Denial of Bengali Muslim Citizenship in Assam, India

Cameron Giebink

On August 31, 2019, 1.9 million people in India’s Assam state, most of them Muslim in a largely Hindu country, found themselves stateless.[1] Residents were given 120 days to challenge their exclusion from Assam’s National Register of Citizens (NRC) before being branded unlawful foreigners subject to deportation.[2] The consequences of omission are dire, and history suggests bloodshed may loom.[3] This conflict has deep roots but the situation today may be approaching a tipping point. Fueled by the militant Hindu nationalism of India’s ruling Bharatiya Janata Party (BJP) and stoked by social media antagonists, the stage for unspeakable tragedy has been set.

While some Indians have offered resistance, domestic opinion favors the NRC and the BJP has even pushed legislation to legitimize all non-Muslim immigrants.[4] Even in this tenuous climate, opportunities to avoid bloodshed remain. International pressure could push the Indian government to undertake citizenship determinations fairly, limiting the number of people affected, while a return to Constitutional norms could prevent the targeting of Muslims. Furthermore, an amnesty program could pave the way for long-term, positive peace in the region.

Historical Backdrop

            Assam’s contemporary conflict, pitting largely Muslim Bengalis against the Hindu Assamese, is rooted in a centuries-old tale of migration and conflict. After establishing their rule in the early 1800s, the British encouraged Bengali immigration to administer the colony and bolster agricultural production.[6] Throughout the early 20^th century, Assam’s Bengali population grew, and by the time the country was partitioned in 1947, it represented an electoral majority. However, partition severed Muslim strongholds from Assam, leaving the Assamese in control, and the Assamese quickly reasserting their primacy.[7] In 1979 a 38% jump in registered voters over the preceding sixteen years led the All Assam Students Union (AASU) to call for illegal immigrants to be purged from voting rolls.[8] In 1983, anti-immigrant tensions exploded as mobs of villagers burned Muslim homes and butchered some 4,000 Muslim residents.[9]

This prompted the 1985 Assam Accords, which sought to “detect, delete and deport all illegal foreigners.”[11] Agitation and sporadic violence continued through the 1990s and 2000s, ultimately leading India’s Supreme Court to order the state to complete the NRC, as stipulated in the Assam Accords.[12]

Resource Scarcity

 “The ostensible reason for attacks against Bengali Muslims is invariant – they are accused of being illegal immigrants who . . . occupied land belonging to the native population.”[13] Census data fleshes out this concern. Assam’s 2011 population stood at 31,205,576,[14] 398 people per square kilometer, or twelve times the density of the US.[15] Furthermore, Assam experienced a growth rate of 17.07% between 2001 and 2011, exacerbating fears of future access to land and associated resources.[16]

While similar density issues plague India generally,[17] these challenges are particularly acute in Assam due to its agrarian economy.[18] Without prospects for diversified economic growth, “land becomes the main source of livelihood.”[19] It follows that violence erupted in the 1980s during a sharp general population spike,[20] rather than during the first half of the 20^th century when Assam experienced its highest rates of Bengali Immigration.[21] “As long as there was excessive land in the state for cultivation, immigration did not result in a clash of material interests. But once the optimum level was reached, competition and conflicts developed amongst groups for control over limited resources and opportunities.”[22]

Assam’s land squeeze may soon be exacerbated even further by a water shortage. While the state enjoys prolific rainfall, Assam “has lost two per cent of its usable groundwater resource and is at the brink of suffering drought and famine in impending years.”[23] This may further inflame tensions between Assamese and Bengali residents as they compete for ever- scarcer resources.

