action, characteristic of a war zone, is highlighted when these powers can also be exercised for acts that are ‘likely to be made’ or ‘about to be committed’. Besides the nature of the power conferred upon the armed forces, the fact that the commanding officer is given the power to judge and execute action on his own only proves that the Act is based on the business of war. In a war situation, any officer – irrespective of whether he is a commissioned, junior commissioned or non-commissioned officer-leading his men in the field has to be the judge as well as part of the body that executes his judgments. In the context of maintaining law and order within the domestic space, the same person or body cannot execute the job of the police, the attorney, and the judge.
Moreover, ‘the soldiers’ operational space, that is ‘alien and hostile’, is a relatively undifferentiated space and it does not require elaborate conditions and procedures as in the case of the differentiated domestic space. Hence, unlike other Acts (including the erstwhile POTA) which provide explicit conditions and elaborate procedures running into pages, AFSPA is hardly a one page Act with six sections. All that the Act requires is to restate the assumption of the taken-for-granted hostile intent (based on ‘opinion’ and ‘suspicion’) of the inhabitants of the alien space to exercise the power to eliminate, destroy or neutralize the latter (Section 4).
AFSPA does not have any provision for interrogation and/or gathering evidence. Nor is it like any other so called ‘special laws’, meant to ‘facilitate’ trial or ‘enhance’ conviction rate. It is plainly an instrument of war empowering the military and forces operating under it to eliminate, neutralize and destroy the enemy or ‘suspected enemies’, which more often than not practically includes every body residing in the ‘disturbed area’.
AFSPA: Constitutional Contradictions
The large scale violations of fundamental rights in the north eastern states is a direct consequence of the provisions of the AFSPA, of areas declared as Disturbed Areas under Section No. 3 and the simultaneous acquiring of wide powers by army personnel under Section 4 of the Act.
The AFSPA, which grants armed forces personnel the power to shoot to arrest, search, seize and even shoot to kill, violates the Right to Life enshrined in Article 21 of the Constitution of India which guarantees the right to life to all people.
The AFSPA also violates the International Covenant on Civil and Political Rights (ICCPR). India signed the ICCPR in 1978, taking on the responsibility of securing the rights guaranteed by the Covenant to all its citizens. In particular, the Act is in contravention of Article 6 of the ICCPR guaranteeing the right to life.
Crucially, the AFSPA effectively undermines civil authority. For instance: After the Oinam incident (1987) the Chief Minister, wrote to the Union Home Minister, “The civil law has, unfortunately, ceased to operate in Senapati District Manipur due to excesses committed by the Assam Rifles with complete disregard shown to the civil administration. The Deputy Commissioner and the Superintendent of Police were wrongfully confined, humiliated and prevented from discharging their official duties by the Security Forces”. And consequent to the Kohima incident in 1995, even the Superintendent of Police, Kohima, was stopped at gun point by army personnel.
At the same time, the AFSPA is an emergency legislation that constitutionally requires to be reviewed every 6 months. Yet it has been imposed in Manipur and other states of the north east for years on end, which contributes to the misuse of unbridled and arbitrary powers by the armed forces.
Historical Background of AFSPA
The AFSPA gives the armed forces wide powers to shoot, arrest and search in the name of aiding civil power. It was first applied to the north eastern states of Assam and Manipur; the act was amended in 1972 to extend to all the seven states in the north eastern region of India. They are Assam. Manipur, Tripura, Meghalaya, Arunachal Pradesh, Mizoram and Nagaland, also known as the seven sisters. The enforcement of the AFSPA has resulted in innumerable incidents of arbitrary detention, torture, rape and looting by security personnel. This legislation is justified by the Government of India on the plea that it is required to stop the North East states from seceding from the Indian Union.
A large part of the original region that constitutes the seven states of the republic of India had strong political, economic and socio-cultural links with South East Asia. The great Hindu and Muslim empires that reigned over the Indian subcontinent never extended east of the Brahmaputra River. Indian British colonizers were the first to break this barrier. In the early nineteenth century they moved in to check Burmese expansion into today’s Manipur and Assam. The British, with the help of the then Manipur king, Gambhir Singh, crushed the Burmese imperialist dream and the treaty of Yandabo was signed in 1828. Under this treaty Assam became a part of British India and the British continued to influence the political affairs of the region.
