LEGAL LIMITATIONS: IN THE LIGHT OF MURIA TRIBE BY - SANTWANA CHILLA
LEGAL LIMITATIONS: IN THE LIGHT OF MURIA TRIBE
AUTHORED BY - SANTWANA CHILLA, NALSAR
2026
Abstract
The Muria Tribe, hailing from
Chhattisgarh, are finding themselves in an uncertain predicament due to
internal displacement across the adjacent states of Andhra Pradesh, Odisha and
Telangana. This research paper examines the legal complexities surrounding the
Muria tribal group, who have the nomenclature of Gutty Koya in the migrated
states of Telangana and Andhra Pradesh. The Muria tribe is a marginalized
indigenous community that has been affected by the violence resulting from a
crossfire between Maoists in the forest area of Chhattisgarh and the
state-sponsored militant group, Salwa Judam. After multiple instances of
violence, the community fled to undivided Andhra Pradesh and Odisha. According
to local tribes, the Murias of Chhattisgarh and Gotti Koyas of Khammam district
belonged to one clan, even though they lived in different states and had
different names. Murias have the status of a scheduled tribe in the state of
Chhattisgarh but lost their title due to forced migration to the neighboring
states. Focusing on their loss of scheduled tribe status during migration, the
study analyses the issue in the light of Action Committee v. Union of India.
The study attempts to critique the
effectiveness of area limitations and highlights governmental reluctance to
recognize internally displaced tribal
identity.
In the present paper, we will be asking
a few questions about the law that is present in the country, and its implications
for the most marginalized people of the country. The paper will look at the
reasoning and the criteria that were taken into consideration while curating
the Schedule tribe list and the situation of migrants and their legal status as
tribal members while simultaneously looking at the slight but significant
distinction between voluntary migration and internal displacement. This paper
further advocates for tailored legal reforms that address the unique challenges
of involuntary displacement and ensure the protection and inclusion of
marginalized communities within the framework of social Justice.
Introduction
The mass migration of approximately
20,000 Murias[1], from
Chhattisgarh to the neighboring states of erstwhile Andhra Pradesh and Odisha[2]
unveils a poignant chapter of displacement and societal upheaval. The
consequences of this movement have been multifaceted, impacting not only the
displaced community but also triggering tensions and challenges in the
receiving regions. The division of the Murias into East Godavari district in
Andhra Pradesh[3] and the
more substantial presence in Telangana's Khammam district[4]
reflects the intricate nature of their dispersal. However, this migration has
not been without complications, as the state-recognized Adivasis in Khammam,
known as Koyas, faced threats and challenges due to the influx of Muria
tribals.[5]
The root cause of this internal displacement[6]
lies in the crossfire between Chhattisgarh and Andhra Pradesh, compounded by
Maoist activities in the Bastar and Dantewada regions. What began as a movement
protesting against wealthy landlords evolved into a struggle for power.[7]
The Maoists, initially supported by
the CPI, witnessed a shift with the establishment of Salwa Judum[8], a
state-sponsored counterinsurgency operation.[9]
This drastic change compelled the Adivasi community, including the Murias, to
become involuntary participants, forced into the frontline of the "war on
Maoists."[10] As the
movement transformed from peaceful protest to violent measures, the Murias
sought refuge in neighboring states, indicating the harrowing impact of the
conflict on their lives. The years 2005 to 2007 witnessed an accelerated influx
of Murias into Andhra Pradesh and Odisha[11],
signifying the urgency and intensity of the situation.
This migration narrative underscores
the interconnectedness of socio-political factors, armed conflict, and
displacement. The Murias, grappling with the consequences of external
conflicts, were compelled to seek safety in unfamiliar territories. The
ramifications of this mass movement extend beyond mere geographical relocation,
shaping the socio-cultural dynamics of both the displaced and the communities
receiving them.
Tribal Oppression
More than 500 scheduled tribes are
notified under article 342 of the Constitution of India.[12] Forced
displacement is a major concern within the Adivasi community. The reasons
primarily are associated with state activities. Displacement does not
exclusively feature the loss of shelter but extends to losing land and natural
resources that are the basis of the economic survival of these tribal
communities.