The Rise of Hindu Nationalism 

            Hindu nationalism, and accompanying anti-Muslimism, arose alongside resistance to British imperialism during the early 20^th century.[24] While anti-Muslimism was relegated to the fringes of Indian political thought for most of the 20^th century, its role has re-emerged with the rise of the BJP. The party’s “political roots lie in a Hindu nationalist movement that emphasizes the religion’s supremacy.”[25] Since the BJP’s Narendra Modi “took office in 2014, government bodies have rewritten history books, lopping out sections on Muslim rulers, and changing official place names to Hindu from Muslim.”[26] The rise of communal tensions has also strengthened the BJP’s position and it won control of Assam in 2016, two years after sweeping into power nationally.[27]

This emphasis on Hindu supremacy has led to mixed messaging on immigration. While the BJP has called Bengali Muslims “termites” who should be “thrown into the Bay of Bengal,”[29] it has also proposed a Citizenship Amendment Bill which would “ease the way for non-Muslim minorities from neighboring countries to become citizens.”[30] This is because the BJP sees Bangladeshi Hindu refugees as integral to their electoral success.[31] By painting the issue as one of “infiltration,” designed to destabilize all of India, the party has characterized the conflict as a religious clash, despite the presence of many Hindu Bengali immigrants in Assam.[32]

The religious tone of Modi’s presidency is perhaps best underscored through his relationship with Pakistan.[33] Domestically, the BJP has leveraged anti-Pakistani, anti-Muslim, identity politics “to extend their control over the Hindu votes by creating a bogey of Muslim fundamentalism.”[34] In one striking example, in 2019 “Mr. Modi unilaterally wiped out the statehood of India’s only Muslim-majority state, Jammu and Kashmir, removing its special autonomy and turning it into a federal territory without any consultation with local leaders.”[35] In this context, the threat of statelessness faced by Assam’s Muslims today cannot be confined to the state’s borders. Politicians in neighboring states have asked that their citizens be registered and the BJP has called for the exercise to be carried out nationwide.[36] Thus, the conflict in Assam, and the situation in Kashmir, may represent the first steps in a nationwide drive to assert the primacy of Hinduism, to the detriment of Muslims, throughout all of India.

Social Media

Social media platforms play an evolving role in Assam, facilitating communal resentment and holding the potential to unleash outbursts of violence. As early as May of 2005, “[m]obile phones in Assam [were] flooded with text messages saying, ‘Save the nation, save identity. Let’s take an oath: no food, no job, no shelter to Bangladeshis,’” prompting thousands of Bengalis to flee.[37] Since then, the ubiquity and significance of social media’s messaging has only grown. One study found that 86% of Assamese youth discussed social issues on social media, 96% believed that social media was “an effective platform for staging protests and gathering public support,” and 95%  believed that social media protests result in real world consequences.[38] Most notably, the study identified illegal immigration from Bangladesh as the most commonly-voiced  concern on social media.[39]

Social media was also integral to the 2012 protests which spurred the government to complete the NRC. In the summer of 2012, groups such as “STOP AND ERADICATE ILLEGAL BANGLADESHI IMMIGRATION” shared news articles and comments about immigration on Facebook.[40] At the same time, student groups organized a series of protests on social media, demanding “the update of the NRC” and “quick implementation of the core principles enshrined in the Assam Accord.” [41] This activism was then reflected “on the streets of Guwahati and several parts of Assam” as thousands of people flooded the streets, “seeking  urgent  measures  from  the  state  government  to  detect  and  deport  illegal Bagladeshis.”[42]

The dissemination of unsubstantiated rumors has also led to bloodshed. In June of 2018, two Assamese youth were lynched after false rumors about their involvement in child trafficking circulated on WhatsApp.[43] This is particularly concerning as “[p]osts targeting religious and ethnic minorities in Assam have been seen more than 5.4 million times” and some have included “call[s] for them to be exterminated.”[44]

Events like the lynching prompted local police to create social media cells “to identify and defeat fake news.”[45] Police engagement, however, has not necessarily served to protect Assam’s Muslims. After one Muslim student posted about eating beef following the Indian national cricket team’s loss to Pakistan, she was met with outrage rising to “rape threats on social media.”[46] Rather than following up on the threats, the “Assam Police registered a suo motu case against [the victim] under the Information Technology Act.”[47]

