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Harnessing Constitutional And Policy Spaces For
Organized Resistance
Movement To Save Hasdeo Aranya Forests
Priyanshu Gupta
Indian Institute of Management Lucknow
(In “Organizing Resistance and Reimagining Alternatives in India”)
Abstract
This chapter documents the decade-long journey of Hasdeo Aranya Bachao Sangharsh Samiti –
an adivasi community-led resistance movement to resist displacement and protect their densely
forested and biodiversity-rich region. The movement has successfully resisted the capitalist
expansion of mining and infrastructure projects by utilising the available policy and constitutional
spaces. The use of decentralized governance provisions (PESA and FRA), continuous, and often
proactive, engagement with policy processes for environmental and social clearances have
become the focal points of resistance. The ‘gram sabha’ resolutions and dialogues across scales
of governance (local to state and central government), have emerged as valuable tools to bridge
the tyranny of distance from the seats of political power and media influence. Further, the strategy
of careful framing that amalgamates environmental and social dimensions of resource conflict and
tactically leveraging the broader civil society network to amplify local voices has allowed Hasdeo
Aranya forests to emerge at the centre stage of energy-conservation policy debates in India. Thus,
this article showcases the potential and limits of harnessing the institutional spaces for organized
resistance, as available in a constitutional democracy.
Introduction
Accompanying the announcement of the largest-ever round of auctioning of coal blocks in India
in June 2020 were stories of resistance from a relatively nondescript region of central India: the
Hasdeo Aranya forests. The media outlets – regional, national, and even global – were replete with
news of letters from sarpanchs
1
(Alam, 2020; Kaiser, 2020), petitions from the gram sabhas
2
(Mishra, 2020b), reports of organized community resistance (Dasgupta, 2020; MS, 2020), and
even interventions from the state government of Chhattisgarh (Drolia and John, 2020; Singh, 2020)
and the political elites like the former Union Environment Minister Jairam Ramesh (The Wire,
2020). The community resistance of 20 villages of one of the most impoverished states of India
threatened to put a spanner into the Prime Ministers’ plans of ‘Atmanirbhar Bharat’ (a self-reliant
India) and dreams of becoming the world’s largest exporter of coal (Gupta and Regan, 2020; PTI,
2020). The Guardian characterized Hasdeo Aranya as the ‘battleground’ where the ‘war’ for coal
pitted ‘indigenous people, ancient trees, elephants and sloth bears against the might of bulldozers,
trucks and hydraulic jacks’ (Ellis-Petersen, 2020, emphasis added).
However, descriptors such as war, battleground, and conflict are perhaps, the least likely to be
associated with the area based on traveler accounts. As one travels on NH130 around 300
kilometers from the state capital of Raipur, one is greeted by the relative calm and the resplendent
beauty of the expansive Hasdeo-Bango reservoir (one of the longest, widest, and oldest multi-
purpose irrigation projects in Chhattisgarh irrigating approximately 300,000 hectares of
agricultural farms downstream) at the beginning of Hasdeo Aranya forests. For another ~40
kilometers on the highway that skirts the Hasdeo Aranya forests’ periphery, the dense forest
canopy that almost entirely blocks sunlight appears as a welcome relief to weary travelers.
However, regular signboards indicating the need to be careful of ‘elephants’ and ‘sloth bears’
discourage casual tourists from stepping out to bask in the beauty of the surroundings. It is almost
entirely possible to miss any signs of habitation at the first visit beyond the occasional wooden
huts by the roadside, a couple of teashops, and the forest range office with its green signboards
camouflaged with the surroundings. Only a purposive visit to one of the villages a few kilometres
from the highway on one of the often muddy, arterial roads would reveal a warm and welcoming
1
Elected head of the local governance unit the ‘panchayat’
2
Gram Sabha refers to a constitutionally recognized village assembly that comprises of all the eligible voters of the
village
human populace that is eager to share stories of the forest, their encounters with wildlife, and their
peaceful quiet and happy existence since ages. What is striking is the slogans written on the walls
of almost every hut regarding the various legal and constitutional provisions. These include The
Panchayat Extension to Scheduled Areas Act (PESA Act, 1996), The Scheduled Tribes and Other
Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 (hereafter Forest Rights Act
or FRA 2006), Schedule 5 of Indian Constitution, and others. It requires one to dig deeper and ask
questions about these slogans to find stories of gloom, worries, and insecurities stemming from
the impending threat of displacement and of resolve to resist it. Perhaps, the more likely
characterization of the Hasdeo Aranya region would be of remoteness, calm, beauty, and a socio-
economically marginalized, relatively sparse Adivasi (indigenous tribes, literally ‘first/original
residents’) population.
Figure 1: Location of Hasdeo Aranya forests
The difference in this characterization of the region as one of the most critical battlegrounds across
India’s energy-conservation debate vis-à-vis a picture of remoteness and calm in traveler accounts
throws up a series of questions. How does a remote, peaceful, subaltern, and supposedly powerless
population capture the national (and international) imagination dominating media stories and the
policy debate, to challenge the State narrative on the most significant coal liberalization policy
action in recent times? What are the strategies and tools underlying the local community’s struggle
to resist displacement and protect their densely forested and biodiversity-rich regions? And what
are the prospects of their eventual success?
This article analyzes the decade-long journey of Hasdeo Aranya Bachao Sangharsh Samiti
(hereinafter HABSS) – the local adivasi community-led resistance movement to investigate these
questions. We find the key to this movement’s relative success in capturing the policy attention
lies in its ability to harness constitutional and policy spaces to launch and sustain organized
resistance. The gram sabha resolutions, reliance on legal provisions like PESA and FRA, and
dialogues across scales of governance (local to state and central government) have emerged as
valuable tools to bridge the tyranny of distance from the seats of political power and media
influence. The consequent framing and advocacy strategies allow for successful scaling and
amplification of local voices. However, we also note the limits and challenges of sustaining this
approach over the long run. The analysis is based on the author’s extensive fieldwork in the region
between 2014-2020 and comprises conversations with community members, movement leaders,
and references to documents maintained by HABSS.
In the next section, we outline the legal provisions and policy spaces offered by India’s forest
governance framework. Subsequently, we trace the social movement trajectory of HABSS to
analyze its strategies and tools of resistance. Thereafter, we explore the interim successes and
failures of the movement to highlight the existing legal framework’s challenges and limitations in
giving space to the local community resistance. Finally, we conclude by analyzing the long-term
implications of the HABSS’s movement on building alternative organizations for resisting
capitalist expansion.
Constitutional and Policy Spaces for Resistance
Hasdeo Aranya (literally the forests over the Hasdeo river) region represents a microcosm of forest
governance-related conflicts due to its vast mineral potential, strong environmental considerations,
and the habitat of the Adivasi population. It is one of the largest intact forest regions in central
India to remain outside of the protected area system, and therefore, not yet protected from non-
forest activities. The region comprises around 1900 sq. km. Eighty percent of which has dense
forests with an average forest cover density of over 40%, crossing even 70% in some parts
3
3
Under the Indian forest classification system, forests with canopy cover of 40-70% are classified as moderately dense
forests, and those above 70% are classified as very dense forests.
(HABSS, 2014; Sivalingam, 2014). As per the official working plan of the forest department, the
region has a rich biodiversity with over 300 species of flora and fauna, including some of the rare
and endangered species of flora and Schedule 1 protected mammals like elephant, leopard, and
sloth bear, among others (HABSS, 2014; National Green Tribunal, 2014)
4
. It is also believed to be
a part of a large contiguous elephant corridor with a high annual seasonal presence and regular
visits during other parts of the year. At the same time, it is one of the largest coalfields in India,
with estimated coal reserves of 5.2 billion tonnes and at least 20 identified coal mining blocks at
different stages of allocation and commencement of mining operations (HABSS, 2014). It is also
home to a population of around 15,000, approximately 80 percent of which comprises scheduled
tribes (Census, 2011). The tribal population includes majority Gond, interspersed with Majhwar,
Kawar tribes, and other communities. Minor forest produce, especially tendu (scientific name
Diospyros Melanoxylon) and mahua (scientific name Madhuca longifolia), constitutes a
significant share in the livelihood of the local population. Nearly 90 percent of households (both
tribals and non-tribals) are involved in its collection and close to 30-50 percent of the total income
of the household (Janabhivyakti, 2015) is derived from it.
Owing to the inherently contested nature of the resource, Hasdeo Aranya also emerges as a test
case for the multitude of policies and constitutional provisions designed to account for the distinct
considerations associated with India’s governance of forest resources. As we shall see in the next
section, these policy spaces and legal provisions emerge as critical tools for organizing the
resistance movement. It is important to recognize the trajectory of the evolution of these policy
spaces for local communities, especially since they remained essentially absent in the colonial and
much of the post-colonial era.
4
The National Green Tribunal is a quasi-judicial institution setup by the Ministry of Environment, Forest and Climate
Change (MoEFCC) for effective and expeditious resolution of legal disputes relating to issues of environment
protection, conservation of forests and other natural resources.