Murias have to face the brunt of the
forest officials as they proceed to place themselves systematically in a
privileged position among the tribals, especially in relation to those seen as outsiders
belonging to a foreign state. In Telangana, the Muria community, in the initial
years of their displacement, worked for various officials and non-tribal locals
free of cost.[13] They
have been forced to do free work in the cotton mills, and they still claim to
work for the officials and the forest department, despite having lands of their
own to look after. Tribal groups suffer from various forms the oppression.
However, some groups, like the Murias, are compelled to endure greater levels
of oppression, constantly fearing unprovoked attacks on their property or
people. Murias have witnessed their abodes get ransacked, officials destroy
crops, and also have seen their women become victims of lathi-violence. A vast
majority of the forceful displacement from Chhattisgarh was a consequence of the
fear of death, injury, sexual violence, forcible recruitment, or regrettably, a
combination of these fears.[14]
However, individuals belonging to the community, could not escape violence and
discrimination in the migrated state as well.
The issue that brought the tribal
community into the limelight in recent years is the result of the Telangana
government’s ‘Haritha Haaram’[15]
project. This is an afforestation program to increase the present tree cover
from 24% to 33% and aims at making the State a “green city” that covers at
least one-third of the State's geographical areas.[16]
With the same aim in mind, the Chief Minister of the State has stated that the
lands should be given to the government so that the forests can flourish again.
This led to conflict between Podu (Slash and Burn agriculture) cultivators and
the forest department. The program protects tribal communities listed in the
State of Telangana[17]
by ensuring that the uncertainties on their livelihood are looked after as per
the rights given by way of the Forest Rights Act and the Constitution. The same
situation cannot be extended to the Muria tribal community, who do not have a
legal claim over the lands they have been cultivating for 20 years now. They
are viewed to be encroachers who are illegally living in the area and have been
evicted from their dwelling places by the forest department. The tribal
encroachment is seen to be an obstacle for the Telangana government to promote
the Afforestation program.
The fact remains that the Telangana
government and its officials have been moving forward with infrastructural
developments like the construction of flyovers, highways, and colossal malls,
which extend to 15 acres. Non-tribals in Telangana have occupied many acres of
land for which they are rarely held accountable because the people involved
have power political affiliations and are not vulnerable to the legal system. On
the other hand, the acquisition of the tribal land is justified on the premise of
benefiting the public in large. However, on the contrary, tribals, markedly internally
displaced tribal communities, like the Murias, are susceptible to government
developmental programs, negatively.[18]
The transformation of the Scheduled
Tribe list from its inception in 1950[19]
to its current iteration signifies a nuanced understanding by the state that
not every tribe necessitates or should be treated with special consideration.
The initial categorization as "primitive tribes"[20]
eventually evolved into the term "backward tribes."[21] A
pivotal moment in this evolution occurred with the Lokur Committee's scrutiny
of the criteria for designating tribes as Scheduled Tribes in 1965. This
committee emphasized the significance of traits such as primitiveness, the
distinctiveness of culture, geographical isolation, and a collective reluctance
to engage with the broader community.[22]
It concluded that tribes whose members significantly integrated with the
general population should be ineligible for inclusion in the Scheduled Tribe
list, aligning with the provisions outlined in Article 342 of the Constitution
of India.[23]
Concurrently, special schemes and social welfare programs were implemented to
uplift Scheduled Castes and Tribes, ensuring their overall well-being
paralleled that of other sections of society. The committee also acknowledged
that if the population of a tribal group was too minimal to be considered a
community, inclusion in the list might be impractical.