The National Register of Citizens

“The NRC list is unique to Assam and was first prepared in 1951” after a nationwide census.[48] The document is essentially an accounting of all the Indian citizens living in the state. During the 1980s, unrest over Bengali immigration led the government to agree to the Assam Accords, in which the state promised to update the NRC and deport all residents whose names were not reported therein.[49] The NRC’s definition of illegal immigrants is also taken from the Assam Accords and “anyone who cannot prove that they or their ancestors entered the country before midnight of March 24, 1971, [will] be declared a foreigner and face deportation.”[50]

In 2012, renewed frustration with the government’s perceived failure to deport Bengali immigrants led to massive protests, and in 2013, “Assam Public Works filed a petition asking that so-called illegal migrants be struck off the electoral rolls.”[51] The Indian Supreme Court ordered an updated NRC be published in Assam, noting; “The culture of an entire people is being eroded in such a way that they will ultimately be swamped by persons who have no right to continue to live in this country.”[52] The project was subsequently launched in 2015 and since then has been “monitored directly by the Supreme Court.”[53]

The current NRC is to include those whose names appeared in the 1951 NRC, their descendants, and anyone who has been listed on India’s electoral rolls, or in any other approved government document, since March 23, 1971, as well as their descendants.[54] Those whose names were not recorded in earlier documents have been required to submit evidence substantiating their relationship with listed individuals such as “land records, bank accounts, government certificates, or other similar documents” indicating their “ancestors lived in India before March 24, 1971.”[55] Disturbingly, clerical errors like misspelled names, common given that 28% of Assam is illiterate,[56] and inconsistent birth dates, notorious in rural India, have led authorities to strip citizenship from individuals who have never lived outside the country.[57]

In addition to clerical issues, the Supreme Court’s validation of an “original inhabitants” category, which “contemplates a less strict and vigorous process for deciding claims” of Assamese as opposed to Bengali petitioners, further hindered Bengali registration efforts.[58] Then, In March of 2017, the High Court in Assam ruled that residency certificates issued by village councils could not be used to link petitioners born after 1971 with their ancestors.[59] While this decision was eventually overturned by the Supreme Court, local certificates alone remain insufficient, and must be substantiated by additional documents, further complicating matters for Muslim women whose marriages are often only documented at the village level.[60]

After passing through two preliminary drafts, the final NRC was released on August 31, 2019 and left 1.9 million people off the register.[61] The names of those left off the NRC have been marked with a “D,” for doubtful, on official voting rolls.[62] However, this iteration of the NRC has not been finalized, as those excluded from the final list were given “120 days to prove their citizenship at hundreds of regional quasi-judicial bodies known as foreigners’ tribunals.”[63]

Foreigner Tribunals

Under the Foreigners Act of 1946 and the Foreigners Tribunal Order of 1964, only Foreigner Tribunals are empowered to declare people foreigners. Thus, omission from the NRC alone does not render anyone deportable.[64] Those whose names were omitted from the NRC may now appeal to Foreigner Tribunals set up throughout the state. Initially, thirty-six Tribunals operated in the state but in 2013, the Supreme Court  found that number “abysmally low” and authorized the creation of sixty-four additional tribunals.[65] This brought the number to 100 and the government planned to establish another 200 after the release of the NRC’s final draft.[66] In reality, to date, more than 500 tribunals have been established to hear NRC appeals.[67]

These Tribunals are quasi-judicial hearings established as part of the Illegal Migrants Act of 1983.[68] The law was actually struck down by the Supreme Court in 2005 because its provisions “were so stringent, they made the ‘detection and deportation of illegal migrants almost impossible.’”[69] Nonetheless, the tribunals remain, and according to law, they provide anybody whose name is not included in the final list an opportunity to appeal.[70] Finally, if petitioners are unhappy with their tribunal ruling, the determination may be appealed to the Supreme Court.[71]