Figure 2: The Hasdeo Aranya Forests
Source: Photograph by Alok Shukla
A Brief History of Forest Governance in India
The traditional pre-colonial forest governance framework in India comprised a plethora of local
customary rights, which, though subordinated to the local kings and rulers, were respected as
primarily a domain of traditional community-led governance institutions. The advent of British
rule brought radical changes wherein the colonial administration through the forest department
asserted absolute authority over forests without recognizing the customary rights of the forest-
dwellers (Guha, 1983; Sivaramakrishnan, 1995). The colonial forest policy based on ‘scientific
forestry’ principles focused primarily on commercial exploitation of forest resources with limited
recognition of other forest-based resource uses (Guha, 1983; Sivaramakrishnan, 2009). The early
post-colonial policies, formalized as Forest Policy in 1952, largely followed the framework of
colonial policies. However, the post-colonial administration shifted its focus on industrialization,
resulting in large-scale clearance of forests for mining and other industrial projects, often with
limited resettlement or compensation to the forest dwellers. As a result, over 60 million people
were displaced in India during 1951-2004 for various kinds of developmental projects, of which;
a disproportionate 40% were tribals and forest dwellers (Fernandes, 2009). Although the
Constitution of post-independence India recognized the unique status of tribals and provided for
various socioeconomic policies for the so-called Scheduled Tribes, including provisions of self-
governance in Schedule 5 and Schedule 6 areas, such provisions did not get harmonized with the
forestry policies. Thus, contentious issues of land rights or tenurial reforms remained unaddressed
(Guha et al., 2012; Chemmencheri, 2015). In official parlance, the forest dwellers remained mere
‘encroachers’ with limited rights.
Growing environmental consciousness and a realization that State-led forest policy was unable to
prevent massive degradation and diversion of forests for non-forest uses brought a plethora of
policy changes in the 1980s and 1990s (Ramesh, 2017). These included The Environment
(Protection) Act, 1986 (for all aspects of environment protection), The Forest Conservation Act,
1980 (focused on forests), and the Wildlife Protection Act, 1972 (for ensuring wildlife
conservation). These legislations provide a veto right to the Ministry of Environment, Forest and
Climate Change (MoEFCC) through the clearances processes for forest diversion (Kumar, 2015).
As part of this framework, elaborate procedures and guidelines were developed to harmonize and
streamline the environment and forest clearance processes, including the introduction of a public
hearing with affected communities.
The other key change was decentralization through the Joint Forest Management (JFM) program
in 1988. The program was supported by international agencies and in line with global changes that
saw community resource governance as an efficient alternative to the State-led command and
control approach to forest conservation (Agrawal, Chhatre and Hardin, 2008; Larson and Dahal,
2012). The JFM program involved collaboration between forest officials and local community
members for managing the forest resources. However, there was limited participation of
communities in the planning process that was effectively controlled by the forest departments
(Sarin et al., 2003; Bose, 2012; Kashwan, 2013; Joshi, 2016). As Purabi Bose (2012) puts it, the
essential idea of JFM seemed to be that ‘we decide (the Forest Department) and you participate
(the forest people)’, and the forest dwellers were often reduced to mere laborers hired to plant trees
(Bose, 2012; Kashwan, 2013).
The growing marginalization and tenurial insecurity of forest dwellers, coupled with limited
recognition of the community self-governance provisions guaranteed by the constitution, led to
increasing resistance and mobilization of Adivasis. It culminated in the implementation of the
PESA Act in 1996. Further, growing discursive legitimacy of forest conservation objectives and
increased frustration with poor Government initiatives to stop forest degradation combined to
determine the next phase of transition in the Indian forest governance regime. A series of litigations
in India’s Supreme Court sought to check rampant, often illegal, and unsustainable commercial
exploitation of forests by various State and non-State stakeholders. In a series of orders, the
Supreme Court banned all kinds of forest encroachments. It stayed and even reversed the process
of regularization of forest dwellers’ rights. A court order to frame a time-bound action plan to evict
all forest encroachers became the pretext for the Government to carry out a large-scale eviction of
forest dwellers from the forests. The forcible evictions met with spontaneous and large-scale
protests and an organized social movement to recognize forest dwellers’ long-pending tenurial and
property rights, bringing the issue to the forefront of political agenda (Bijoy, 2008; Bose, 2010;
Kumar and Kerr, 2012). Mass resistance in Adivasi areas, an effective social movement campaign,
and a supportive newly-elected UPA government eventually culminated in the enactment of FRA
in 2006.
Overview of The Current Policy Framework
In the context of Hasdeo Aranya, the following policies and laws have emerged as the most
significant:
(i) Schedule 5 of the Constitution and PESA Act 1996 – the entire region being a majority Adivasi
habitation is deemed a Scheduled Area where the local communities can exercise self-governance
through their ‘gram sabhas’. The PESA Act 1996 has empowered gram sabhas with powers to
make local plans and manage resources, prevent alienation of land, and the right to be consulted
in all matters of land acquisition and mineral exploitation (Upadhyay, 2001; Dandekar and
Choudhury, 2010). Before enacting PESA in 1996, the State had absolutist eminent domain powers
to acquire land in ‘public interest’ without any consultation with the affected communities. This
provision was rampantly abused to ostensibly facilitate industrial and infrastructure development
with little consideration to the rights and interests of communities (Sampat, 2013). In several cases,
it also became a pretext for the accumulation of real estate for speculative gains (Levien, 2015).
While PESA Act empowered the Adivasi population in scheduled areas, subsequent laws like FRA
and The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and
Resettlement Act, 2013 (LARR 2013) extended the consultative process to other communities and
regions.
(ii) Forest Rights Act, 2006 – FRA provides for a bouquet of tenurial land rights including a)
community forest rights (CR) guaranteeing access to common property resources (section 3(1) (b)-
(f), (j)-(m)), b) a set of individual rights (IFR) that are exercised by participants in their individual
capacities (section 3(1)(a)), and c) community forest resource rights (CFR) that seek to legitimize
traditional forest governance practices and acknowledge the community leadership in protecting,
conserving, managing and regenerating forest resources (section 3(1)(i)) while giving them
exclusive ownership over all non-timber forest produce (section 3(1)(c)) (GOI, 2007). Recognizing
the vital issue of marginalization of forest dwellers’ rights due to forest diversion for various kinds
of mining and developmental projects, the FRA framework (outlined explicitly in an August 2009
circular from the Ministry of Environment and Forests (MoEF)) provides for free prior and
informed consent of local communities for such diversion (MoEF, 2009; MoTA, 2012). The
requirement of consent from all associated gram sabhas before any forest diversion (including for
mining) is undertaken was further reaffirmed in the famous Niyamgiri judgment of the Supreme
Court. Using the consent provisions, local communities thwarted bauxite mining plans of a large
conglomerate (Kumar, 2014; Borde, 2017).
(iii) Go/No-Go or Inviolate area policy – initiated in 2009 as a joint exercise between India’s
environment and coal ministries, this policy sought to ‘objectively demarcate’ India’s forests
across mining and conservation end-uses (PIB, 2009; Kumar, 2015). As per the initial criteria
formulated in 2010, the entire Hasdeo Aranya region was declared ‘no-go’ for mining owing to its
high forest density – the only coalfield declared entirely as ‘no-go’ among all the surveyed
coalfields. It is pertinent to note that such regions represented only 8.11% of India’s potential coal-
bearing area and 11.50% of its total explored coal-bearing areas (MoEF, 2011; Ramesh, 2015).
However, the policy was subsequently withdrawn in 2011 and revisited in the form of ‘inviolate’
areas that sought to include a more comprehensive set of environmental parameters to determine
those areas that needed to be conserved at all costs (Chakraborty and Sethi, 2015). While the new
policy remains work-in-progress and therefore not in-force, the latest drafts confirm that Hasdeo
Aranya has the maximum share of ‘inviolate blocks’, and 18 of the 20 identified coal blocks would
be deemed out of bounds for mining
5
.
5
Drafts of policy documents reviewed by the author through information obtained under RTI
(iv) various processes under the Environment and Forest Clearance processes, particularly the
‘public hearing’ provisions – prior to any diversion of land for mining projects, an elaborate
approval process is needed to ascertain and mitigate the environmental impacts. It involves
consultations with the local community in the form of a ‘public hearing’, a certification that the
forest rights have been recognized and settled, and various appraisal stages by expert bodies where
public stakeholders can share their comments (Chaturvedi et al., 2014).
With such an elaborate rights schema and constitutional and legal safeguards, it would prima facie
appear that ecologically important areas like Hasdeo Aranya would remain protected. Further, the
local communities have sufficient powers to articulate their opposition (if they so wish to) and
exercise their rights to thwart any displacement. However, the experience from implementation
and forest diversion processes across India belie such suppositions. Scholars have often lamented
the ‘pro-business’ nature of the Indian State (Kohli, 2009). It has meant that marginalized
communities have found it extremely difficult to assert their rights or participate in policy
processes that remain tied with business interests (Kohli and Menon, 2016b). This calls for a
critical assessment of the potential and prospects of harnessing policy spaces within the framework
of capitalist democracy.
Prospects of Utilizing Policy Spaces for Resisting Capitalist Expansion
It is imperative to note that these policy spaces have been created at specific conjunctures due to
coordinated civil society action, a supportive political opportunity structure, and democratic
imperatives faced by ruling governments in a constitutional democracy (Chakrabarti and Sanyal,
2017). For instance, a favorable political climate where the Adivasi vote was becoming
increasingly crucial for electoral success, its consolidation around issues of forest rights, and a
supportive political dispensation
6
is believed to have been critical for the enactment of FRA
(Kumar and Kerr, 2012). Similarly, the personal initiative and impetus of the then Environment
Minister Jairam Ramesh are credited with the formulation of the No-Go policy (Kumar, 2015;
Ramesh, 2015). Yet, an alignment of ruling elites with business interests has often thwarted the
potential of these policies to provide real redistribution of powers or effective rights to the hitherto
marginalized communities (Kohli and Menon, 2016b). Further, subsequent governments,
6
United Progressive Alliance (UPA) formed as an alliance of left-liberal Congress, other socialist parties and Left
political parties came to power in 2004. It is credited with enactment of a number of people-centric legislations like
the FRA, National Rural Employment Guarantee Act, Right to Education, LARR, among others.
especially the BJP-led government post-2014, seen as more business-friendly, have been less
supportive of such laws and policies. They have actively attempted to either dilute the key
provisions or circumvent them altogether (Sethi, 2015b; Aggarwal, 2019; Kohli, 2019). Even as
the path dependency of policy evolution ensures some resistance to any subsequent policy changes,
there are limits and constraints on the prospects of policy spaces reliant on parliamentary
democracy within the broader framework of a capitalist economy.