This undue interference eventually led to the bloody Anglo-Manipuri Conflict of 1891. The British reaffirmed their position but were cognizant of the ferocious spirit of independence of these people and did not administer directly but only through the King.
It was during the Second World War, when the Japanese tried to enter the Indian sub continent through this narrow corridor, that the strategic significance of the region was revealed to the Indian armed forces. With the bombing of Hiroshima and Nagasaki, the defeated Japanese had to retreat from the Imphal and Kohima fronts. However, the importance of control over the region subsequently remained a priority for the Government of India.
With the end of the war, the global political map was changed overnight. As the British were preparing to leave Asia, the political department of the British Government planned to carve out a buffer state consisting of the Naga Hills, Mikir Hills, Sadiya Area, Balipara Tract, Manipur, Lushai Hills, Khusi Hills, and hills in Assam, as well as the Chin Hills and the hills of Northern Burma. The impending departure of the British created confusion and turmoil over how to fill the political vacuum they would leave behind. Ultimately, the various territories were parceled out to Nehru’s India and Jinnah’s Pakistan, according to strategic requirements. As expected, there were some rumblings between the New Asiatic Powers on who should get how much. Compromises were made, and issues were finally settled in distant capitals, to the satisfaction of the new rulers. The people who have been dwelling in these hills and valleys for thousands of years were systematically excluded from the consultation process. The Indian share of the disputed British colonial cake in this region constitutes the present seven sister states of the North east. Over the years local democratic movements evolved as the people aspired to a new social and political order. One important example is a strong popular democratic movement against feudalism and colonialism in Manipur, led by Hijam Irabot Singh.
The Annexation of Manipur
After the departure of British, the kingdom of Manipur was reconstituted as a constitutional monarchy by passing the Manipur Constitution Act 1947. Elections were held under the new constitution. A legislative assembly was formed. In 1949 V.P Menon, a seminar representative of Government of India, invited the king to a meeting on the pretext of discussing the deteriorating law and order situation in the state in Shillong. Upon his arrival, the king was forced to sign under duress. The agreement was never ratified in the Manipur legislative Assembly. Rather, the Assembly was dissolved and Manipur was kept under the charge of a Chief Commissioner. There were strong protests but using violent and brutal repression the Government of India suppressed the democratic movement in Manipur and has continued applying the same methods ever since.
The Deception in Nagaland
At the beginning of the century, the inhabitants of the Naga Hills, which extend across Indo-Burmese border, came together under the banner of Naga National Council (NNC) aspiring for a common homeland and self governance. As early as 1929, the NNC petitioned the Simon Commission, which was examining the feasibility of future of self governance of India.
The Naga leaders forcefully articulated the demand of self governance once the British pulled out of India. Gandhi publicly announced that Nagas had every right to be independent. Under the Hydari Agreement signed between NNC and British administration, Nagaland was granted protected status for ten years, after which the Nagas would decide whether they should stay in the Indian union or not. However, shortly after the British withdrew the new Indian rulers colonized Nagaland and claimed it to be Indian Territory.
Articulating the democratic aspirations of the people of Nagaland, The Naga National Council proclaimed Nagaland’s independence in retaliation, and the Indian authorities arrested the Naga leaders. The AFSPA is one of the instruments where the Indian state used to violently suppress the democratic aspirations of the people of North East. In 1975, some Naga leaders held talks with the Government of India which resulted in the Shillong Agreement. Democratic forces of Nagaland smelt a rat in this deceptive agreement and rallied the people for national liberation of Nagas. One of the organizations which articulated the democratic demand of Naga people is National Socialist Council of Nagaland (NSCN).
In the Lushai Hills of Assam in the early sixties a famine broke out. A relief team requested for help from the Government of India. But there was little help. The relief team organised themselves into the Mizo National front (MNF) to liberate themselves from the neo-colonial occupation of India. Against the democratic aspirations of the people Indian army moved in. This is the only place in India where the Indian security forces actually aerially bombed its own civilian population. The armed forces compelled people to leave their homes and dumped them on the road side to set up new villages.