To succeed on appeal, a petitioner must present “some document pre-dating March 24, 1971.”[72] Given the number of people omitted from the NRC, a plethora of issues have plagued the process. First, despite promises that alleged foreigners would be provided notice of their exclusion,[73] the Tribunals have received accusations that they are little more than ex parte judgments against people who never received notice from the court.[74] Second, the members presiding over the trials have testified before Assam’s high court that they are “hired on contracts, which aren’t renewed if they do not brand enough people as foreigners.”[75] Finally, the tribunals have shown a record of discrimination; a recent survey found that “nearly nine out of 10 cases were against Muslims [and] [a]lmost 90% of those Muslims were declared illegal immigrants — as compared with 40% of Hindus tried.”[76]

Construction of Camps

“Foreigners” are subject to internment in one of Assam’s six detention centers.[77] Until recently, they could be detained indefinitely, and while the Supreme Court ordered the release of detainees held longer than three years, it stipulated that a bond of ₹200,000 must be posted by the detainee prior to release.[78] Given that the average annual income in Assam is ₹64,046,[79] a typical detainee must pay more than three years’ annual salary to escape internment.

Furthermore, the state is building ten new foreigner detention centers in order to incarcerate every declared foreigner.[80] One of the planned centers will hold more than 3,000 detainees and include a school, hospital, recreation area, and living quarters for guards.[81] These new facilities suggest that long-term detention is the goal, rather than an unintended consequence. International negotiations bear out this intent, as India’s foreign minister recently informed his Bangladeshi counterpart that the NRC was an “internal matter” and that those declared to be “foreigners” would not be sent to Bangladesh.[82] Given that there is nowhere else to move the 1.9 million people left off the NRC, long-term internment is almost assured.

The Resistance

Nationally, “[a] small but vocal minority of intellectuals, Muslim leaders, and opposition politicians has tried to turn public opinion against Mr. Modi’s policies with little success.”[84] Despite India’s Constitutional commitment to secular government, the BJP continues to score legislative victories to the detriment of the Congress Party (CP), which poses the most powerful opposition to BJP policies.[85]  After the Citizenship Amendment Bill passed the lower house of parliament, CP staged a walkout to protest the bill, which they dubbed “an assault on the very imagination of India, of the freedom struggle, of the Constitution, of the idea of a country in which everyone belongs equally.”[86] The bill ultimately stalled due largely to protests in Assam.[87]

Locally, CP leaders have also led the resistance to the NRC, accusing the BJP of “creating a fear psychosis that [the] Muslim population is growing by leaps and bounds and they are going to swamp the local indigenous population.”[88] CP’s efforts have been aided by All India United Democratic Front, which advocates for people of Bengali origin and has provided legal and financial aid to those swept up in the immigration crackdown.[89]

While the UN has noted concern over the NRC process in Assam,[90] international press attention has been muted, and accordingly, governments have done little to address it. Furthermore, the foreign nation with the most at stake, Bangladesh, has declared that those “who don’t figure in the draft NRC lists are not its citizens and it is not responsible for them.”[91]

However, international recognition is not entirely lacking. Genocide Watch flagged the activity in Assam, identifying the ongoing crisis as entering a preparation stage, the seventh of ten stages precipitating all-out genocide.[92] Likewise, Human Rights Watch has called on Indian authorities to “ensure the rights of Muslims and other vulnerable communities in Assam,” and Amnesty International noted the need for transparency and fairness from Foreigner Tribunals.[93] Still, the international response has been quiet and will likely remain so, barring violent escalation.

The Path Forward

The groundwork for ethnic cleansing has been laid in Assam. At a minimum, the situation bears five early genocide indicators based on Dr. Stanton’s stage model. First, the development of the Hindu-Indian/Muslim-Bangladeshi binary qualifies as classification. Second, omission from the NRC, and demarcation on voting roles, represents symbolization. Third, rhetoric referring to “termites” and “infiltrators” signifies dehumanization. Fourth, anti-Muslim political action groups created through social media and student activism represent organization. Fifth, dissemination of anti-Muslim messaging and the stripping of citizenship shows polarization. Moreover, the construction of detention facilities, release of the final NRC, and demarcation of voter lists may actually constitute preparation for genocide. If so, all six early indicators may be accounted for.