Even when the policy spaces do not get foreclosed by subsequent policy changes, the
implementation dynamics can thwart their radical potential. There remains a significant gap
between policy design and its implementation across several policy arenas in India. In an attempt
to explain the wide divergence between the policy framework and its implementation outcomes in
India, scholars have commented that India represents a ‘Cunning State’. It capitalizes on its
‘perceived weakness’ in State capacity to render itself unaccountable to select ideas and interest
groups even while notionally recognizing their concerns and interests within the policy framework
(Randeria, 2003b, 2003a). Therefore, despite a robust policy framework that accommodates the
rights of communities in design (or de jure), the implementation processes tend to subvert these
guaranteed rights, making them de facto inapplicable in several cases. For instance, multiple
studies have shown how ‘the experience of PESA has been tragically stilted’ and no real autonomy
or power has been devolved to the gram sabhas (Dandekar and Choudhury, 2010, p. 6). Further,
FRA’s most radical provisions have either not been implemented or implemented in only a few
regions (Chemmencheri, 2015; Broome, Rai and Tatpati, 2017; Kumar, Singh and Rao, 2017). The
consent provisions that require gram sabha approval before forest diversions are thwarted as
consent is ‘manufactured’ through the various power-laden bureaucratic processes such that ‘all
documents lead to consent’ (Choudhury and Aga, 2019). The inviolate policy, in any case, remains
inoperative, and clearances are customarily accorded in such areas despite official recognition of
their ecological importance (India Environment Portal, 2011; Chellam, 2016). Similarly, the
environment and forest clearances yield limited meaningful participation as public hearing
comments are willfully ignored and clearances accorded in most cases despite strong grounds to
the contrary (Kohli, 2015; Menon and Kohli, 2015).
Thus, despite offering policy spaces to resist capitalist expansion on the grounds of ensuring social
and environmental justice, there is little actual room for sustained and effective opposition. It is
crucial to remember that such policy spaces arise and get negotiated within the framework of a
capitalist state. To that extent, it is not a revolutionary space for confronting capitalism.
Consequently, the civil society space largely remains bereft of success stories. Even a decade after
the local Kondh community’s victory in protecting their forests from destruction by global
capitalist forces, the Niyamgiri example continues to get cited as the poster child of social
movement success in India. The Niyamgiri example, in many ways, remains an exception rather
than the norm. In this context of few success stories and constrained policy spaces available in a
capitalist State, it is remarkable to understand how communities of Hasdeo Aranya were able to
harness these constitutional and policy spaces to mount sustained resistance and achieve their
relative successes, howsoever provisional they may be.
The Movement Strategy and Trajectory
The movement was forged after the bitter experiences and frustrations from initial mine
operationalization processes for two coal mines – Chotia (owned initially by Prakash Industries
till 2015 and later by Balco – a Vedanta group company), and Parsa East Kete Basen (operated by
Adani on behalf of Rajasthan Rajya Utpadan Nigam Ltd). In fact, most villagers report having no
understanding of the constitutional and legal provisions. A Forest Advisory Committee (FAC)
7
report dated May 15, 2011, affirms the same by noting
Interaction with villagers, who are likely to be affected if the projects become
operational, revealed inadequate knowledge about the R&R [Relief and
Rehabilitation] policy/measures….the process for settlement of community rights,
in accordance with the provisions of the Scheduled Tribes and other Traditional
Forest Dwellers (Recognition of Forest Rights) Act, 2006, on the forest land
proposed for diversion have not been completed, so far. There is a lack of basic
awareness of such provisions in this very important Union legislation on the matter
of forest and community rights.
8
Consequently, the local communities could not have any say or organize much resistance for the
initial projects. Also, they remained largely unaware of whether their consent was needed and
7
This committee is responsible for advising the ministry on issue of forest clearances. It often submits reports based
on site inspections by a team or sub-committee.
8
Observations of the sub-committee of Forest Advisory Committee (National Green Tribunal, 2014)
reported not having participated in any gram sabha where they accorded their consent to the mining
project. Further, the experiences with resettlement and compensation remained poor. Over time, it
also became clear that the threat of displacement and living with adverse impacts of mining
projects was not just limited to these projects. As more mines continued to get allocated, it became
clear that the entire region was sitting over coal. All the villages of the region were implicated in
the struggle to save the forests. Realizing the need for a jointly organized resistance, all the region’s
villages – that span several tribal and non-tribal groups – covering a substantially large area came
together to organize themselves under a common banner. Thus, Hasdeo Aranya Bachao Sangharsh
Samiti (literally, a collective to resist and save the Hasdeo Aranya forests) was formed with the
aim of saving the region and their lifestyle from imminent devastation. A monthly meeting was
instituted to ensure effective coordination across this vast region, wherein representatives of all
the villages in the area regularly participate.
Sustained Capacity Building and Awareness Generation
It was clear that the biggest challenge was the community’s lack of awareness of their rights and
entitlements and their role in the various consultative processes that underpin India’s mining and
forest diversion processes. Further, decades of tenurial insecurity before FRA and the adverse
power relationships with the forest bureaucracy meant that the local community remained
underconfident and unwilling to articulate or assert their rights even when they became aware. As
Umeshwar Singh Armo, convenor of HABSS and an elected peoples’ representative
9
from the
region, highlighted
Before the early 2000s [before the enactment of FRA], we were just users of forest
produce whose access and use of forest resources was carefully regulated by the
forest department. We could not bring back too much forest produce to our homes
without the fear of being beaten and fined. After FRA, even though our legal
position changed, it is difficult to convince people to shed their fear and
insecurities. From user to an owner is a big cultural shift that requires a change
in mindset. (Interview notes – emphasis added)
9
Block Development Council representative elected by a group of approximately 20 villages
The problem required HABSS to approach various NGOs for technical inputs and capacity-
building support. This, however, brought with it the risk of a shift in power from the community
to these NGOs. To ensure that the movement remained disciplined and community-driven and did
not deviate from its core aims, the HABSS adopted a five-point principle — community issue,
community decision, community struggle, community resources, and community leadership.
Simply speaking, the community is responsible for identifying the problem, making decisions, and
raising resources to support and lead the movement. However, the extent to which they’ve been
able to imbibe these principles in their movement strategy is crucially predicated on the
community’s abilities and access to the critical sources of power in their chosen terrain of conflict.
For instance, a reliance on the written documents as the mode of protest (letters, petitions, and
written submissions) is bound to tilt the powers in favor of the more ‘lettered’
10
among the
community. Similarly, an intervention in the environmental clearance processes requires a detailed
understanding of environmental processes, impacts, and technical language that is often only
accessible to local communities through focused environmental groups and NGOs. Thus, the
movement principles are bound to get tested over time as the members encounter newer forms of
information and power asymmetry in their encounters with the mining companies and the State.
With the help of Janabhivyakti (NGO working in north Chhattisgarh on FRA implementation and
environmental justice issues), and several invited experts on FRA, PESA, Environmental Justice,
Local Governance, HABSS conducted many training and workshops on the various constitutional
and legal provisions. Some of the key legal provisions were converted to easily accessible and
catchy slogans painted across the houses to reinforce the messages and serve as a constant reminder
to the local population. These include slogans like ‘Vanon ke maalik hum, hum se van, van se hum’
(we are the owners of the forest, the existence of forest is dependent on us, and we exist because
of the forest) and ‘Na Lok Sabha na Vidhaan Sabha, Sabse Oonchi Gram Sabha’ (Neither state
assembly nor national parliament, most important is the local gram sabha). Such slogans have been
derived from interpreting PESA and FRA provisions, specifically Section 3(1)(i). Further, various
signboards were also put up at several places that indicated that the village was a Schedule 5 area
where gram sabha had powers to settle all issues under PESA provisions. Partly, these measures
also helped the community gradually alter their power relationships with the forest bureaucracy.
10
I use ‘lettered’ instead of learned or educated to indicate the privileging of the homogenized forms of knowledge
and the language of the State, as opposed to the traditional forms of knowledge and articulation.
As Bajrang, a community leader from Gidhmudi village commented, ‘now forest officials treat us
with respect, they even come to our gram sabhas for informing us of regular forest management
activities’ (Interview notes).
Figure 3: Community awareness and training by Janabhivyakti (NGO)
Source: Photograph by Alok Shukla, Chhattisgarh Bachao Andolan
Overcoming the Tyranny of Distance by Using Formal Authority of ‘Local Governance’
Structures
The training and awareness campaigns helped the community better understand and articulate their
local interests and alter local power asymmetries. However, the resistance to mining required
effective articulation at a larger scale – district, state, and national levels in addition to the local
level. There remained two critical challenges – (i) the tyranny of distance where the mere
remoteness of the region from seats of power and influence (the state and national capital) meant
that it was difficult to attract and sustain media or policymakers’ attention to any local protests,
and (ii) the challenges and high costs of organizing any large-scale mass protests in Raipur or
Delhi for sustained periods, especially given the relatively lower population density. It was likely
that the local protest sites would be completely ignored while the protests in centres of power
would get lost in the din of urban city-centric issues.
A formal ‘gram sabha’
11
resolution became the primary tool for articulation, which partially
overcame these challenges and complemented the more conventional forms of protest. Vested with
PESA powers, the gram sabhas have a legitimate and legally recognized role in articulating
community opinions, decisions, and prevention of land and resource alienation. Thus, a gram sabha
resolution can be seen as a decision of one government level (local) vis-à-vis the other levels of
government (centre and state levels). Also, a formal resolution from gram sabhas is believed to
have constitutional standing, especially after the Niyamgiri judgment recognized the primacy of
gram sabhas in forest diversion decisions. Further, by its very nature, a formal gram sabha
resolution represents the will of a ‘majority’ of local residents, thereby bridging the crisis of
legitimacy that most social movements face as their various protests get questioned on the grounds
of being determined by a small, motivated group of individuals. Thus, a gram sabha resolution’s
legal sanctity can serve to elicit formal State and policymakers’ response, bridging the tyranny of
distance and breaking through the clutter of informal urban-centric protests.