Turning our attention to the Muria
tribe, inhabiting the forested regions of Telangana and Andhra Pradesh, we find
a community characterized by a rich and unique culture steeped in customary
rites, traditions, and beliefs. Notably, their cultural practices, such as the
Gaur dance[24] and the
amalgamation of animistic and Hindu doctrines, contribute to the
distinctiveness of the Muria tribal group in Chhattisgarh. Despite the cultural
richness, governmental recognition of the Muria community was a belated
development, highlighting a historical oversight.[25]
However, a more pressing concern
surfaces as we delve into the plight of the Muria tribe. The forced
displacement of as many as 55,000[26] from
Chhattisgarh to the forested areas of Andhra Pradesh has led to severe neglect
of their rights. The initial stages of displacement were marked by a lack of
acknowledgment and humanitarian support for the tribal society. Instances of
demolitions and violence perpetrated by forest officials further exacerbated
their vulnerability. Despite the intervention of non-governmental organizations
(NGOs) and human rights groups[27],
the marginalization and violence against the tribals persisted.
Compelled to resettle in the interior
forest areas, the Muria tribe lives in a state of perpetual fear and distress,
devoid of a sense of belonging in their displaced state. The forested areas
they now inhabit are isolated, and their interactions are confined to forest
officials, police, NGOs, and human rights organizations.[28]
What amplifies their plight is the lack of legal recognition as a scheduled
tribe, even though they unequivocally meet the criteria outlined in Article 342
of the Constitution of India.[29]
This denial of recognition subjects the Murias to heightened marginalization,
violence, and discrimination compared to other listed Adivasi tribes in
Telangana and Andhra Pradesh.
The underlying narrative echoes the
need for comprehensive recognition and protection of the rights of marginalized
tribal communities, particularly those who have undergone involuntary displacement.
The complexities of their struggles underscore the imperative for systemic
changes, legal amendments, and proactive measures by both state and central
authorities to rectify oversights and provide equitable opportunities for these
communities to thrive and preserve their dignity and legal status, that they
are rightly entitled to under the Constitution of India.
Area Limitations
The Lokur committee established that
there had been great criticism, both within the parliament and outside, that
the area restrictions and limitations hamper social mobility as the communities
concerned would confine themselves to the specified areas as they would be
trading off their privileges and benefits by moving out.[30] With
this covert constitutional restriction in place, it acts antithetical to the policy
of social integration, and the advocacy of abandoning their isolation and promotion
of intermixing of their groups with the rest of the population becomes a task
that becomes difficult to achieve. After appreciating the considerations, the
area limitations were removed by every State and Union territories.[31]
The report also considers whether, in
a situation where a caste or a tribe that is listed as a scheduled caste or a
scheduled tribe in a particular State or a Union territory, would be recognized
as an SC or an ST in the migrated state.[32] Having
an all-India list for Scheduled castes and Scheduled tribes is not feasible
from the constitutional point of view, as articles 341[33]
and 342[34] specify
the method of recognizing Scheduled Castes and Scheduled Tribes with respect to
each individual state through the consultation of their respective governors. The
report proceeds to state that the problem or the issues that arise is not of
great significance and not so serious as to bring about a constitutional
amendment.[35] This
report fails to consider large forced internal “migrations” that take place due
to civil uncertainties. The report primarily considers displaced persons to be
individuals who traveled to India from East Pakistan. Through investigations, Assistant
Commissioners concluded that the social disabilities seen in the communities of
Scheduled Castes and Scheduled Tribes were non-existent. These communities received
substantial benefits under rehabilitation schemes,[36] better
than what was awarded to the Scheduled Castes and Scheduled Tribes in the
respective states.
The committee and the constitution acknowledged
the importance of policy decisions directed towards the upliftment of displaced
individuals from Pakistan. Murias endure disabilities in relation to the
officials and the Koya tribe of Telangana which was considered as one of the
requirements to conclude the displaced people from Pakistan have a dignified ad
protected life. It has also been noted that the displaced people have gotten
substantial benefits under rehabilitation schemes, on a scale better than those
normally afforded to the scheduled castes in the state concerned.[37] Murias,
on the other hand, have not seen any development. They face the same plight and
have not been enabled with significant policy decisions for their upliftment. In
addition to the entire tribal community losing its legal recognition as a
scheduled tribe in the migrated state, there is a looming threat of displacement,
once again. If it were not for The High Court of Telangana’s intervention,[38]
the Muria tribe would have been victims of the ambitious “Haritha Haaram”
project. Listing Murias as Scheduled tribes of Telangana is a necessary step in
the right direction, which is to be considered by the Telangana Government.