Still, bloodshed may be avoided. This depends on the evenhanded operation of foreigner tribunals, de-escalation of BJP rhetoric, and an amnesty program for those born in India. Steps may include; (1) ensuring that Foreigner Tribunals operate transparently and provide due process protections; (2) doing away with performance metrics based on the number or percentage of “foreigners” identified; (3) ensuring personal service of notice to all alleged foreigners so defendants are aware of pending trials; and (4) prohibiting ex parte determinations. Instituting these safeguards may soften the NRC’s impact, given that Assam’s population of illegal Muslim immigrants likely lies somewhere between 125,000 and 502,000.[94] While the prospect of half a million stateless people is horrifying, absorbing this group into Indian society is more politically palatable than accommodating two million people.

Political palatability is necessary because amnesty for those born in India may provide a path towards positive peace. While politically untenable at present, a stay of the Citizenship Amendment Act could prompt the BJP, which counts on Hindu immigrant votes, to engage on immigrant amnesty. Assamese fears of economic competition could be mollified with a verification program and penalties for companies hiring illegal migrants. Moreover, a ten-year moratorium on immigrant voting rights could accommodate fears of an impending Bengali takeover and provide political cover to BJP negotiators. In exchange, those who were born in India would receive citizenship, and after ten years and the payment of a one-time, ₹200,000 fine, equal to what detainees currently pay as bond, they would receive voting rights. While this compromise is far from perfect, it would foster improvements in governance through the rule of law; promote the equitable distribution of resources and social mobility; improve relations with Bangladesh by decreasing hostility towards foreigners; and improve the acceptance of others by decreasing group grievances, thereby strengthening four pillars of positive peace.[95]

 

 

[1] Helen Regan & Manveena Suri, 1.9 Million Excluded from Indian Citizenship List in Assam State, CNN (Aug. 31, 2019, 2:13 AM), https://www.cnn.com/2019/08/30/asia/assam-national-register-india-intl-hnk/index.html.

[2] Debasish Roy Chowdhury, Abandoned in Assam, South China Morning Post: This Week in Asia (Aug. 23, 2019, 8:42 PM), https://www.scmp.com/week-asia/society/article/3024155/assam-edge-indias-rohingya-moment-threatens-millions-modis-hindu.

[3] Ranjan Basu, Assam NRC: Should Bangladesh be concerned?, Dhaka Trib. (Sep. 3, 2019, 3:46 PM),  https://www.dhakatribune.com/bangladesh/foreign-affairs/2019/09/03/assam-nrc-should-bangladesh-be-concerned (“The authorities will probably attempt to make a position of second class citizen within India.”).

[4] Krithika Varagur, Indian Home Minister Promises Non-Muslim Citizenship Bill, Wash. Post (Oct. 1, 2019, 8:14 AM), https://www.washingtonpost.com/world/asia_pacific/indias-top-minister-promises-non-muslim-citizenship-bill/2019/10/01/1b3dbbe6-e43f-11e9-b0a6-3d03721b85ef_story.html.

[5] https://www.mapsofindia.com/states/

[6] H. Srikanth, Militancy and Identity Politics in Assam, 35 Econ. & Pol. Wkly., Nov. 18-24, 2000, at 4117, 4118.

[7] Myron Weiner, The Political Demography of Assam’s Anti-Immigrant Movement, 9 Population & Dev. Rev., June 1983, at 279, 283-84.

[8] Monirul Hussain, State, Identity Movements and Internal Displacement in the North-East, 35 Econ. & Pol. Wkly., Dec. 16-22, 2000, at 4519, 4519.

[9] Weiner, supra note 6, at 280

[10] https://www.americanprogress.org/issues/security/reports/2012/08/29/35050/understanding-the-historical-conflicts-behind-todays-violence-in-assam/.