This devastated the structure of Mizo society. In 1986, the Mio Accord was signed between MNF and Government of India. This accord was as deceptive as the Shillong Accord made with the Nagas earlier.
The North East: A Neo-colonial Hinterland
Much of this bloodshed and genocides by the Indian state could have been avoided if the Indian ruling classes had listened to the voices of democratic aspirations of the people of Nagaland and the rights of colonized nationalities.
Culturally the high-caste dominated feudal Indian society is totally incompatible with the ethics of North East cultures which were by and large democratic and egalitarian. To make matters worse the Indian ruling classes forcibly clubbed these different non-feudal ethnic groups with Adivasis, cheating them in the name of scheduled tribes and in the process forcing them to be marginalized and stigmatized by the upper caste ruling elites of India.
The languages of the Northeast are of the Tibeto-Chinese family rather than the Indo-Aryan or Dravidian like the rest of India. Until the later eight schedule of the Indian constitution, none of Tibeto-Chinese Languages were recognized as Indian Languages.
Politically dependant, the North East is being economically undermined; the traditional trade routes with south east Asia and Bangladesh have been closed. It was kept out of the Government of India’s massive infrastructural development in the five year plans. Gradually it became the neocolonial hinterland for exploitation by the Indian state, where local industries were made worthless and now the people are entirely dependant on goods and businesses owned predominantly by those from the Indo-Gangetic plains. The new Indian unscrupulous businesses pull the economic strings of this region.
For instance, Assam produces one fourth of all petroleum for India, yet it is processed outside Assam and the state is deprived of a major source of revenues.
The shifting demographic balance due to large scale immigration from within and outside the country is another source of frustration. The indigenous people fear that they will be outnumbered by outsiders in their own land. Laborers from Bihar and Bengal who live under rigidly feudal, casteist socio-economic conditions in their own states are ready for all kinds of menial jobs at much lower wages. As they pour in more and more local laborers are being edged out of their jobs. Illegal immigration from Bangladesh and Nepal is also perceived as a threat. In Tripura the indigenous population has been reduced to a mere 25% of the total population of the state because of large scale immigration from the North east and Bangladesh.
The Indian state’s primary interest in the North East was strategic, and so was its response to problems. A series of repressive laws were passed by the Government of India in order to deal with this rising National liberation aspirations of the people of North east. In 1953 the Assam maintenance of Public order (Autonomous District) Regulation Act was passed. It was applicable to the then Naga Hills and Tuensang districts. It empowered the Governor to impose collective fines, prohibit public meetings, and detain anybody without a warrant.
On 22 May 1958 a mere 12 Days after the Budget session of Parliament was over, the Armed Forces (Assam-Manipur) Special Powers Ordinance was passed. A bill was introduced in the Monsoon session of Parliament that year. Amongst those who cautioned against such blanket powers to the Army included then the Deputy Chairman of the Rajya Sabha Mr. P. N Sapru. In a brief discussion that lasted for three hours, in the Rajya Sabha, parliament approved the Armed Forces (Assam-Manipur) Special Powers Act with retrospective from 22 May 1958.
Enactment of AFSPA: from colonialism to neocolonialism
North east India is one of South Asia’s most contested spaces. The resulting struggle has taken many forms: armed opposition to the Indian state, movement for separate federal states and autonomous units based on ethnic lines, protest against extractive industries, and demand for more funds from central government. The AFSPA stands almost in centrality of creating spaces for such contestation, with the content of the Act having changed little over the last 50 years and impacting the North east, India and South Asia in profound ways. The Act itself stems from the specific context of North east’s integration into post-colonial India which emerged out of a dominant mainstream Hindu (even enshrined ‘secular’) Nationalist imagination. Long drawn self determination struggles, first inaugurated by the Naga rebellion who asserted their own independent history, became the defining characteristic of the region which is materially, and ideologically a space distinct from the larger vision of a developing India. While India contains diverse regions and holistic national polity or even a national society, however unassimilated, there is a strong belief in both the Indian mainland and in most of the Northeast that an unbridgeable gap exists between the two regions. This, then, makes one understand how a law like the AFSPA, with its extraordinary provisions by any measure, persists in India’s democratic polity for 52 years.