11
The gram sabha comprises of all elected voters of the village, and a formal resolution can only be passed by a
majority of all members present and voting. Further there are quorum requirements (33% of total voters of the village)
for passing such resolutions, although in the case of Hasdeo Aranya, gram sabha meetings are attended by over 50-
60% of the members. Therefore, a gram sabha resolution can be seen as a formal, legitimate, and a representative
articulation of the village. In the case of opposition to mining projects or assertion of rights under FRA, such
resolutions were passed by consensus.
Figure 4: Gram Sabha
Source: Author
The use of gram sabha as the primary mode of articulation of community issues also ensured a
broad community-wide participation in the resistance struggle, including cross-sections. There was
adequate space for women’s leadership in the movement, and often, the gram sabhas were chaired
by women leaders, including several elected womens’ representatives. The youth, more well-
versed with the language of official government correspondence, were at the forefront of drafting
the community’s resolutions and engaging with the formal processes. HABSS regularly ensured
that all associated gram sabhas periodically (often every 3-6 months) passed formal resolutions
(with compliance of all due processes) opposing mining in their region. Further, most village-level
meetings started being called gram sabha meetings – some backed by formal processes and some
informal. When a joint meeting is organized involving more than one village, it is often termed a
‘mahagramsabha’ (meeting of gram sabhas) rather than a simple community event. For instance,
when HABSS invited the Minister for Tribal Affairs of the state government in February 2019, the
event was termed ‘gramsabhaon ka mahasammelan [a conference of gram sabhas]’. These gram
sabha resolutions became the focal point of their advocacy strategy in their various letters and
petitions to the various ministries and statements to media (Gupta and Roy-Chowdhury, 2017). It
does not mean that HABSS shelved the regular protests like dharnas, strikes, protest marches, sit-
downs at district and state headquarters, etc. These protest tactics were typically complemented
with gram sabha resolutions. The banners and posters at their protest sites referred to these duly
passed gram sabha resolutions, citing the legally vested powers under PESA and FRA.
‘Proactive’ Rather Than ‘Reactive’ Engagement with the Policy Processes
One of the key challenges of relying on gram sabha’s rights and powers is the late stage in the
forest diversion process at which such community consultations are formally required to be
conducted, and consent from gram sabha is sought. Instead of a meaningful exercise of rights to
‘free, prior and informed consent’ that would require community involvement from the early
stages of project conceptualization, the process of gram sabha consultations seems to almost
appear as an after-thought to the forest-diversion decision, a mere compliance requirement
(Choudhury and Aga, 2019). It can take up to 3-7 years before the community is first consulted
after the decision to allocate a coal block has been taken, and the pre-mining processes are started
(IDFC, 2010). Even a committee constituted by the central government admitted that community
consultations are treated merely as a compensation and rehabilitation problem rather than a process
of ascertaining the community’s opinions (MoTA, 2014, pp. 258–298). However, even when
seeking the consent and NOC for mining operations, there is no discussion on the actual
compensation and rehabilitation package; this is announced later at the time of land acquisition
based on a pre-determined policy. As such, there is no genuine consultation envisaged under the
current policy processes.
While the environment clearance process also provides for community consultations in the form
of a public hearing, it gets treated as a one-off event. The entire process is ridden with a significant
conflict of interest favoring project proponents like mining companies. The Environment Impact
Assessment (EIA) Report, which forms the basis of such community consultations, is prepared by
a consultant hired by the project proponent (Menon and Kohli, 2007). The public hearing process,
including the preparation of minutes, is often led by the project proponent itself, even though the
government is responsible for the conduct of such hearings (Kohli, 2014). Further, the project
proponent is not legally bound to address the issues raised therein (Lahiri-Dutt, Balakrishnan and
Ahmad, 2012). The experience with governments’ role in public hearings has also been
disappointing as they are often marred by intimidation, violence, and procedural irregularities
(Kohli, 2015; Menon and Kohli, 2015). Moreover, there have been instances of the MoEF grant
of clearance despite justifiably adverse public hearings and EIAs, such as the Parsa mining project
in Hasdeo Aranya (Menon and Kohli, 2007; Kohli, 2014).
HABSS has attempted to follow a ‘proactive’ approach to engaging with the policy processes to
partially address the challenge. Instead of waiting for their turn to answer the question of consent
when formally asked by the project proponents (and the higher levels of government), HABSS has
tried to intervene at the early stages of the decisions to allocate/auction a coal block. This proactive
engagement is sustained at every stage of the subsequent policy processes – for instance, every
step of the environment and forest clearance processes - through letters, petitions, representations,
and meetings. This strategy allows for a more prolonged engagement with formal policy spaces,
thereby offering greater temporal space for articulating the resistance. It also keeps the local
communities meaningfully engaged, collectivized, and committed to the movement principles of
following constitutionally mandated democratic spaces.
In one of their key campaigns in the winter of 2014-15, twenty gram sabhas of Hasdeo Aranya
tried to influence the allocation of coal blocks itself by taking their resolutions against mining to
the concerned ministries (coal, environment, tribal affairs, and the prime minister). They argued
that since they were unlikely to give their consent as required to start mining operations, the central
government should not go ahead with allocation itself (Chhattisgarh Bachao Andolan, 2015;
Choudhury, 2015). In many ways, this was a unique framing of the situation wherein the local-
level government vested with its powers under PESA, and FRA tried to influence the allocation
process, which is the exclusive domain of the central government (Gupta and Roy-Chowdhury,
2017). The elected and formally recognized leaders (sarpanchs) played a lead role in representing
the gram sabhas in communicating with the other government functionaries. This campaign was
repeated at every subsequent allocation of a new coal block in the region, most recently in June
2020 (Alam, 2020; Mishra, 2020b). While the government has disregarded these gram sabha
resolutions and went ahead with allocating blocks, this strategy has allowed HABSS to capitalize
on other political spaces – media, political leaders, and government officials. The allocation (or
auction) of coal blocks is usually done with much fanfare – launched by the PM himself or the
senior-most minister on most occasions. Therefore, a proactive strategy to engage at the very
instance when the public attention is high has allowed HABSS to access and exploit media and
policy spaces that open up around such events (Aggarwal, 2015; Sethi, 2015a; Wal, 2015).
Figure 5: Meeting of HABSS
Source: Author
Careful Framing that Amalgamates Environmental and Social Dimensions
The Hasdeo Aranya region offers possibilities of resistance on both environmental and social
grounds, given the region’s particular facts. However, too often, movements tend to emphasize
only one of these dimensions, thereby foregoing possibilities of engagement across the entire
policy spectrum. The social movement literature is also replete with examples of tensions and
conflicts between the social and environmental movements, popularly referred to as ‘blue-green
conflicts’ (Satheesh, 2020). The schism between environmental and social dimensions of a
resource conflict becomes particularly stark in the context of India’s forest governance. The forest
bureaucracy sees local communities as a challenge to forest conservation efforts, thereby adopting
a hostile approach to the issue of rights of forest-dwellers (Singh, 2021).
In the case of Hasdeo Aranya, there was the added challenge of overcoming the community’s
hostility and fear of wildlife in the wake of rising human-elephant conflict (Gopalakrishnan and
Selvaraj, 2017; WTI, 2017). Due to the extensive crop losses, house damages, and even loss of life
from elephant conflicts every year, it is not easy to sustain the communities’ narrative of a quest
for both environmental and social justice. However, faced with the more significant threat of
displacement and disruption to their way of life, HABSS amalgamated environmental and social
dimensions into their movement strategy.
The master frame for HABSS emerged from the community’s own socio-historical experiences –
the communities’ peaceful and harmonious co-existence with nature since ancient periods. To the
forest dwellers of Hasdeo Aranya, the forest was a way of life. There was no visualization of an
alternate lifestyle that did not involve co-partaking from nature’s bounty along with other species.
The movement for FRA by the umbrella coalition of forest-based movements in the early 2000s
and FRA’s enactment had already provided recognition and legitimacy to this frame (Kumar and
Kerr, 2012). The powers granted to Gram Sabha to ‘protect, conserve, and manage forests and
resources’ in their CFR areas and legal recognition of their historical role in this function further
provided a useful frame to articulate the community’s interests (MoTA, 2012; Kumar, Singh and
Kerr., 2015). The roots of the growing human-wildlife conflict were traced to the pressure faced
by large mammals due to disruption of their habitat by the expansion of mining and industrial
activities in nearby areas (Fernandes, 2012; Sivalingam, 2014). This issue was also carefully
documented and analyzed in a report by Greenpeace that claimed that the real ‘Elephant in the
Room’ was the threat of coal mining (Sivalingam, 2014). The Hasdeo Aranya area’s notification
as a ‘no-go’ area based on the governments’ internal bureaucratic exercise further provided
grounds for HABSS to exploit the political space offered by the region’s vital environmental and
ecological parameters.
Figure 6: Community Protest March
Source: Alok Shukla, Chhattisgarh Bachao Andolan
This framing allowed HABSS to ensure a credible and consistent intervention across all policy
arenas – FRA implementation processes, gram sabha consent processes, as well as environmental
and forest clearance processes. Thus, all letters, petitions, and even gram sabha resolutions
included a consistent message which included (i) the role and powers as per constitutional and
legal provisions, (ii) the ecological importance of the region, including it being deemed a ‘no-go’
or ‘inviolate’ areas, (iii) and the historical relationship of the community with forests that make it
essential for the communities to protect forests at all costs to conserve their life, livelihood, and
identity.