[11] Chowdhury, supra, note 2.

[12] Vivek Singh, In Assam, a Familiar Pattern of Violence, N.Y. Times (May 8, 2014, 10:41 AM), https://india.blogs.nytimes.com/2014/05/08/in-assam-a-familiar-pattern-of-violence/?searchResultPosition=7; K. Anis Ahmed, Why Is India Making Its Own People Stateless?, N.Y. Times (Sep. 11, 2019), https://www.nytimes.com/ 2019/09/11/opinion/india-assam-stateless-bengalis-muslim.html?searchResultPosition=1.

[13] Vani Kant Borooah, The Killing Fields of Assam: Myth and Reality of Its Muslim Immigration, 48 Econ. & Pol. Wkly., Jan. 26, 2013, at 43, 44.

[14] Assam Population 2011-2019 Census, Census 2011 India, https://www.census2011.co.in/census/state/assam.html (last visited Oct. 15, 2019).

[15] 2010 Census: Population Density Data, U.S. Census Bureau, https://www.census.gov/data/tables/2010/dec/density-data-text.html (last visited Oct. 16, 2019).

[16] Census 2011 India, supra note 12.

[17] Population Census 2011, Census 2011 India, https://www.census2011.co.in/ (last visited Cot. 15, 2019).

[18] Srikanth, supra note 5, at 4123.

[19] Srikanth, supra note 5, at 4123.

[20] Population of Assam, Stat. Times, http://statisticstimes.com/demographics/population-of-assam.php (last visited Oct. 15, 2019).

[21] Borooah, supra note 11, at 48.

[22] Srikanth, supra note 5, at 4123.

[23] Tulika Devi, From ‘Insane’ to ‘Innovative’, How This Assam Engineer Planned to Tackle Looming Water Crisis, News18 (July 4, 2019, 11:10 PM), https://www.news18.com/news/india/from-insane-to-innovative-how-this-assam-engineer-planned-to-tackle-looming-water-crisis-2217631.html.

[24] Praful Bidwai, Confronting the Reality of Hindutva Terrorism, 43 Econ. & Pol. Wkly, Nov. 22-28, 2008, at 10, 11.

[25]Jeffrey Gettleman & Hari Kumar, India Plans Big Detention Camps for Migrants. Muslims Are Afraid., N.Y. Times (Aug. 17, 2019), https://www.nytimes.com/2019/08/17/world/asia/india-muslims-narendra-modi.html?module=inline.

[26] Id.

[27] Shoaib Daniyal, Why Hindu Immigrants from Bangladesh are a Key Component of the BJP’s West Bengal Expansion Strategy, Scroll.in (Aug 10, 2017, 9:00 AM), https://scroll.in/article/845354/why-hindu-immigrants-from-bangladesh-are-a-key-component-of-the-bjps-west-bengal-expansion-strategy; India’s BJP Wins Landmark Assam Victory, BBC News (May 19, 2016), https://www.bbc.com/news/world-asia-india-36319405.

[28] https://commons.wikimedia.org/wiki/File:Narendra_Modi_(cropped).jpg

[29] Ahmed, supra note 10.

[30] Zeba Siddiqui & Zarir Hussain, India leaves Nearly Two Million People off Citizens’ List, Fate Uncertain, Reuters (Aug. 31, 2019, 1:21 AM), https://www.reuters.com/article/us-india-politics-citizenship/india-leaves-nearly-two-million-people-off-citizens-list-fate-uncertain-idUSKCN1VL04W

[31] Daniyal, supra note 25.

[32] Borooah, supra note 11, at 51.

[33] Gettleman & Kumar, supra note 23.

[34] Srikanth, supra note 5, at 4122.

[35] Gettleman & Kumar, supra note 23.

[36] Ahmed, supra note 10.

[37] Bangladeshis in Assam Flee Anti-Migrant Drive, N.Y. Times (May 20, 2005), https://www.nytimes.com/2005/05/ 20/world/asia/bangladeshis-in-assam-flee-antimigrant-drive.html?searchResultPosition=22.