That disunity was a factor that led to British rule over South Asia had been a part and parcel of the awareness of Nationalist awakening since the 19th Century. The trauma of partition at independence accentuated the anxiety of ‘disunity’. Emergence of the post revolutionary regime in 1949 in China heightened the sense of persecutory anxiety once represented by the “castrating Muslim Plunderer” and “bad British-colonial Mother”. Thus long before insurgency became the defining characteristic of Northeast, referring to Assam, the land of nationalist Gopinath Bordoloi, and the political leadership of Manipur, Sardar Patel wrote to Jawahar Lal Nehru
“The People inhabiting these portions have no established loyalty or devotion to India. Even the Darjeeling and Kalimpong areas are not free from pro-Mongoloid prejudices”.
In other words, the entire population was clearly defined as the ‘Cultural Other’.
Manipur: Irom Sharmilla’s struggle and her body as site of contestation
While there were other instances of ‘Merger Agreements’, being signed in situations of stress and duress (Jammu and Kashmir) as well as of military intervention (the police action that ended Nijam’s rule in Hyderabad in 1948), what makes the Manipur situation unique is the stream-rolling of democratic institutions that the merger represented, the irony of a state (India) which at that time aspired to be a democratic republic, but was not one yet. Effectively undermining the foundations of an existing democratic state through what is basically a military manoeuvre makes the case of Manipur quite exceptional. That all this was justified not by reference to the ‘will of the people’ of the territories concerned (as was the case with Hyderabad) or by a response to internal aggression (as is said to be the case with Jammu and Kashmir), but by a ‘strategic necessity’ is all the more revealing. The reason cited for the decision to annex Manipur: Manipur is a ‘border state’ and ‘backward’ therefore its takeover is a ‘strategic’ necessity. These were the expressions used by V.P. Menon. The fact that he uses the expression ‘takeover’ to mean ‘integration’ speaks for itself.
“Indian army rape us” read the banner which the women were holding when they protested against the murder and death of Manorama devi in front of Army Headquarters in Imphal, Manipur in year 2004. Thangiam Manorama, a Manipuri woman, was raped and murdered by jawans of Rastriya rifles in July 2004. She became of symbol of atrocities faced by the people North East for the past 60 years. If the abduction and cold-blooded murder of Manorama devi showed the brutal face of Indian occupation, the indomitable courage of Irom Sharmila signifies the strength of peaceful resistance of a beleaguered people.
The 39 year old Manipuri is about to complete 11 years of a hunger strike in protest against AFSPA that gives security forces powers to kill with impunity. The UPA promised as far back as 2004 to replace the act with a ‘more humane’ law but has shown little interest in taking up the task in the face of opposition from the internal security establishment. Union Home Minister P Chidambaram recently admitted there was no consensus within the Government on the issue. Ms Sharmila’s fast began on November 3, 2000, a day after security personnel shot down 10 people at a bus stand just outside Imphal.
Within days, she was detained by the police, since then, she has been nasally force-fed a liquid concoction of nutrients in a hospital, which serves as her prison. After every year in detention, she is released for a day and rearrested for attempting to commit suicide, because she refuses to call off her fast until the government repeals the legislation, which is in force in Manipur, Assam, Nagaland and parts of Arunachal Pradesh besides, Jammu and Kashmir. Hers may be the longest hunger strike in recorded history but it has generated little or no interest outside Manipur. In recent days, the attention Ms Sharmilla has received in the wake of Anna Hazare’s anti corruption hunger strike has served to highlight her personal life.
By legitimizing the use of military force in the internal affairs of the state beyond what is already provided in the Criminal Procedure Code and the provisions of emergency in the constitution, AFSPA seeks to supplant rather than supplement civil authority with military authority in the administration of everyday life. To convert such an ordinance into a regular law that stays in place for almost half a century is to entrench a military structure and ethos in the polity and structure of the state. It sets into motion the process of reproduction and appropriation of the military structure and ethos by other instruments of the State (the paramilitary and police) as well as civil society itself. Ultimately, it leads to a complete subversion of the basic foundation of society and polity. It blurs the necessary distinctions between the police and the military, between the civilian and the combatant, and between ‘domestic’ and ‘alien’ space. This is what has happened in Manipur.