Leveraging Broader Civil Society Network While Retaining Community’s Identity
It was evident that despite strategies that sought to leverage the available policy spaces, Hasdeo
Aranya is still a localized movement representing a relatively small and remotely located
population. Thus, it could not expect to capture attention on a stand-alone basis without building
solidarities and alliances with other civil society actors. The importance of national and
transnational advocacy networks in extending influence spheres of influence with decision-makers
had already been outlined by the Niyamgiri movement’s case (Macdonald, Marshall and Balaton-
Chrimes, 2017). However, the Niyamgiri case had also presented insights into the challenges of
navigating the heterogeneity of interests of different actors in these networks and highlighted the
need for caution by local movements in such interactions (Kraemer, Whiteman and Banerjee,
2013). Thus, the importance of close alignment of interests and the need for deeper relationships
with the associated advocacy networks remained crucial for HABSS.
At the outset, HABSS joined the Chhattisgarh Bachao Andolan (Save Chhattisgarh Movement,
hereafter called CBA), a state-level alliance of peoples’ movements working on similar issues
across various parts of Chhattisgarh (Gupta and Roy-Chowdhury, 2017). Being a relatively small
and closely aligned group of movements enabled HABSS to retain its core identity and interests
even with the presence of an alliance. Due to the geographical proximity, the members of
individual movements associated with CBA could also actively participate in each other’s
resistance sites and forge effective solidarities and relationships. At the same time, being a state-
level civil society platform, CBA offered access to the regional and state-level policy circles and
networks. It also allowed HABSS to pool resources and technical and legal expertise from other
member groups and their leaders.
To traverse policy scales, HABSS, however, needed to extend its presence to the national level.
Again, CBA could channel its collective strength and legitimacy to gain access to the NGOs, media
personnel, and national-level advocacy coalitions. These often helped amplify local community
voices to the national-level policy scale. HABSS also joined newer civil society alliance networks
like the Bhoomi Adhikar Andolan to raise broader land alienation issues. However, the challenge
before HABSS remained its limited ability to influence larger national networks given the tyranny
of distance that we discussed earlier. Therefore, HABSS relied on its tactical strength of leveraging
‘gram sabha’ resolutions to retain distinct community articulation of its core interests even while
participating in the broader alliances and networks.
A Critical Appraisal of The Movements’ Achievements
The high point for HABSS came in September 2020, when five coal blocks were eventually
withdrawn from the list of mines put up for auctions (Trivedi, 2020). The decision was taken after
a sustained campaign surrounding the first-ever commercial coal block auctions announced by the
Prime Minister in June 2020 (PTI, 2020). Based on gram sabha resolutions (Mishra, 2020b), all
the region’s elected sarpanchs had written a letter to the Prime Minister and other associated
ministries expressing their continued opposition to mining in the region (Alam, 2020; Kaiser,
2020). Directly attacking the Prime Minister’s speech on the need for auctioning coal blocks in the
quest for ‘Atmnirbhar Bharat (self-sufficient India), the sarpanchs had argued that these auctions
ran contrary to the ‘atmnirbharta’ of these villages. In their letter subsequently released to the
media, they mentioned
On the one hand, you speak of atmnirbharta; on the other, you talk of destroying
the livelihood, lifestyle, and culture of Adivasis and forest-dwelling communities
through this auction…. In the region, the gram sabhas have already built a model
of ‘atmnirbhar’ local self-governance under the provisions of PESA and FRA.
(letter by sarpanchs to the PM dated June 18, 2020)
The local resistance found resonance and support from several quarters and was widely covered
across the media outlets. The local resistance to coal in Hasdeo Aranya also became the focal point
of a global debate on issues of India’s tryst with decarbonization and climate change, as reported
by CNN and the Guardian (Ellis-Petersen, 2020; Gupta and Regan, 2020).
Remarkably, the issue of ‘no-go’ areas also took centre stage as several political leaders and the
state-level governments intervened to protect high-conservation zones from the list of mines to be
auctioned in the current list (Jamwal, 2020; The Wire, 2020). The most crucial intervention came
from the state government of Chhattisgarh, which is run by the Congress party that is politically
opposed to the BJP-led government at the centre. The Chhattisgarh state forest minister referred
to the state government’s intentions to create an elephant reserve project (called Lemru) in the
region (Mishra, 2019, 2020a) and requested his counter-part in the central government to withdraw
coal blocks from auctions. He wrote
the jungles around the coal blocks have been reserved for the Lemru elephant
reserve… It will not be right to ever create coal blocks in these areas, with regards
to environmental safety. So, kindly remove the coal blocks falling in Hasdeo Aranya
and the catchment areas of Mand river should be removed from the current and
any future list of available coal blocks. (Verma, 2020)
The support from the state government and political elites can be seen as an outcome of the series
of advocacy campaigns over the years and meetings with political leaders across the political
spectrum. These included visits by some of the senior-most leaders of the Congress Party,
including its Vice President Rahul Gandhi (Das, 2015). This was followed by multiple rounds of
meetings and discussions with the state’s current Chief Minister, including when he was in
opposition
12
.
The removal of Hasdeo Aranya blocks from the auctions list appears to mark the culmination of
the decade-long protests by HABSS to gain policy attention for their issues. It also represents a
remarkable success story amidst the chequered history of civil society struggles in India. However,
by no means does it mark the end of the community’s struggle, as became evident within months
of this success.
A Cautionary Note
In January 2021, the central government announced its intention to acquire land for the Madanpur
South coal block, which lay adjacent to and sandwiched between the five coal blocks that had just
been withdrawn from the auction list (Das, 2021). Like six other coal blocks of the region, this
block had already been allocated between 2015-2020. However, clearance processes had not been
undertaken thus far owing to stern community resistance. It is important to note that these blocks
had been allocated to various mining companies despite prior opposition and repeated gram sabha
resolutions from the associated gram sabhas (Aggarwal, 2015; Wal, 2015). The fact that the
government was also willing to ignore its classification as a ‘no-go’ or ‘inviolate’ area while
allocating these blocks points to the inherent limits offered by the policy spaces for a resistance
movement’s success.
Even though these new mining projects would continue to require consent from the local gram
sabhas, the communities remain worried about the forcible processes that could be followed to
obtain, or as Choudhury and Aga (2019) articulate, ‘manufacture’ this consent. The Parsa coal
block experience in Hasdeo Aranya documents communities’ bitter experience navigating formal
consent processes (MS, 2020). The very design of the process of community consultations is
12
Between 2014-2019, both the centre (national-level) and the state (provincial) governments were ruled by BJP.
Motivated by the strong resistance from HABSS, the opposition Congress party periodically used the issues of
conservation of Hasdeo Aranya region, protection of rights of communities under PESA and FRA, and the need for
elephant reserve. In 2019, the Congress came into power in the state with the promise of Lemru Elephant reserve in
their manifesto. However, since coming to power, the Congress-led state government has adopted an ambivalent
stance to the issue – sometimes supporting the local resistance and creation of elephant reserve, at other times
continuing to expand mining clearance processes in the same areas.
loaded against the communities wherein the consent can be sought any number of times. However,
the community has to consent only once to have an irretrievable decision. If the community does
not provide consent, it can be asked repeatedly until it relents. Further, the gram sabha is not
empowered to invalidate such consent with a subsequent resolution. Jainandan Singh Porte of
Ghatbarra village, a community leader, affected by the Parsa project, explains the inherent injustice
in the system,
We have been opposing mining through several gram sabha resolutions, but the
government didn’t listen… then in 2017, the government conducted 4-5 gram sabha
meetings over a span of 6 months to pressurize us to give consent… however, when
even that failed, it forged the consent and took NOC to process the clearance. We
have subsequently passed a fresh resolution opposing mining, but that is held as
invalid. (Interview notes)
HABSS also needs to worry about the long and arduous legal processes if a project manages to get
clearance despite any irregularities or even blatant violations of the legal procedures. For instance,
the forest clearance for Parsa East Kete Basen (operational) mining project was invalidated on
multiple grounds by the National Green Tribunal (National Green Tribunal, 2014). Yet, the mine
continues to remain operational and continues to seek expansion as the case remains pending in
the Supreme Court (Nandi, 2021). Further, the villagers of Ghatbarra also continue to struggle in
courts to regain their community forest rights after their CFR title was invalidated by
administrative fiat in what remains the only such exercise across the country (Kohli, 2016; Sethi,
2016). It is important to note that success in the legal arena requires an altogether different set of
capabilities than in the social and political arenas. Local indigenous communities are often ill-
equipped to navigate the legal challenges.
While the example of HABSS represents a moment of success in India’s experience of social
movements, it also throws up the challenges and limitations of following such a strategy. Despite
remarkable achievements in capturing popular imagination and gaining the policymakers’
attention, there is a limited guarantee that the movements’ core aims will be met in the long run.
Even as the HABSS carefully navigated and exploited the constitutional and policy spaces, their
case also throws up newer questions on the scope of these spaces to offer meaningful
environmental and social justice.
Even the ability to explore and raise these newer legal and constitutional questions, which remain
pending before the courts and the policy-making bodies, can partly be seen as a success of the
essentially local social movement (Gupta and Roy-Chowdhury, 2017; Choudhury and Aga, 2019;
Kohli, 2019). In essence, HABSS has managed to expose and highlight the inherent asymmetric
design of policy processes and contemporary policy dilemmas– auction before consent and
clearance, asymmetric design of consent provisions, limits of powers under CFR and FRA
recognition processes. Thus, HABSS’s movement strategy can be seen to have been successful in
traversing the scales of policy design and policy implementation.