Action
Committee on Issue of Caste Certificate to Scheduled Castes and Scheduled
Tribes in the State of Maharashtra and Ors. V. Union of India (UOI) and Ors.[39]
In this particular case, the State of
Maharashtra denied extending benefits and rights that were available to
Scheduled tribes and Scheduled Castes of the State to the Scheduled castes and
Scheduled Tribes of another state who have migrated to Maharashtra. The issue
before the court was whether the petitioner was entitled to avail the upliftment
benefits of being a scheduled Caste and Scheduled Tribe in Maharashtra when the
said individual had a scheduled caste certificate from Andhra Pradesh. After
discussing articles 341 and 342 of The Indian Constitution, the court concluded
that the president, with the consultation of the governor, is the only official
who is competent to recognize the tribals that are to be named as Scheduled
Caste or scheduled Tribe. Without the notification of the same, a tribe or a
person belonging to a scheduled caste claiming to have the same rights as an ST
or SC in the migrated State was deemed to not be allowed to claim the same. For
the same reason, the petitioner was not entitled to admission under a reserved
quota.
The conclusion that has been arrived
at by the court emphasizes the importance of the notification to enroll a
particular Caste or Tribe into the State's list. Such notification is necessary
for the individual or the group, in its entirety, to be able to enjoy the
enabling provisions given to the STs and SCs in the migrated State.
The court in this case, and the
succeeding cases,[40]
relied on the same ratio, which extensively relied on the premise that “through
migration, the individual or the group has a better and more socially free and
liberal atmosphere, and if a sufficiently long time is spent in socially
advanced areas, the inhibitions and handicaps suffered by belonging to a
specifically disadvantageous community do not truncate their growth and the
natural talent of an individual gets the full scope to blossom and
flourish."[41] This is
highly presumptuous of the Supreme Court when the same argument is extended to
the Muria community, who have been persecuted from their primal State and have
been equally, if not exponentially, marginalized in the migrated states of
Andhra Pradesh, Odisha, and Telangana in particular.
The loss of identity experienced by
internally displaced tribal individuals diverges significantly from that of
non-tribals. When tribal groups are forcibly uprooted and relocated to a
different state, they find themselves compelled to shed their tribal status, a
distinction that holds particular significance. This transition from being
recognized as tribals in their native state to assuming a non-tribal identity
i.e., not securing enabling provisions or welfare schemes in an unfamiliar
region, amplifies the challenges faced by internally displaced tribals. The
disadvantage becomes glaringly apparent when one considers that the privileges
and legal rights provided in their original state transform into a disadvantage
in the new state, even though the circumstances of primitiveness and
backwardness, as stated in article 342 are still prominently a characteristic
feature of the tribal group.
In contrast, the experience of the
average citizen undergoing migration, seeking educational opportunities or
employment benefits, does not typically involve a fundamental change in social
status. The benefit and entitlements accessible in the original state persist
unchanged even after migration. Mobility is not constrained, and migration is
indeed seen as a development process. The migration of backward communities,
particularly tribals, entails inherent tradeoffs, with the challenges becoming
even more pronounced in instances of forceful displacement. Migration for
Murias was not an act that was viewed to be beneficial; rather, it served as an
escape from violence, a quest for refuge, and is marked by the absence of legal
recognition as a scheduled tribe. It is driven by the imperative to secure
lives as a desperate response to state-sponsored violence and eviction rather
than a pursuit of economic or occupational advancement.
The court, as a custodian of justice,
holds the power to mandate states and institutions responsible for recognizing
these displaced communities to make requisite amendments. The absence of such
directives may inadvertently position the law as an instrument that, instead of
safeguarding the marginalized, inadvertently facilitates institutional
practices that perpetuate social hierarchies. This raises concerns about the
efficacy of the legal system in ensuring equitable treatment for certain societal
groups and enabling their upward mobility, especially when confronted with
systemic challenges.