As Bimol Akoijam says: the single Act AFSPA has given rise to a plethora of Acts of horrors, like the thousands of murders, rapes, custodial deaths, disappearances, tortures, combing operations and genocide. Recently discovered unmarked graves in Kashmir are a chilling testimony to these hard realities of everyday life in Kashmir and the Northeast.
The lists of such acts of horror in the Northeast is long, but to name a few well known cases, from 1980, onwards they include: the massacres of civilians at Heirangoi thong (Manipur) in 1984, at RIMS Manipur in 1995, at Malom (Manipur) in 2000; the horror of army torture and violence on civilians during operation Blue bird (Manipur) in 1987 and operation Rhino (Assam) in 1991. Indiscriminate firing on civilians by armed forces personnel when their own vehicle burst in the town of Kohina (Nagaland) in March 1995, the shelling and destruction of the town of Makokchung (Nagaland) in 1994, the enforced disappearances of Loken and Lokendro (Manipur) in 1996, and the rape of Miss N Sanjita (who subsequently committed suicide) (Manipur) in 2003.
Armed Forces (Special Powers) Act 1958: A Fact Sheet adopted by the SAHELI and PUDR team from earlier reports and submissions to the Jeevan Reddy Committee:
Over the last five decades, heavy militarization in the north east has taken its toll on normal civilian life and led to innumerable instances of violations committed against the civilian populations there. Encounter deaths, extra judicial killings, disappearances, arbitrary arrests, rape and torture have been a regular feature among the relentless series of atrocities meted out to the people by the army with impunity, especially in areas where they are protected by legislation like AFSPA.
Some of the most widely known incidents of such horror in the north east are:
Army torture and violence against the villagers of Oinam (Manipur) in 1987 who were detained in army camps, beaten mercilessly, given electric shocks. At least 3 women were raped, 15 villagers killed, and many left permanently disabled;
-The gang rape of the women of Ujanmaidan (Tripura)by security forces;
-The terror wreaked by the army in Assam during Operation Rhino in 1991;
-the shelling of town of Ukhrul (Manipur) with mortars in May 1994 by the Assam Rifles when they violently ransacked the town, leaving many homes damaged, over a hundred men and women bleeding with serious injuries and 3 dead;
-four women raped at gunpoint, and homes and shops set on fire by the Maratha Light Infantry, killing others people in December 1994 in Mokokchung (Nagaland);
-indiscriminate firing on civilians and combing operations by the combined forces of the 16th Rashtriya Rifles, CRPF and Assam Rifles when a tyre of an army jeep burst in the Kohima town (Nagaland) in March 1995;
-torture, forced detaining, starvation, sexual assault of women and looting in the 5 villages of Namtiram (Manipur) in 1995 by the 21st Rajputana Rifles;
-the army’s reign of terror in Jesami (Manipur) in January 1996;
-the rampage of the village of Huishu (Manipur) by the Assam rifles in March 1996
-the massacre of 10 innocent civilians by the Assam Rifles in Malom (Manipur) on 2 November, 2000 by security forces
-the torture, rape and killing of Thangajam Manorama in Imphal (Manipur) in 2004
A. Bimol Akoijam: Another, 9/11, Another Act of Terror: The Embedded disorder of the AFPSA.
Nayanjyoti: Integrate, Develop or shooting to kill on Suspicion in South Asian Periphery, term paper submitted to CSSS/SSS/JU.
End army rule, committee for the repeal of the Armed Forces Special Powers Act, Delhi.
An Illusion of Justice, PUDT Delhi 1998.
Licence to Kill-INSAF, Delhi 2005.
Fantasies of Development and the Democracy deficit in North East India by Sanjib Barvah.
An Analysis of Armed Forces special power act 1958 PUCL and Asian Centre for Human Rights. Manipur in the shadow of AFSPA.
Love in the time of AFSPA. Hindu editorial.
Poem on Sharmilla by Kamayani Bali Maha Bal.
SAHELI-PUDR Fact Sheet on Human Rights abused in Northeast.
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