In the brave new world that defines India today, if your
biometrics fail to match those in the Aadhaar database, you don’t get your
rations, and could even die.[1] Similarly, if the
government fails to recognise your claims on forest land, not only do you not
get the title to the land you have been cultivating for generations, but you
even stand the risk of being evicted. Again and again, we see that it is the
most poor and vulnerable who are at risk of being penalised for government
failures.
When the Scheduled Tribes and Other Traditional Forest
Dwellers (Recognition of Forest Rights) Act 2006, generally referred to as the
Forest Rights Act (FRA) was passed, there was hope that it would at last usher
in some change in the undeclared civil war that has existed between the forest
department and forest dwellers over the last century or more. The Act aimed to
redress the ‘historical injustice to the forest dwelling Scheduled Tribes’ by
recognising their property rights to land, as well as non-timber forest
produce, and the community right of control and management which was
appropriated by the forest department. However, recent events show that there
is little likelihood of that, with the looming threat of Supreme Court mandated
evictions and a highly problematic 2019 Forest Act that is proposed to replace
the 1927 Indian Forest Act.
In 2008, soon after the FRA was passed, a range of conservation groups like Wildlife First, Nature Conservation Society, Tiger Research and Conservation Trust (TRACT) as well as former foresters (Orissa Retired Forest Officers’ Association) and even ex-zamindars (TNS Murugadoss) filed cases in various High Courts across the country as well as in the Supreme Court. They wanted the Act to be declared unconstitutional; claimed that FRA was beyond the legislative competence of Parliament since land is a state issue; that satellite imagery should be used as evidence of fresh encroachment; that FRA should not extend to sanctuaries and National Parks, and especially, that FRA should not apply to Other Traditional Forest Dwellers (OTFD). They also objected to the Ministry of Tribal Affairs (MoTA) being given responsibility for implementing the Act as against the Ministry of Environment and Forests (MoEF), a touching concern for the very institution under whose watch wildlife has suffered and forests have degraded.[2]
On February 28, 2019 after the
Government lawyers finally turned up in court to defend the FRA after having
been absent on previous occasions, the Supreme Court stayed its earlier order
of 13 February 2019, in which it had ordered State Governments to evict all
those whose claims had finally been rejected under the FRA.[3] This could amount to over a million people.[4] The Court has now asked the States to give
data on procedures followed for settling claims, the composition of those
making claims (whether scheduled tribes or other forest dwellers), and the
process to be followed after eviction. The Forest Survey has also been asked to
place on record the scale of encroachment based on satellite surveys, a method
which is problematic for reasons that will be explained below. The Court has
now fixed a date for July 2019. The
Government’s failure to defend the Act has been systemic – an earlier Bench
which heard the matter also issued notice on 29 January 2016, focused on the
area over which claims were rejected. If
it is now scrambling to restore its credibility on this issue, it is perhaps
only because of the potential fallout on elections.[5]
No doubt the Court is worried
that “in
the guise of and Other Traditional Forest Dwellers (OTFDs), the land is not in
occupied by mighty people, industrialists and other persons who are not
belonging to the aforesaid category.” (sic) (28.2.2019) The Court’s desire to
protect forests from the powerful and influential is a laudable aspiration but,
unfortunately, not one shared by the petitioners – all of whose petitions are
conspicuously silent on the diversion of forest land for non-forest purposes or
the destructive effect of encroachment by so-called godmen