Lessons For Future
Scholars have elaborately commented on the inadequacies of the institutional and policy spaces
for organized resistance in India – inadequate devolution of powers under PESA (Dandekar and
Choudhury, 2010), the abysmal implementation, and disregard to the substantive provisions of
FRA (CFR-LA, 2016; Kumar, Singh and Rao, 2017), the inadequate consultation and ‘free, prior,
informed, consent’ framework for local-level consultations regarding displacement projects
(Choudhury and Aga, 2019), and an ineffective environmental clearance framework (Menon and
Kohli, 2015). Despite these shortcomings, the success of HABSS in harnessing these spaces, as
available in any constitutional democracy, can serve as a model for organized resistance to the
capitalistic expansion project.
HABSS’s methods represent a valuable experiment in utilizing the ‘gram sabha’ not only for local
self-governance – as envisaged in policy – but also as a valuable tool to articulate the community
views and negotiate with the central and state tiers of government. The successful framing of the
issue as a conflict between the local government, i.e., the gram sabhas pitted against the collective
might of the powerful central and state-level government tiers, managed to capture policy attention
and expose the fault-lines in the decentralization and democratic framework of the constitution.
Interestingly, the movement primarily targeted policy spaces where State is the dominant actor
and consequently the primary target for the resistance struggle. While HABSS mentioned the
corporates in most of the letters, petitions, and documents, they remained in the background of the
formal conflict. The policy processes seek to negotiate clearances and consent for a project,
ostensibly as an independent arbiter between the communities and the project proponents or the
corporates. However, the State-corporate nexus, wherein the corporate interests get reflected in the
formal policy positions adopted by the central and state governments, thereby assigning a
semblance of legitimacy to the corporate interests. Thus, the corporates often recede to the
background as the State is often at the centre-stage of the conflict (Kohli, 2009; Kohli and Menon,
2016a). In this context, the HABSS’s strategy of pitting one level of government (local) against
the other levels (centre and state) could help expose this State-corporate nexus and bridge the
legitimacy gap typically faced by social movements across the country.
The movement’s ability to resist any expansion of mining operations over the last nine years in the
face of some of the most powerful corporate groups of the country remains laudable and a
testament to the collective resolve of the local communities. Yet, in the wake of an ever-expanding
capitalist project, any momentary success remains provisional and vulnerable to reversals. There
are limits to such strategies of using ‘gram sabha’ as the focal point for a social movement amid
the asymmetric distribution of real powers between different tiers of government. Further, a
movements’ strategies and variegated responses remain embedded within the broader structures
of power in the society that operate differently in each context and even in the same context over
different points of time. It is neither guaranteed that HABSS would be able to achieve its objectives
over the long run nor that another movement could expect to achieve similar results with such
strategies.
One must also recognize the inherent pitfalls of using the strategies adopted by HABSS. As
multiple scholars have warned, as ‘the rule of law’ became the central focus of the movement, the
communities were forced to enter into ‘political and legal negotiations already constituted as
certain kinds of legal subjects, which constrains their imagination in certain ways’ (Sundar, 2011,
p. 419). The very choice of focusing on institutional and policy spaces offered by a constitutional
democracy forces the communities to adapt and respond to the knowledge systems privileged by
the State and subject themselves to the asymmetric power balances represented therein. In the long
run, such strategies reliant on legal rights and constitutional guarantees run the risk of falling into
the trap of becoming unwilling participants in newer modes of ‘neo-liberal governance’. By
disembedding the tribal society from their intimate connection with nature, rights-based legislation
like PESA and FRA, and the knowledge systems that produce and manage these laws, force such
communities to encounter and respond to the modernity and capitalist expansion project on
inherently unfamiliar terms (Bhattacharya, Bhattacharya and Gill, 2017). Addressing this
challenge would require conceptualization of radical spaces and alternate development models
across levels of governance – national, regional, and local. Even as such alternatives are emerging
in select regions across the country, they remain marginalized in the broader public discourse
(Kothari and Joy, 2017). In the absence of a such radical spaces, the formal policy spaces
embedded within the current constitutional framework of a capitalist democracy would remain a
significant challenge to the long-term success of any movement like HABSS. Regardless of the
current achievements, or the potential and prospects of the strategies adopted by the HABSS, the
movement needs to be celebrated for its remarkable resilience in the face of adverse power
structures. The forest-dwelling communities of Hasdeo Aranya have shown how even a remote,
peace-loving, and powerless populace can wage an effective ‘war’ (Ellis-Petersen, 2020) against
the powerful elites and the State in their quest to protect and conserve their union with nature. The
movement by Hasdeo Aranya captures the indomitable spirit and the age-old Adivasi traditions
and their struggle for rights and dignity as captured by this poem by the late Adivasi rights activist
Abhay Xaxa:
Among the doom and gloom they smile,
Mistaken for idiots by the mad rational world.
The Adivasis, beautifully damaged people!
On the treasures of iron, gold and diamond they sit,
Poor and powerless, holding the curse of nature.
The curse of loving their land, water, forest,
where they prefer to die as mad lover
beautifully damaged people!
With stars in their eyes, n moon in their minds,
Thoughts flowing like an undammed river
with hearts unadulterated with twisted philosophies,
Religions, ideologies, lust and greed.
Their vision misunderstood as juvenility,
On the face of violence, loot and hopelessness they remain,
Dreamy, defiant and deviant,
Beautifully damaged people!
(excerpts from the poem titled ‘Beautiful Damaged People’ by Abhay Xaxa (Xaxa, 2017))
Acknowledgement
The author would like to express gratitude towards the HABSS members for their active support,
and open discussions that led to this chapter. They warmly welcomed me and openly shared their
stories – both old and new, of misery and joy, of losses and gains, of freedom and tradition. They
also taught me how to find joy and hope amidst the most trying circumstances. I am grateful to
Alok Shukla, convenor of Chhattisgarh Bachao Andolan for his sharp insights and feedback on
the contents of this chapter. I would also like to thank Prof. Rohit Varman, Prof. Devi Vijay and
the reviewers for their insightful comments and detailed feedback on earlier drafts of the
manuscript.
Postscript
Over the last few months, notification for land acquisition has been issued for four new coal blocks
in Hasdeo Aranya – Parsa, Kete Extension, Gidhmudi Paturia, and Madanpur South. In each of
these cases, no prior gram sabha consent has been taken. The government has held that land
acquisition under an earlier Act called Coal Bearing Areas Acquisition and Development Act,
1957 does not attract PESA and FRA consent provisions. Further, the initial forest clearance
(Stage-1) for the Parsa coal block was processed based on what the communities have alleged is a
fake No Objection Certificate (NOC) based on forged gram sabha resolution. Further, the proposed
boundaries of Lemru Elephant reserve were amended to 450 sq km in June 2021 from the initial
3,827 sq km for which gram sabhas had been consulted only nine months ago in October 2020. To
resist these developments, hundreds of villagers from the region marched on foot (Hasdeo Bachao
Padyatra or the Save Hasdeo Foot-Rally) from Surguja to Raipur – 330 km journey over ten days
between October 4 to October 13. This delegation met the Chief Minister and Governor, who
assured them of looking into their demands and ordering an enquiry into the allegations of forged
gram sabha resolutions. The event and protest also received widespread coverage in regional and
national media.
The resistance of Hasdeo Aranya communities received partial success again as the Lemru
Elephant reserve boundaries were again amended to a 1995 sq km area to include parts of the
region while still excluding a large number of coal blocks. Further, in his meeting with the
communities on October 14, 2014, the Chief Minister of Chhattisgarh assured of his intention to
protect Gidhmudi Paturia and Madanpur South coal blocks by including them in the elephant
reserve project. At the same time, on October 21, 2014, the final forest clearance (Stage-2) for the
Parsa coal block was processed within a week of this meeting despite the clear assurance from the
Chief Minister and Governor for an investigation into the allegations of forged gram sabha consent.
These developments and the partial and provisional successes achieved further serve to highlight
the prospects and challenges of relying on constitutional and policy spaces for organized resistance
to capitalist expansion.
References
Aggarwal, M. (2015) ‘20 gram sabhas in Chhattisgarh pass resolutions against auction of coal
mines’, Livemint, 15 January. Available at:
http://www.livemint.com/Politics/9ReivDrAjzdvv7d6Hw8NGL/20-gram-sabhas-in-
Chhattisgarh-pass-resolutions-against-auct.html.
Aggarwal, M. (2019) ‘With forest rights in focus ahead of elections, proposed changes to Forest
Act draw attention’, Mongabay, 27 March. Available at:
https://india.mongabay.com/2019/03/with-forest-rights-in-focus-ahead-of-elections-proposed-
changes-to-forest-act-draw-attention/.
Agrawal, A., Chhatre, A. and Hardin, R. (2008) ‘Changing Governance of the World’s Forests’,
Science, 320, pp. 1460–1462.
Alam, M. (2020) ‘Chhattisgarh: 9 Sarpanchs Write to PM to Stop Mining Auction at Hasdeo
Arand’, The Wire, 16 June. Available at: https://thewire.in/rights/chhattisgarh-sarpanchs-modi-
hasdeo-arand-atmanirbhar.
Bhattacharya, R., Bhattacharya, S. and Gill, K. (2017) ‘The Adivasi Land Question in the
Neoliberal Era’, in D’Costa, A. P. and Chakraborty, A. (eds) The Land Question in India: State,
Dispossession, and Capitalist Transition. Oxford: Oxford University Press, pp. 177–198.
Bijoy, C. R. (2008) ‘Forest Rights Struggle The Adivasis Now Await a Settlement’, American
Behavioral Scientist, 51(12), pp. 1755–1773.
Borde, R. (2017) ‘Differential Subalterns in the Niyamgiri Movement in India’, International
Journal of Postcolonial Studies, 19(4), pp. 566–582.