MIGRATION AND INTERNALLY DISPLACED PEOPLE
Migration, on the global stage, is a
comprehensive term encompassing various forms of movement. The International
Organization for Migration defines a migrant as an individual who relocates
from their habitual residence, whether within national borders or across
international frontiers, either temporarily or permanently. This movement can
be prompted by a multitude of factors. Internal migration, on the other hand,
pertains to individuals who move within a country's borders, irrespective of
the reasons motivating such relocation.[42]
The World Refugee Survey estimated
the total number of IDPs in India to amount to 507,000, whereas the Global DIP Project estimates 3.9
million of the population to be displaced due to conflict-induced internal
displacement.[43]
The court delves into the intricate
considerations surrounding tribes and castes sharing identical nomenclature
across different states. It asserts that the specifications for such
designations may differ, leading to varying degrees of disadvantages in
distinct states. The court underscores that the mere inclusion of a caste as a
Scheduled Caste in one state does not automatically entitle an individual from
that caste in another state to the rights, privileges, and benefits accorded to
a Scheduled Caste member in the latter state "for the purposes of this
Constitution."
In the Action Committee case, the court
presupposes that opting for migration implies choosing a more socially
liberated and liberal environment, especially after spending a considerable
time in socially advanced settings. However, this presumption proves flawed in
the context of the Murias. Despite their migration to neighboring states since
2005, spanning 15 years, the promised development and advancement are notably
absent. Many members lack essential documents such as ration cards and NREGA
job cards, and educational opportunities for Muria children are alarmingly
limited, as highlighted by the NGO "Save The Children."[44]
Contrary to the Supreme Court's assumptions, social discrimination persists,
and advancements in Muria livelihoods remain elusive.
A crucial aspect overlooked by the
court pertains to whether internally displaced individuals are considered
migrants. Indian census data categorizes migration reasons, including
employment-seeking, better employment opportunities, migration of the family's
earning member, and job loss.[45]
The Muria tribe of Chhattisgarh, however, does not fit into any of these
categories, as their displacement was involuntary, resulting from state-induced
disruption.
The court's decision in the Action
Committee case, centered on voluntary migration, does not apply to the
circumstances of internally displaced people like the Muria tribal community. It
prompts a crucial question: should there not be a differentiation in approach
when addressing the challenges faced by internally displaced tribal groups,
particularly when their disadvantages persist even in the state of migration? The
principles derived from the judgment must be adapted to the distinctive
challenges faced by internally displaced individuals, as their movement is not
a matter of choice but, rather, a consequence of forceful displacement. The
court's reliance on Ambedkar's response to Jaipal Singh, emphasizing
eligibility based on voluntary migration, does not hold for internally
displaced people, for whom the context of involuntary displacement necessitates
a reevaluation of legal principles.
Governmental
shortcoming
Article 342 of the Indian
Constitution empowers the President of India, in consultation with the state's
governor, to specify tribes or tribal communities as Scheduled Tribes through a
public notification. In the case of the Muria tribe, whose members have been
internally displaced and currently reside in Telangana, the Telangana
government has the authority to recognize and recommend their tribal status to
the central government.
Notably, the Telangana government has
taken steps to recommend the inclusion of eleven tribes, namely Khaithi Lamada,
Valmiki Boya, Mali, Chamar Mathuras, Chunduvallu, Bedar, Kirataka, Nishadhi,
Pedda Boyas, Talayari, and Bharat Mathuras, into the Scheduled Tribe list.[46]
However, a critical examination of the state's objectives is warranted,
particularly in light of its reluctance to acknowledge internally displaced
persons (IDPs) like the Murias as listed tribals.
Despite the Telangana government's
proactive stance in recommending multiple tribal groups for inclusion, it
appears unwilling to extend the same recognition to the displaced Murias.
Recognizing the tribal status of internally displaced Murias and recommending
it to the central government for parliamentary approval would not be
unconstitutional or objectionable. This is particularly relevant given that the
Murias are already recognized as a Scheduled Tribe in their native state of
Chhattisgarh.