[38] Manoj Deori & Sunil Behera, Youth Activism Through Social Media in Assam: An Exploratory Study, 4 DEV SANSKRITI: Interdisc. Int’l J., 8, 15-17 (2014) (Figures 4, 7 & 8).

[39] Id. at 19.

[40] Id. at 11.

[41] Id. at 12.

[42] Id.

[43] Pranjal Baruah & Manimugdha S. Sharma, Armed with Twitter Wit, Assam Police is India’s Latest Social Media Darling, Times of India (June 30, 2019, 10:41 AM), https://timesofindia.indiatimes.com/home/sunday-times/armed-with-twitter-wit-assam-police-is-indias-latest-social-media-darling/articleshow/70007712.cms.

[44] Billy Perrigo, Facebook Was Used to Incite Violence in Myanmar. A New Report on Hate Speech Shows It Hasn’t Learned Enough Since Then, Time (Oct. 29,2019), https://time.com/5712366/facebook-hate-speech-violence/.

[45] Baruah & Sharma, supra note 40.

[46] How a PhD Scholar Was Branded ‘Anti-National’ by Assamese Media Over Fake News, NewsClick (20 Aug 2019), https://www.newsclick.in/how-PhD-scholar-branded-anti-national-assamese-media-over-fake-news.

[47] Id.

[48] Saif Khalid, India Publishes Final NRC: All You Need to Know on Citizens’ List, Al Jazeera (Aug. 31, 2019), https://www.aljazeera.com/news/2019/08/final-nrc-list-india-assam-190829133456422.html.

[49] Chowdhury, supra note 2.

[50] Ipsita Chakravarty, Explainer: What exactly is the National Register of Citizens?, Scroll.in (July 15, 2019, 8:00 AM), https://scroll.in/article/930482/explainer-what-exactly-is-the-national-register-of-citizens.

[51] Id.

[52] Atul Dev, India Is Testing the Bounds of Citizenship, The Atlantic (Aug 31, 2019), https://www.theatlantic.com/international/archive/2019/08/india-citizenship-assam-nrc/597208/.

[53] Id.

[54] Khalid, supra note 45.

[55] Dev, supra note 49.

[56] Census 2011 India, supra note 12.

[57] Dev, supra note 49.

[58] Dev, supra note 49.

[59] Chakravarty, supra note 47.

[60] PTI, Supreme Court Says Gram Panchayat Certificates No Proof of Citizenship, Mint (Nov. 22, 2017, 7:54 PM), https://www.livemint.com/Politics/hukI7PrhdcvnCYtWOhbAYM/Supreme-Court-says-gram-panchayat-certificates-no-proof-of-c.html.

[61] Regan & Suri, supra note 1.

[62] Saif Khalid, ‘Harassed, discriminated’: Story of Assam’s Bengali origin people, Al-Jazeera (June 23, 2018),  https://www.aljazeera.com/indepth/features/discriminated-story-assam-bengali-origin-people-180620101455019.html.

[63]  Siddiqui & Hussain, supra note 27.

[64] IANS, NRC: 400 Foreigners’ Tribunals to Deal with Cases of Excluded People, Econ. Times (Aug 31, 2019, 9:25 AM), https://economictimes.indiatimes.com/news/politics-and-nation/nrc-400-foreigners-tribunals-to-deal-with-cases-of-excluded-people/articleshow/70919445.cms.

[65] Arunabh Saikia, ‘The Highest Wicket-Taker’: Assam’s Tribunals are Competing to Declare People Foreigners, Scroll.in (June 19, 2019, 9:00 AM), https://scroll.in/article/927025/the-highest-wicket-taker-assams-tribunals-are-competing-to-declare-people-foreigners.

[66] Khalid, supra note 45.

[67] Manogya Loiwal, Assam NRC: Foreigners Tribunals Set to Hear Appeals, India Today (Sep. 3, 2019 4:28 PM), https://www.indiatoday.in/india/story/assam-nrc-foreigners-tribunals-1594975-2019-09-03.