like Jaggi Vasudev and his Isha Foundation.[6]
No one, least of all the anti-forest rights
groups, appears to have a problem with the Adanis being given some 2000 acres
of forest land in the heart of the dense Hasdeo Arand forests of Chhattisgarh,
and it is telling that it is the forest villagers who are protesting against
this desecration, not the foresters.[7] In fact, soon after the SC order, the MoEF
issued a circular saying that compliance with the FRA and gram sabha consent
was no longer necessary for projects on forest land.[8] As the Niyamgiri case showed showed (Orissa Mining Corp. v MOEF
2013 6 SCC 476), it is villagers empowered under acts like the FRA or
Panchayats Extension to Scheduled Areas Act 1996 (PESA) who are the best
bulwark against senseless mining and destruction of forest cover – not forest
departments, not authoritarian conservationists, and certainly not corporates
who promise compensatory afforestation. Indeed, all sensible conservationists
recognise this deep connection between local community rights and conservation
and many of them work with communities to keep out predatory forces.[9] While it is true that poachers are a major
threat to wildlife and there is a range of new vested interests, only locals
can provide the kind of continuous timely information needed to tackle the
problem.[10]
Forest Diversion vs Forest Recognition
If the real
concern is destruction of forest cover, it might be worth looking at some
statistics provided by the government itself. In response to a Lok Sabha
Question of 8 February 2019, the government noted that in the last four years
alone (2015-’19), 54,648.54 ha of forest land had been diverted under the
Forest Conservation Act. In response to
a previous question on 8 September 2016,
the government had noted that on average 25,000 ha of land had been diverted
annually for non-forest use, including mining, since 1980. This would amount to
some 10 lakh ha over forty years. A Parliamentary committee report on the
status of forests in India tabled in both Houses in February 2019 cites the
following statistics provided to it by the government: “The Committee was informed that the Ministry has granted
approval of 3226 number of cases in all categories during the last five years
from 2013-’14 to 2017-’18 under the Forest (Conservation) Act, 1980, which
involve 70,920.61 ha. diversion of forest land for non-forestry purposes. …
From 01.01.2013 to 20.06.2018, an area of 2,39,572.16 hectare forest land has
been diverted for infrastructure projects under FCA, 1980.”[11] While these figures are not consistent
(indeed, government figures are usually quite inconsistent), it is clear that
industry and infrastructure are as big a threat, if not more, as encroachment
by villagers.
In a status
report by the MoTA showing forest rights recognised up to 30 November
2018, the Ministry noted that titles for 17.32 lakh ha had been distributed
against individual claims, and 37.26 lakh ha had been conferred with community
forest titles.[12] What is essential to note is that neither of
these, especially the community forest land titles, involves diversion of
forest land to non-forest uses. In giving these community titles, the
government has effectively just saved 37.26 lakh ha of forest land. Even when
it comes to individual titles, the FRA is not a land distribution exercise — it is a process of recognising existing claims up to 4
ha, and only on cultivation that predates 13 December 2005. In principle, all
the land that is being recognised under FRA is already under cultivation or was
never forest land to begin with.
Why was FRA needed?
It is important
to go into the history that necessitated the FRA. One major reason for the Act is the faulty
settlements in place in adivasi areas. When reserve forests were constituted,
thousands of adivasis were displaced from their homes and lands, usually
without any compensation, and prevented from their customary use of forests.
This was also one of the major reasons for the great adivasi rebellions like
the Birsa Ulgulan in Jharkhand or the Bastar Bhumkal of 1910.