The Telangana government's hesitancy
to address the issue of internally displaced Murias, who number around 50,000,
raises concerns about its commitment to recognizing and safeguarding the rights
of these tribals. Shunning responsibility in this regard is not only a
disservice to the displaced community but also undermines the principles of
inclusivity and protection that the Scheduled Tribe status is intended to
provide. Addressing the situation through proper recognition and inclusion in
the Scheduled Tribe list would be a constitutional and ethical step toward upholding
the rights and dignity of the internally displaced Muria community in
Telangana.
Conclusion
In conclusion, the plight of the
Muria Tribe unfolds a distressing narrative of forced internal displacement and
subsequent marginalization. The intricate web of social, legal, and
governmental challenges they face underscores the urgent need for comprehensive
intervention.
The distinction between voluntary
migration and involuntary displacement is a cornerstone in understanding Murias'
predicament. Unlike voluntary migrants seeking opportunities, the Murias were
compelled to abandon their homeland due to violence, adding a layer of
complexity to their legal status and identity in the new states. Legal
recognition becomes a central issue as the Murias lose their scheduled tribe
status post-migration. Judicial decisions, as seen in the Action Committee
case, seem to grapple with voluntary migration assumptions, potentially leaving
internally displaced persons in a precarious legal limbo. The need for a nuanced
approach that acknowledges the unique circumstances of forced displacement is
apparent.
Systematic oppression, exemplified by
labor exploitation and violence, perpetuates the vulnerability of the Muria
tribe. The Telangana government's reluctance to recognize their tribal status,
especially in contrast to its acknowledgment of other tribes, raises questions
about governmental responsibility and fairness in addressing the specific needs
of marginalized communities.
As we reflect on the constitutional
provisions and potential amendments, it is clear that a concerted effort is
needed to bridge the gaps in legal recognition and ensure the protection of
rights for internally displaced tribal groups. Advocacy remains crucial, urging
both legal and policy reforms that encompass the complexities of involuntary
displacement and safeguard the dignity and well-being of communities like the Murias.
In the broader context, Murias' story
serves as a poignant reminder of the challenges faced by internally displaced
persons and the imperative for a compassionate and just response that upholds
the principles of equality and human rights.
[1] Mamidi Bharat Bhushan, Study on
the Identity & Socio cultural integration of Gutty Koya Tribals in
Jayashankar Bhupalapally, Telangana, Save The Children 23 (2017), https://www.academia.edu/63837986/Identity_of_IDPs_and_Socio_Cultural_Integration_of_Gutty_Koya_Tribe.
[2] Swamy et al., The Fragile
Livelihoods of the Murias in Telangana and Andhra Pradesh 48(4), Social Change 528,
529 https://doi.org/10.1177/0049085718801412.
[3] Thunga Ramesh, Problems and
Prospects of Gutti Koyas 3 The Law Brigade Publishers 100, 101 (2022), https://thelawbrigade.com/wp-content/uploads/2022/12/Thunga-Ramesh-AJMRR.pdf.
[4] Supra note 1 at 5.
[5] Centre for Social Justice, A study on internally displaced persons of
India Mapping and Citizenship Rights 18 (June 20, 2013), https://www.centreforsocialjustice.net/wp-content/uploads/2015/12/A_Study_on_Internally_Displaced_Persons_of_India.pdf.
[6] About Internally Displaced
persons, UNHR, https://www.ohchr.org/en/special-procedures/sr-internally-displaced-persons/about-internally-displaced-persons.
[7] Where the State Makes War On
Its Own People, Camp. for Peace & Just. in Chhattisgarh (2006), https://cpjc.files.wordpress.com/2007/07/salwa_judum.pdf.
[8] 17 Rajya Sabha Deb (15th
Ser.) (2011) 12 (India), https://rsdebate.nic.in/bitstream/123456789/592078/1/IQ_223_03082011_S41_p1_p6.pdf.
[9] Supra note 5 at 19.
[10] Supra note 5 at 19.
[11] Supra note 5 at 20.