Bose, I. (2010) ‘How did the Indian forest rights Act, 2006, emerge’, Institutions for Pro-Poor
Growth Discussion Papers, 39.
Bose, P. (2012) Forest rights: the micro-politics of decentralisation and forest tenure reform in
tribal India. Wageningen University.
Broome, N. P., Rai, N. D. and Tatpati, M. (2017) ‘Biodiversity Conservation and Forest Rights
Act’, Economic and Political Weekly, 52(25 & 26), pp. 51–54.
Census (2011) Houselisting and Housing Census Data - 2011, Census of India. Available at:
http://www.censusindia.gov.in/2011census/hlo/HLO_Tables.html (Accessed: 27 July 2016).
CFR-LA (2016) Promise and Performance: 10 Years of Forest Rights Act in India. India:
Community Forest Rights–Learning and Advocacy Process.
Chakrabarti, R. and Sanyal, K. (2017) Shaping Policy in India: Alliance, Advocacy, Activism. New
Delhi: Oxford University Press.
Chakraborty, S. and Sethi, N. (2015) ‘Final number of inviolate coal blocks down from 206 to less
than 35’, Business Standard, 2 September. Available at: http://www.business-
standard.com/article/economy-policy/final-number-of-inviolate-coal-blocks-down-from-206-to-
less-than-35-115090200004_1.html.
Chaturvedi, V. et al. (2014) State of Environmental Clearances in India: Procedures, Timelines
and Delays across Sectors and States. New Delhi: Council on Energy, Environment and Water.
Chellam, R. (2016) Violating the inviolate forests, Greenpeace. Available at:
http://www.greenpeace.org/india/en/Blog/Campaign_blogs/the-green-blindfold-over-our-
forest/blog/55949/.
Chemmencheri, S. R. (2015) ‘State, social policy and subaltern citizens in adivasi India’,
Citizenship Studies, 19(3–4), pp. 436–449.
Chhattisgarh Bachao Andolan (2015) Press Release: Twenty Gram Sabhas (Village Assemblies)
pass resolutions, urge Government to safeguard of constitutional rights and restrict coal mining.
Choudhury, C. (2015) ‘Not Just A Coal Block’, People’s Archive of Rural India, 2 January.
Available at: https://ruralindiaonline.org/articles/not-just-a-coal-block-hasdeo-arand/.
Choudhury, C. and Aga, A. (2019) ‘Manufacturing consent: Mining, bureaucratic sabotage and
the Forest Rights Act in India’, Capitalism Nature Socialism, pp. 1–21.
Dandekar, A. and Choudhury, C. (2010) PESA, Left-Wing extremism and governance: Concerns
and challenges in India’s tribal districts, Report of a study commissioned by Ministry of
Panchayati Raj, Government of India. Anand.
Das, A. (2021) ‘Is Centre Violating Peoples’ Rights for Acquiring Coal-Bearing Land in
Chhattisgarh?’, Newsclick, 8 January. Available at: https://www.newsclick.in/is-centre-violating-
peoples-rights-acquiring-coal-bearing-land-chhattisgarh%3F.
Das, R. K. (2015) ‘Chhattisgarh coal mines protest gets Rahul Gandhi’s stamp’, Business
Standard, 15 June. Available at: https://www.business-standard.com/article/politics/chhattisgarh-
coal-mines-protest-gets-rahul-gandhi-s-stamp-115061500885_1.html.
Dasgupta, A. (2020) ‘Adani and the Elephants of the Hasdeo Aranya Forest’, Newsclick, 26 June.
Available at: https://www.newsclick.in/Adani-Elephants-Hasdeo-Aranya-Forest.
Drolia, R. and John, J. (2020) ‘Exclude coal blocks in ecologically sensitive areas from e-auction,
Chhattisgarh govt tells centre’, The Times of India, 21 June. Available at:
https://timesofindia.indiatimes.com/india/exclude-coal-blocks-in-ecologically-sensitive-areas-
from-e-auction-chhattisgarh-govt-tells-centre/articleshow/76487073.cms.
Ellis-Petersen, H. (2020) ‘India plans to fell ancient forest to create 40 new coalfields’, The
Guardian, 8 August. Available at: https://www.theguardian.com/world/2020/aug/08/india-prime-
minister-narendra-modi-plans-to-fell-ancient-forest-to-create-40-new-coal-fields.
Fernandes, A. (2012) How Coal Mining is Trashing Tigerland. Delhi. Available at:
http://www.greenpeace.org/india/Global/india/report/How-Coal-mining-is-Trashing-
Tigerland.pdf.
Fernandes, W. (2009) ‘India’s half century search for a resettlement policy and the right to
livelihood’, in Modi, R. (ed.) Beyond relocation: The imperative of sustainable resettlement. New
Delhi: SAGE Publications India, pp. 102–126.
GOI (2007) The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest
Rights) Act, 2006.
Gopalakrishnan, S. T. S. C. and Selvaraj, M. S. (2017) ‘It Is Not Just about Fences’, Economic and
Political Weekly, 52(52), pp. 97–104.
Guha, R. (1983) ‘Forestry in British and Post-British India: A Historical Analysis’, Economic &
Political Weekly, 18(44), pp. 1882–1896.
Guha, R. et al. (2012) Deeper Roots of Historical Injustice: Trends and Challenges in the Forests
of India. Washington D.C.: Rights and Resources Initiative.
Gupta, P. and Roy-Chowdhury, A. (2017) ‘Harnessing Gram Sabhas to Challenge State Profligacy
in Chhattisgarh’, Economic & Political Weekly, 52(48), pp. 58–63.
Gupta, S. and Regan, H. (2020) ‘India’s plans for a coal-fuelled recovery are threatening this
ancient forest’, CNN, September. Available at:
https://edition.cnn.com/interactive/2020/09/world/climate-covid-money-intl/.
HABSS (2014) Perspective document on Coal Mining in Hasdeo Arand region. Raipur: Hasdeo
Arand Bachao Sangharsh Samiti. Available at: http://www.janabhivyakti.org/wp-
content/uploads/sites/61/2015/01/Implications-of-Mining-in-Hasdeo-Arand-coloured.pdf.
IDFC (2010) Captive Coal Mining by Private Power Developers – Issues and Road Ahead.
Mumbai.
India Environment Portal (2011) ‘Go, No Go and All Go’, 13 April. Available at:
http://www.indiaenvironmentportal.org.in/content/326817/go-no-go-and-all-go/.
Jamwal, N. (2020) ‘After Jharkhand, Chhattisgarh and Maharashtra oppose the Centre’s auction
of 41 coal blocks for commercial mining’, GaonConnection, 22 June. Available at:
https://en.gaonconnection.com/after-jharkhand-chhattisgarh-and-maharashtra-oppose-the-
centres-auction-of-41-coal-blocks-for-commercial-mining/.
Janabhivyakti (2015) Development Imperatives for Udaypur block, South Surguja: Issues and
Challenges with recognition of land & forest titles and implementation of various Government
Schemes. Raipur. Available at: http://www.janabhivyakti.org/resources/development-imperatives-
for-udaypur-block-south-surguja/.
Joshi, S. (2016) ‘Tribes, Land and Forests: Emerging Legal Implications with reference to PESA
and FRA’, in National Seminar on ‘Governance, Resources and Livelihoods of Adivasis in India:
Implementation of PESA and FRA’. Hyderabad: NIRDPR, Hyderabad.
Kaiser, E. (2020) ‘Coal mining: Sarpanchs urge PM Narendra Modi to stop auction of blocks’, The
New Indian Express, 18 June. Available at:
https://www.newindianexpress.com/nation/2020/jun/18/coal-mining-sarpanchs-urge-pm-
narendra-modi-to-stop-auction-of-blocks-2158059.html.
Kashwan, P. (2013) ‘The politics of rights-based approaches in conservation’, Land Use Policy,
31, pp. 613–626.
Kohli, A. (2009) Democracy and development in India: from socialism to pro-business. New
Delhi: Oxford University Press.
Kohli, K. (2014) ‘Ignoring the “public” at a public hearing’, india together, 28 May. Available at:
http://indiatogether.org/articles/irregularities-in-parsa-coal-bock-public-hearing-environment.
Kohli, K. (2015) Environmental Impact Assessment: The problem with public hearings, mylaw.net.
Available at: http://blog.mylaw.net/environmental-impact-assessment-the-problem-with-public-
hearings/ (Accessed: 26 December 2015).
Kohli, K. (2016) ‘Mining is in the Way of Adivasi Forest Rights, Not the Other Way Round’, The
Wire, 7 June. Available at: http://thewire.in/40405/mining-is-in-the-way-of-adivasi-forest-rights-
and-not-the-other-way-round/.
Kohli, K. (2019) Historical injustice and “Bogus” claims: Large infrastructure, conservation and
forest rights in India. Available at:
https://in.boell.org/sites/default/files/uploads/2019/06/historical_injustice_and_bogus_claims_lar
ge_infrastructure_conservation_and_forest_rights_in_india.pdf.
Kohli, K. and Menon, M. (2016a) Business Interests and the Environmental Crisis. New Delhi:
SAGE Publications India.
Kohli, K. and Menon, M. (2016b) ‘Introduction: Green and Pink’, in Kohli, K. and Menon, M.
(eds) Business Interests and the Environmental Crisis. New Delhi: SAGE Publications India Pvt
Ltd.
Kothari, A. and Joy, K. J. (2017) Alternative Futures: India Unshackled. New Delhi:
AuthorsUpFront.
Kraemer, R., Whiteman, G. and Banerjee, B. (2013) ‘Conflict and astroturfing in Niyamgiri: The
importance of national advocacy networks in anti-corporate social movements’, Organization
Studies, 34(5–6), pp. 823–852.
Kumar, K. (2014) ‘The sacred mountain: Confronting global capital at Niyamgiri’, Geoforum, 54,
pp. 196–206.