In
many places, lands were never surveyed and later arbitrarily declared forest
land, leading not just to disputes between people and the forest department,
but also to disputes between the revenue and forest department, and even to
interstate boundary disputes. To give just a couple of examples — in 1949, all
the nistari forests in the Central Provinces were declared Government Protected
Forests with the condition that the nistari rights of the people would not be
affected.[13] This blanket notification meant that many of
these forests remained unsurveyed, with control shared uneasily between the
revenue and forest departments. These were known as “orange areas” on the basis
of the colour assigned in maps. Although the land was claimed by the forest
department as protected forest, the revenue department granted title deeds on
this land, often without informing the forest department. Villagers also
continue to refer to these areas as their nistari forest. As a consequence of
this legal and physical ambiguity, several long term cultivators were declared
“encroachers”.[14] The Madhya Pradesh Forest Survey 2003 admitted
that people’s rights had not been settled in 83% of land declared forests,
something the forest department was legally bound to do.[15] In Orissa, Kundan Kumar has highlighted how
over 50% of the ‘forest’
areas under revenue department control, several tracts of ‘deemed’ reserve forests, and lands
above a ten degree slope (on which large numbers of adivasi families live and
practice shifting cultivation) have never been properly surveyed and settled,
thus denying thousands of people, mostly adivasis, property rights.[16]
It is also important to note
that there is no necessary correlation between the land under forest department
ownership and actual forests. The two overlap, but there are also areas of
divergence. The 2019 Parliamentary Committee Report notes that the MoEF follows
the Supreme Court’s 12 December 1996 order in (C) No.202/1995 Godavarman
Thirumulkpad vs Union of India & Ors, which defined forests “according to
its dictionary meaning”. As interpreted by the MoEF, this means:
“As of now, ‘forest’ means any area that is
recorded as forest in any Governmental record irrespective of whether it is
having a forest growth or not. .. The second aspect is that it includes any
land area, irrespective of whether it is recorded as forest or not, if it is
supporting natural forest as per the dictionary meaning of the term.”[17]
This
1996 order of the Supreme Court was deeply problematic since it insisted that
working plans drawn up by the forest department should be used to manage even
private forests, ignoring the complex variety of tenures on the ground. In much
of the North East, forests are privately owned or owned by communities, and the
Court’s ban on timber felling caused a serious loss of income for many
families.[18]
The
data provided by the Forest Survey of
India through its India State of Forest Report (ISFR) to the Parliamentary Committee
further clarifies the difference between forest cover and recorded forest area:
“The term ‘Forest Cover’ as used in ISFR refers to
all lands more than one hectare in area with a tree canopy of more than 10 %,
irrespective of land use, ownership and legal status. It may include even
orchards, bamboo, palm etc and is assessed through remote sensing. On the other
hand, the term ‘Recorded Forest Area’ refers to all the geographical areas
recorded as ‘Forests’ in Government records as Reserved Forests (RF) and
Protected Forests (PF), which have been notified under the provisions of Indian
Forest Act, 1927 or its counterpart State Acts. Besides RFs and PFs, the
recorded forest area may also include all such areas, which have been recorded
as forests in the revenue records or have been constituted so under any State
Act or local laws.” [19]
The Report goes on to note
that “only 16 States/Union Territories have been able to provide details of
digitised boundaries of Recorded Forest Area for incorporation in the India
State of Forest Report, 2017” (para 4.12) which makes it difficult to test the
overlap between actual forest cover and forest land.
In short, what this tell us is
that government records are seriously problematic when it comes to recording
forest land, that there are large tracts of forest land on which there is no
forest in any conventional sense, that there are forests on private or revenue
land, and that people have been cultivating in both forest land (which became
forests much after they started cultivation) and revenue land (for which they
should have been given titles but were not). So the first failure of the
government is in its own record keeping, without which it had no right to label
people encroachers and take steps to evict them even prior to the passage of
the FRA, or to criminalise then under other offences. Across the central
states, lakhs of people have been booked for minor forest offences, with many
unable to post bail for years.
While faulty revenue and forest settlements are one major
cause, another major cause for ‘encroachment’ in the forest has been land
hunger and proletarianisation among adivasis, whose holdings tend to be
unproductive and fragmented. As figures collected by the Government of India
appointed High Level Committee on Tribal Communities, 2014, revealed, average
operational holdings among scheduled tribes declined from 2.44 ha in 1980-81 to
1.53 ha in 2010-11.[20] Displacement by a variety of industrial and
hydel projects as well as conflict has also pushed people onto forest land. For
instance, after 2005 when the Koyas started fleeing from the Salwa Judum in
Chhattisgarh and fled to Telangana, the only place they could settle was on
forest land. The Forest Department has sometimes allowed them to stay, but
equally often they have burnt the huts of the IDPs (internally displaced
persons) and destroyed their standing crops.