[12] Kalpana Kannabiran, Tools of Justice: Non-discrimination and the
Indian Constitution 242 (Taylor & Francis., 1st ed. 2013) (eBook).
[13] Supra note 1 at 41,42.
[14] Supra note 1 at 15.
[15] Ayesha Minhaz, With no place to
call home, the Gutti Koya tribe fights for survival, Frontline, The Hindu (Dec 29, 2022), https://frontline.thehindu.com/social-issues/with-no-place-to-call-home-the-gutti-koya-tribe-fights-for-survival/article66281629.ece.
[16] Id.
[17] GoI Minister of Social Just. &
Empowerment, State wise/UT-wise of Scheduled Tribes in India, 1, 11(2023), https://tribal.nic.in/ST/LatestListofScheduledtribes.pdf.
[18] Supra note 12 at 257.
[19] The Const. (Scheduled Tribes)
Order, 1950, MoL, 40 (1950).
[20] Department of Social Sec., Revision
of the lists of scheduled castes and scheduled tribes 7 (1965), https://tribal.nic.in/downloads/Statistics/OtherReport/LokurCommitteeReport.pdf.
[23] INDIA CONSTI. Art. 342.
[24] Supra note 2 at 528.
[25] Supra note 3 at 107.
[26] Shubhranshu Choudhary, Time to
rehabilitate Gutti Koyas, Telangana
today (June 29, 2022), https://telanganatoday.com/opinion-time-to-rehabilitate-gutti-koyas.
[27] Supra note 1.
[28] Supra note 5.
[29] Supra note 23.
[30]Department
of Social Sec., Revision of the lists of scheduled
castes and scheduled tribes 7 (1965), https://tribal.nic.in/downloads/Statistics/OtherReport/LokurCommitteeReport.pdf.
[31] Department of Social Sec., Revision
of the lists of scheduled castes and scheduled tribes 7 (1965), https://tribal.nic.in/downloads/Statistics/OtherReport/LokurCommitteeReport.pdf
[32] Department of Social Sec., Revision
of the lists of scheduled castes and scheduled tribes 12,13 (1965), https://tribal.nic.in/downloads/Statistics/OtherReport/LokurCommitteeReport.pdf
[33] INDIA CONSTI. Art. 341.
[34] Supra note 23.
[35] Department of Social Sec., Revision
of the lists of scheduled castes and scheduled tribes 14 (1965), https://tribal.nic.in/downloads/Statistics/OtherReport/LokurCommitteeReport.pdf.
[36] Id at 17, 18.
[37] Id at 18.
[38] Supra note 26.
[39] Action Committee on Issue of Caste Certificate to
SCs/STs v. Union of India, (1994) 5 S.C.C. 244 (India).
[40] Marri Chandra Shekhar Rao v. Seth
G.S. Medical College, (1990) 3 S.C.C. 130 (India); S. Pushpa v.
Sivachanmugavelu, (2005) 3 S.C.C. 1 (India).
[41] Supra note 39 at 258.
[42] Migrants, refugees, or
displaced persons, UNESCO (Sep
23, 2021), https://www.unesco.org/en/articles/migrants-refugees-or-displaced-persons.
[43] Mahendra P Lama, Internal
Displacement in India: causes, protection and dilemmas, Oxford Refugee Studies Center (August,
2000), https://www.fmreview.org/accountability-and-displacement/lama.
[44] Supra note 1 at 26.
[45] R.B. Bhagat & Kunal Keshri, Internal
Migration in the Countries of Asia 5,7,9,10 (2020), https://www.researchgate.net/publication/343093233_Internal_Migration_in_India.
[46] Assembly adopts resolution
seeking inclusion of 10 castes in ST list, The Hindu (Feb 10, 2023), https://www.thehindu.com/news/national/telangana/assembly-adopts-resolution-seeking-inclusion-of-10-castes-in-st-list/article66493854.ece#:~:text=Chandrasekhar%20Rao%20stated%20that%20Valmiki,socio%2Deconomic%20conditions%2C%20a%20ST.