Kumar, K. and Kerr, J. M. (2012) ‘Democratic Assertions: The Making of India’s Recognition of
Forest Rights Act’, Development and Change, 43(3), pp. 751–771.
Kumar, K., Singh, N. M. and Kerr., J. M. (2015) ‘Decentralisation and democratic forest reforms
in India: Moving to a rights-based approach’, Forest Policy and Economics, 51, pp. 1–8.
Kumar, K., Singh, N. M. and Rao, Y. G. (2017) ‘Promise and Performance of the Forest Rights
Act: A Ten-year Review’, Economic and Political Weekly, 52(25 & 26), pp. 40–43.
Kumar, P. J. D. (2015) Defending the Green Realm: The Forest Conservation Act 1980 of India
in Theory and Practice. Bengaluru: Institute for Social and Economic Change.
Lahiri-Dutt, K., Balakrishnan, R. and Ahmad, N. (2012) ‘Land acquisition and dispossession:
private coal companies in Jharkhand’, Economic and Political Weekly, XLVII(6), pp. 39–45.
Larson, A. M. and Dahal, G. R. (2012) ‘Forest tenure reform: new resource rights for forest-based
communities?’, Conservation and Society, 10(2), pp. 77–90.
Levien, M. (2015) ‘From primitive accumulation to regimes of dispossession: Six theses on India’s
land question’, Economic and political weekly, 50(22), pp. 146–157.
Macdonald, K., Marshall, S. and Balaton-Chrimes, S. (2017) ‘Demanding rights in company-
community resource extraction conflicts: examining the cases of Vedanta and POSCO in Odisha,
India’, in Demanding Justice in The Global South. Cham: Palgrave Macmillan, pp. 43–67.
Menon, M. and Kohli, K. (2007) ‘Environmental Decision-Making: Whose Agenda?’, Economic
and Political Weekly, 42(26), pp. 2490–2494.
Menon, M. and Kohli, K. (2015) ‘Environmental Regulation in India: Moving “Forward” in the
Old Direction’, Economic and Political Weekly, 50(50), pp. 20–23.
Mishra, R. (2019) ‘Hasdeo Arand forest to be declared elephant reserve’, Hindustan Times, 23
August. Available at: https://www.pressreader.com/india/hindustan-times-
ranchi/20190823/281831465390428.
Mishra, R. (2020a) ‘Chhattisgarh govt considering extending area of proposed Lemru Elephant
Reserve’, Hindustan Times, 18 June. Available at: https://www.hindustantimes.com/india-
news/chhattisgarh-govt-considering-extending-area-of-proposed-lemru-elephant-reserve/story-
TDYYe1FgSFfANsjHUu8MYN.html
Mishra, R. (2020b) ‘Gram sabhas of Hasdeo Arand area write to PM to stop coal block auction’,
Hindustan Times, 16 June. Available at: https://www.hindustantimes.com/india-news/gram-
sabhas-of-hasdeo-arand-area-write-to-pm-to-stop-coal-block-auction/story-
W2hn3GGWJhIoedt4W3PHcN.html.
MoEF (2009) Circular F.No. 11-9/1998-FC: Diversion of forest land for non-forest purposes
under the Forest (Conservation) Act, 1980 - ensuring compliance of the Scheduled Tribes and
Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006.
MoEF (2011) Comments of MoEF on draft note for Cabinet Committee on infrastructure
regarding making available more coal bearing areas for coal production. New Delhi.
MoTA (2012) The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest
Rights) Amendment Rules, 2012.
MoTA (2014) REPORT OF THE HIGH LEVEL COMMITTEE ON SOCIO-ECONOMIC,
HEALTH AND EDUCATIONAL STATUS OF TRIBAL COMMUNITIES OF INDIA. New Delhi.
MS, N. (2020) ‘The long battle of Hasdeo Arand residents against the Parsa coal project in
Chhattisgarh’, The Caravan, 24 June. Available at: https://caravanmagazine.in/communities/long-
battle-of-hasdeo-arand-residents-against-parsa-coal-project-chhattisgarh.
Nandi, J. (2021) ‘Reserves exhausted early, Chhattisgarh coal mine seeks larger forest area’,
Hindustan Times, 5 March. Available at: https://www.hindustantimes.com/india-news/reserves-
exhausted-early-chhattisgarh-coal-mine-seeks-larger-forest-area-101614919495021.html.
National Green Tribunal (2014) Appeal no. 73/2012. New Delhi: National Green Tribunal,
Government of India.
PIB (2009) ‘Ministries of Coal and Environment & Forests finalise action plan for expediting coal
mining project clearance’, Press Information Bureau.
PTI (2020) ‘Atma Nirbhar Bharat: PM Modi launches auction process for 41 coal blocks’, Business
Today, 18 June. Available at: https://www.businesstoday.in/sectors/energy/atma-nirbhar-bharat-
pm-modi-launches-auction-process-for-41-coal-blocks/story/407290.html.
Ramesh, J. (2015) Green signals: ecology, growth, and democracy in India. New Delhi: Oxford
University Press.
Ramesh, J. (2017) Indira Gandhi: A Life in Nature. New Delhi: Simon & Schuster.
Randeria, S. (2003a) ‘Cunning States and Unaccountable International Institutions: Legal
Plurality, Social Movements and Rights of Local Communities to Common Property Resources’,
European Journal of Sociology, 44(1), pp. 27–60.
Randeria, S. (2003b) ‘Glocalization of Law: Environmental Justice, World Bank, NGOs and the
Cunning State in India’, Current Sociology, 51(3/4), pp. 305–328.
Sampat, P. (2013) ‘Limits to Absolute Power: Eminent Domain and the Right to Land in India’,
Economic and Political Weekly, 48(19), pp. 40–52.
Sarin, M. et al. (2003) Devolution as a threat to democratic decision-making in forestry?: Findings
from three states in India. Overseas Development Institute.
Satheesh, S. (2020) ‘Moving beyond class: A critical review of labor‐environmental conflicts from
the global south’, Sociology Compass, 14(7), p. 12797.
Sethi, N. (2015a) ‘Five coal blocks in Chhattisgarh might see land conflict’, Business Standard,
15 January. Available at: http://www.business-standard.com/article/economy-policy/five-coal-
blocks-in-chhattisgarh-might-see-land-conflict-115011500019_1.html.
Sethi, N. (2015b) ‘PMO ordered 60 changes to green clearances, environment ministry delivered
on most’, Business Standard, 20 January. Available at: https://www.business-
standard.com/article/economy-policy/pmo-ordered-60-changes-to-green-clearances-
environment-ministry-delivered-on-most-115012001495_1.html.
Sethi, N. (2016) ‘Chhattisgarh govt cancels tribal rights over forest lands’, Business Standard, 18
February. Available at: http://www.business-standard.com/article/current-affairs/chhattisgarh-
govt-cancels-tribal-rights-over-forest-lands-116021601327_1.html.
Singh, B. K. (2021) Forest Rights Act – Accelerated Deforestation. Notion Press.
Singh, P. (2020) ‘Chhattisgarh opposes Modi govt on coal block auction, says move to hit elephant
reserve plan’, ThePrint, 23 June. Available at: https://theprint.in/india/chhattisgarh-opposes-modi-
govt-on-coal-block-auction-says-move-to-hit-elephant-reserve-plan/447155/.
Sivalingam, N. (2014) Elephant in the Room. New Delhi: Greenpeace. Available at:
http://www.greenpeace.org/india/Global/india/docs/Elephant report_Final6oct14.pdf.
Sivaramakrishnan, K. (1995) ‘Colonialism and forestry in India: imagining the past in present
politics’, Comparative Studies in Society and History, 37(1), pp. 3–40.
Sivaramakrishnan, K. (2009) ‘Forests and the environmental history of modern India’, The Journal
of Peasant Studies, 36(2), pp. 299–324.
Sundar, N. (2011) ‘The rule of law and citizenship in central India: post-colonial dilemmas’,
Citizenship Studies, 15(3–4), pp. 419–432.
The Wire (2020) ‘Allowing Coal Auction in Very Dense Forest Areas Will Be “Triple Disaster”:
Jairam Ramesh’, The Wire, 20 June. Available at: https://thewire.in/politics/allowing-coal-
auction-in-very-dense-forest-areas-will-be-triple-disaster-jairam-ramesh.
Trivedi, V. (2020) ‘Five Coal Blocks Falling in Dense Forests of Chhattisgarh Removed from
Auction List, 3 New Added’, News18.com, 7 September. Available at:
https://www.news18.com/news/india/five-coal-blocks-falling-in-dense-forests-of-chhattisgarh-
removed-from-auction-list-3-new-added-2857457.html.
Upadhyay, V. (2001) ‘Forests, People and Courts: Utilising Legal Space’, Economic and Political
Weekly, 36(24), pp. 2131–2134. Available at: http://www.jstor.org/stable/4410744.
Verma, G. (2020) ‘Chhattisgarh minister writes to Centre, seeks removal of 5 coal blocks from
auction list’, Indian Express, 22 June. Available at:
https://indianexpress.com/article/india/chhattisgarh-minister-writes-to-centre-seeks-removal-of-
5-coal-blocks-from-auction-list-6470278/.
Wal, A. (2015) ‘Chhattisgarh tribals in Delhi with pleas to save their land’, DNA, 13 January.
Available at: http://www.dnaindia.com/india/report-chhattisgarh-tribals-in-delhi-with-pleas-to-
save-their-land-2052206.
WTI (2017) Right of Passage: Elephant Corridors of India. Edited by V. Menon et al. New Delhi:
WIldlife Trust of India.
Xaxa, A. (2017) ‘Beautiful Damaged People’, CJP: defending human rights in the courts and
beyond, 30 November. Available at: https://cjp.org.in/beautiful-damaged-people.