Immediate History of the FRA
In 1990, the MoEF issued a set of six
guidelines to deal with disputes related to forest land and forest villages,
but these were never implemented. In February 2002, as part of the ongoing
Godavarman case, the Supreme Court asked state governments to declare the
extent of encroachments. A Central Empowered Committee constituted by the Court
also issued draconian recommendations included banning all future
regularisation, allowing for the possibility of ‘excessive use of force,
un-provoked firing, and atrocities punishable under the SC/ST Atrocities Act’
in the process of eviction. Many states treated the Court’s request for
statistics as a request for action, and evictions started taking place across
the country. The current fear of
evictions in response to Supreme Court orders, therefore, comes with a sense of
déjà vu.
In response, a range of adivasi
organisations and individuals came together to form the Campaign for Survival
and Dignity (henceforth Campaign); and sustained pressure from both adivasi
organisations and the Left ensured that the first Congress-led United Progressive
Alliance (UPA) regime passed the Act. It was also seen as a way of countering
Naxalism.
The Provisions of the FRA
The
FRA is an unusual act in many respects, not only for the range of rights (as
well as duties) that it recognises, but for the innovations it makes in what
kind of evidence can be summoned which ranges from preliminary offence reports
(PORs) issued by the forest department to oral evidence from village
communities. While applicable to all scheduled tribes it also covers under OTFD,
non-adivasi communities who have historically been living in the forest. While
there is a danger that powerful upper castes may use this loophole to claim
rights, there are also many small dalit, and OBC communities who have shared
space with adivasis across central India.
The
forest rights recognised pertain to both individual and community rights, and
it is the latter which the CSD and other groups have sought to emphasise. Apart
from pattas that legitimate existing cultivation upto 4 ha, villagers gain
ownership rights over minor forest produce, rights over fishing, grazing etc,
but not over hunting. Nomadic pastoralists, and particularly vulnerable tribal
groups (PVTGs) have been given their own rights. Communities have also been
given the right to conserve and manage any community forest resource, as well
as rights to intellectual property and their knowledge of biodiversity.
While
the rights are expansive, the procedures for adopting these rights are
unfortunately quite bureaucratic and go through three levels of committees –
the gram sabha, the sub-divisional level committee, and the district level
committee. The Gram Sabha is supposed to receive and verify claims and the
sub-divisional level committee is supposed to help in the process by providing
forest and revenue maps and electoral rolls. If a claim is rejected at the gram
sabha or sub-divisional stage, claimants are supposed to be given reasons in
writing within sixty days to enable them to appeal to the district committee.
The decision of the district level committee is final, but must be explained in
writing to the claimant. The district committee is also responsible for
ensuring that nomadic pastoralists and PVTGs get their habitat rights. The
State Level Monitoring Committee is supposed to meet every three months, and do
just that - monitor the progress of claims.
The
sub-divisional, district and state committees are all dominated by the
bureaucracy. The latter two are chaired
by the Sub Divisional Officer (SDO) and Collector respectively and have
membership from the forest department and the tribal welfare department apart
from the panchayat at the relevant level. The State Level Committee is chaired
by the Chief Secretary with representation from all relevant departments. If
forest rights are being given to the wrong persons, it can only be by collusion
with the administration, as we saw in the infamous Malik Makbuja scam of Bastar, where in the name of ensuring that
adivasis got a fair price for timber on their private lands, there was mass
felling of trees on forest land with the collusion of the forest and revenue
departments, who passed off the timber as coming from private sources.
The implementation of FRA in practice
As with every
enabling and right-giving Act, the primary problem is that those for whom the
rights are intended do not know of the existence of such an Act and here, the
forest department is in no hurry to enlighten them. The second major problem is
bureaucratic indifference and ignorance of the rules, which leads to a high
rate of rejection of claims. The 2018 MOTA status report on implementation of
FRA tells us that 44.83 percent of claims were granted. 55% of individual
claims were rejected compared to 51% for community claims.