[68] Chakravarty, supra note 47.

[69] Chakravarty, supra note 47.

[70] Loiwal, supra note 64.

[71] Khalid, supra note 59.

[72] Loiwal, supra note 64.

[73] Loiwal, supra note 64.

[74] Khalid, supra note 45.

[75] Dev, supra note 49.

[76] Rohini Mohan, Inside India’s Sham Trials That Could Strip Millions of Citizenship, Vice News (July 29, 2019), https://news.vice.com/en_us/article/3k33qy/worse-than-a-death-sentence-inside-indias-sham-trials-that-could-strip-millions-of-citizenship.

[77] Khalid, supra note 45.

[78] Saikia, supra note 62.

[79]Directorate of Economics and Statistics, State Income Statistics, Gov’t of Assam, https://des.assam.gov.in/information-services/state-income (last visited Oct. 15, 2019).

[80] Khalid, supra note 45.

[81] Zeba Siddiqui, As They Build India’s First Camp for Illegal Migrants, Some Workers Fear Detention There, Reuters (Sep. 7, 2019, 8:13 PM),  https://www.reuters.com/article/us-india-politics-citizenship-camp/as-they-build-indias-first-camp-for-illegals-some-workers-fear-detention-there-idUSKCN1VT00K.

[82] Internal Affairs: On Assam NRC, The Hindu (Aug. 23, 2019 12:05 AM), https://www.thehindu.com/opinion/editorial/internal-affairs-on-assam-nrc/article29224745.ece.

[83] https://www.indiatoday.in/india/story/nrc-story-how-assam-got-detention-centres-for-foreigners-1631835-2019-12-27

 

[84] Gettleman & Kumar, supra note 23.

[85] Varghese K. George, The Idea of Congress-Free India, The Hindu (June 1, 2019, 12:02 AM), https://www.thehindu.com/opinion/lead/the-idea-of-congress-free-india/article27394440.ece.

[86] ET Online, Lok Sabha Passes Citizenship (Amendment) Bill, Econ. Times (Jan. 8, 2019, 5:48 PM), https://economictimes.indiatimes.com/news/politics-and-nation/lok-sabha-passes-citizenship-amendment-bill/articleshow/67438267.cms; Gettleman & Kumar, supra note 23.

[87] India Citizenship Amendment Bill Dropped Amid Protests, BBC News (Feb. 13, 2019), https://www.bbc.com/news/world-asia-india-47226858.

[88] Khalid, supra note 59.

[89] Khalid, supra note 59.

[90] Press Release, High Commission on Refugees, UN High Commissioner for Refugees Expresses Alarm at Statelessness Risk in India’s Assam, U.N. Press Release (Sep. 1, 2019), https://www.unhcr.org/en-us/news/press/2019/9/5d6a24ba4/un-high-commissioner-refugees-expresses-alarm-statelessness-risk-indias.html.

[91] The Hindu, supra note 79.

[92] Dr. Gregory H Stanton, Genocide Watch for Assam, India – Renewed, Genocide Watch (Aug. 18, 2019), https://www.genocidewatch.com/single-post/2019/08/18/Genocide-Watch-for-Assam-India—renewed.

[93] India: Assam’s Citizen Identification Can Exclude 4 Million People, Human Rights Watch (July 31, 2018, 2:15 AM), https://www.hrw.org/news/2018/07/31/india-assams-citizen-identification-can-exclude-4-million-people; Nazia Erum, Uncertain Destiny For Millions In Assam Post NRC, Amnesty Int’l India (Aug. 31, 2019, 10:23 AM), https://amnesty.org.in/news-update/uncertain-destiny-for-millions-in-assam-post-nrc/.

[94] Borooah, supra note 11, at 48.

[95] Institute for Economics & Peace, Positive Peace Report 2018: Analysing the Factors that Sustain Peace 8 (Oct. 2018), http://visionofhumanity.org/reports.