In its affidavit
of February 2019 asking the Supreme Court to reconsider its eviction orders of
13 February, the MoTA cites the following implementation problems, as a reason
why so many claims have been rejected:
wrong interpretation of the Act; appropriate procedure not being
followed in filing of claims due to ignorance by the gram sabha; the reason for
rejection not being communicated to claimants making it impossible for them to
appeal; unrealistic deadlines for filing claims and appeals; the fact that the
district administration did not provide forest and revenue maps and the fact
that the State Level Monitoring Committee
did not meet regularly.
In the 2010 report
of the committee set up jointly by the MoEF and MoTA to look into the working
of the FRA,[21] we get
a fuller sense of what is meant by the ‘wrong interpretation of the Act’. For
instance, claims were rejected because a person owned other revenue land; when
the land claim was not recognized as the land was not officially forest land;
or because the higher authorities recognized only land under ‘plough
cultivation’, and not land cultivated by other means. In many cases, the committees insisted on
PORs or satellite imagery and did not accept other kinds of evidence. One big
problem was that even when claims were recognized, the revenue and forest
records were not changed to reflect this.[22]
Recent academic studies on the FRA - in particular, a set published as part of a
ten year review of the FRA in the Economic and
Political Weekly in 2017 - point to continuing implementation problems, including
recognition being
given to the Joint Forest Management (JFM) committee (in which the forest
department has effective control) instead of the gram sabha, and CAMPA funds
(for compensatory afforestation) being given to the forest department for
afforestation without recognising the existing rights of people on the land
being afforested. [23]
Mining is emerging as a major reason for community forest
rights being denied, along with areas where sanctuaries are to come up. The
most notorious example is of Ghatbarra village in Chhattisgarh which was
granted community forest rights in 2013 in the Hasdeo Arand forests
(over 820 ha out of the 2300 ha claimed) but found its title abruptly cancelled
in 2016,[24] when coal mines were being parcelled out. Many
other cases can be cited where villagers in mining areas have been prevented
from filing FRA applications, such as around Raoghat in Chattisgarh’s north
Bastar or Surjagadh in Maharashtra’s
Gadchiroli. The FRA cannot prevent the forest being given for other uses – but
it can ensure that villagers have a say and that even if their protests are
overridden by the government, they are not displaced without their rights being
recognised and compensated.
In December
2017, I attended a meeting organised jointly by the Campaign for Survival and
Dignity and the CPI in Gadchiroli to mark ten years of the FRA and twenty years
of PESA. It was an amazing meeting where villagers, primarily from different
parts of Maharashtra but with representation from other parts of the country,
discussed the details of the laws and the problems they faced in implanting
these acts. A more informed legal constitutional decision would be hard to
imagine, but the main organiser, a young man called Mahesh Raut has been
arrested for so-called Maoist links in the Bhima Koregaon case. Presumably,
today, anyone who makes adivasis and others aware of their legal rights must be
a Maoist.
One group from
Yeotmal said that they had been issued a letter saying the villagers couldn't
call their own gram sabha meeting, only the sachiv (appointed by
the government) could summon the gram sabha. And since the sachiv was refusing to
do so, they had a problem. Another villager from Bhamragarh said that the
government was refusing to provide the village misal
bandobast (record of rights) to enable people to file claims for
community forest rights. A representative from Rajasthan said that they had got 36,000 ha of the
71,000 ha they had claimed under community forest rights, but the claim papers
for the rest had been lost; both the revenue and forest departments were
disclaiming any knowledge of these. In sanctuary areas, the forest department
was not accepting any claims, saying they were waiting for guidelines from the
government. Where villagers have been
able to get income from tendu and bamboos in Surjagadh (Gadchiroli), they have
put it to innovative uses, such as building a community house for women during their
periods so that they could relax in comfort.
The anti-FRA
petitioners have asked for the use of satellite imagery to show that mass
encroachment has taken place after the FRA was enacted in anticipation of
getting titles. In their order of 28 February 2019, the Supreme Court bench has
also called for a satellite survey by the Forest Survey of India. However, the
Forest Rights rules (12 A.11) are very
clear that satellite imagery and technology may only supplement other forms of
evidence, and
cannot be treated as a replacement. One of the major problems with satellite
imagery is that it does not take into account the practice of keeping land
fallow or under tree cover, especially but not only in areas of shifting
cultivation. Technology is useful but it should be in keeping with the ground truth
that only local communities can provide. Undoubtedly, there will be some false claims and fresh
encroachments, but these cannot be used to jettison the Act altogether. Indeed,
the 2010 Joint Committee Report on the FRA says “(o)n the whole, however, we were presented with limited
evidence, even by the Forest Departments, of false or bogus claims.”[25]
What is to be done?
If the government and the Courts are at all serious about
preserving the forest cover in this country as well as guaranteeing justice for
forest dwellers, it would do well to take community forest rights seriously,
apart from other features of the FRA like habitat rights for PVTGs and
pastoralist rights. So far the government has tended to concentrate on
individual forest titles. While these are important, they are also potentially
open to powerful interests subverting them. However, community forest rights
are almost entirely about conservation.
Kundan Kumar et al estimate that “In terms of area, potentially, up to
85.6 million acres or 34.6 million hectares of forests could be recognised as
CFRs in the country….In terms of potential beneficiaries, an estimated 200
million Scheduled Tribes (STs) and other traditional forest dwellers (OTFDs) in
over 1,70,000 villages are the users of this potential area, and could,
therefore, gain collective rights over forests under the CFR provisions of the
FRA.”[26]
Sharad Lele argues that this potential should
be recognised and used to rewrite the IFA instead of the current proposed IFA 2019
which pretty much replicates the colonial forest act in its demarcation of
reserved and protected areas, albeit with more powers to foresters: “All
reasonable estimates of the potential CFR area (area used by local communities)
suggest that PFs and most RFs should simply be replaced by CFR Forests, which
should be recognised as the main legal forest category. If any RF outside of
NPs and WLSs remains unclaimed as CFR, it could be re-designated as a
‘Conservation Forest’. Correspondingly, the CFR Gram Sabhas should be
recognised as the main manager/custodian for the CFR Forests by the forest law,
and an agency (possibly hived off from the current FDs) created for providing
technical and protection support to them.”[27]
Since the late 1980s, forest policy across the
world has changed towards a recognition that locals must be treated as
important stakeholders and not just cast aside on the grounds that forests are
a national resource. The current moves to backtrack on the FRA and bring in an
old style forest act ignore the depth and breadth of material that has been
generated on this subject, as well as on the importance of customary tenurial
rights. If the people of this country
are treated as a resource rather than a curse, the Courts, conservationists and
communities can together work wonders for forest preservation. A mahagathbandan in the forests is the need
of the hour.
Nandini Sundar is
Professor of Sociology, Delhi University. Her publications include Branching Out: Joint
Forest Management in India (OUP 2001), and two
edited volumes, The Scheduled Tribes and
their India (OUP 2016) and Legal Grounds: Natural Resources, Identity
and the Law in Jharkhand (OUP 2009).
[1] The Wire Staff, Of 42 ‘Hunger-Related’ Deaths Since 2015, 25 ‘Linked to Aadhaar Issues.’ 21 September 2018, https://thewire.in/rights/of-42-hunger-related-deaths-since-2017-25-linked-to-aadhaar-issues
[2] While forest cover has increased from 2015 to
2017, the dense and moderately dense forest has come down, and open forests have increased. Rajya Sabha,
Department-Related Parliamentray Standing Committee on Science and Technology,
Environment and Forests, 324th Report on Status Forests in India,
Presented to the Rajya Sabha and Lok Sabha, 12 February 2019 (henceforth Parliamentary
Committee, 2019)
[3] Orders of 13.2.2019, 28.2.2019, 29.1.2016 in
WP 109/2008, Wildlife First and Ors vs. Union of India, Supreme Court of India,
accessed at https://www.sci.gov.in/
[4] Nitin Sethi, SC orders forced eviction of more
than 1 million tribals, forest dwellers, Business Standard, February 21,
2019.
[5] Bhaskar Tripathi, Forest Rights Could Decide Election Results in
133 (25%) Seats. India Spent, March 20, 2019.
[6] Subhashini Ali, Revisiting Muthamma in her
Little Hamlet Near Coimbatore, The Wire, 25 January 2018
[7] Chitrangada Chowdhury, If we give the Hasdeo
forest, where will we go?, Caravan, 25 February 2019.
[8] Modify Circular that violates FRA, Tribal
Affairs tells Environment Ministry. Indian Express, April 11, 2019
[9] See
letter by Indian Conservationists to Minister, MoEF dated 6th
October 2016, and endorsement by international conservationists, 6th October 2016, at https://forestrightsact.files.wordpress.com/2016/11/international__organisation_endorsement_of_conservation_statement_november_2016.pdf
[10] See even Valmik Thapar, The Future of our
Wilderness lies in Wildlife Startups, Hindustan Times, April 10, 2019.
[12] Government of India, Ministry of Tribal
Affairs, Status Report on the Implementation of the Scheduled Tribes and Other
Traditional Forest Dwellers (Recognition of Forest Rights Act) 2006 (for the
period ending 30.11.2018), Annexure 1
[13] Nistar refers to forest produce allowed to villagers free or
on concessional rates. Specific areas were set aside for this purpose known as
nistari forests.
Government of CP and
Berar, Notification No. 3282 to 3284-2845-IX dt. 17.10.1949.
[14] This section draws on Nandini Sundar, “Is Devolution Democratisation”.
In World Development, 29 (12), 2001, 2007-2024.
[15] Campaign for Survival and Dignity (CSD) 2003. Endangered
Symbiosis: Evictions and India’s forest Communities. Report of the Jan
Sunwai, July 19-20, 2003. Delhi: CSD
[16]Kumar, K., Erasing the
Swiddens: Shifting Cultivation, Land and
Forest Rights in Odisha, in S. Lele and A. Menon (eds.), Democratizing
Forest Governance in India, Oxford University Press, 2014, New Delhi, pp.301-340.
Forest Rights in Odisha, in S. Lele and A. Menon (eds.), Democratizing
Forest Governance in India, Oxford University Press, 2014, New Delhi, pp.301-340.
.
[18] Nathan, Dev,
Timber in Meghalaya. Economic and Political Weekly, January 22,
2000, 25 (4): 182-186.
[20] Government of India. 2014. Report of the High
Level Committee on Socio-economic, Health and Educational Status of Tribal
Communities of India. New Delhi: Ministry of Tribal Affairs, Government of
India.
[21] Joint Committee, 2010, "Manthan: Report of the National
Committee on
Forest Rights Act", Ministry of Environment and Forests and Ministry of
Tribal Affairs, Government of India, New Delhi.
(http://fracommittee.icfre.org/FinalReport/FRA%20COMMITTEE%20REPORT_FINAL%20Dec%202010.pdf)
Forest Rights Act", Ministry of Environment and Forests and Ministry of
Tribal Affairs, Government of India, New Delhi.
(http://fracommittee.icfre.org/FinalReport/FRA%20COMMITTEE%20REPORT_FINAL%20Dec%202010.pdf)
[22] Ibid. Paras 3.5-3.6
[23] Geetanjoy Sahu, Tushar Dash & Sanghamitra
Dubey, Political Economy of Community Forest Rights, Economic and Political
Weekly
June 24, 2017, Vol LII, Nos 25 & 26, pg 44
[25] Joint Committee 2010, Para 3.5.7
[26] Kundan Kumar, Neera M. Singh and Y Giri Rao,
Promise and Performance of the Forest Rights Act: A Ten Year Review, Economic
and Political Weekly June 24, 2017, Vol LII, Nos 25 & 26, pg 41.
[27] Sharad Lele, Reforms in India’s Forest Sector
stuck in Reverse Gear. Down to Earth, April 11, 2019.