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The Road so Far: Forest Rights Act and Constitutionality

It is argued that the Act is a colourable piece of legislation that is outside the legislative competence of the Parliament as it falls under the State List, and therefore, ultra vires the Constitution. The petitioners contend that the forest lands referred to in the Act are more closely associated with the item ‘Land’ instead of ‘Forests’ because it deals with the conversion of forest lands into revenue lands and pertains to rights accrued in and over such land.

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The Road so Far: Forest Rights Act and Constitutionality

By Devashree Pillai and Amrita C

What does the Act cover?

In 2006, the Forest Rights (Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act (hereafter referred to as ‘FRA’ or ‘the Act’) was passed recognising the rights of one of the most marginalised sections of Indian citizenry.1The FRA, for the first time, vested legal rights on the forest-dwelling Scheduled Tribes (STs) and other traditional forest dwellers.

To be recognised as a right-holder under the Act, an individual must demonstrate that they (a) either reside on forests or forestlands or (b) are dependent on forest produce for their livelihoods. Furthermore, not all forest dwellers are eligible for these rights. They must either be recognised as forest-dwelling Scheduled Tribes or must belong to communities that have been dependent on forests for at least three generations (75 years). The latter class are referred to as ‘Other Traditional Forest Dwellers’ (OTFDs).

The FRA grants them the right to secure individual or community tenure (or both) by vesting them with the right to hold and live in the forest land under the individual or common occupation for habitation or for self-cultivation for livelihood; right of ownership, access to collect, use, and dispose of minor forest produce which has been traditionally collected within or outside village boundaries; other community rights of uses or entitlements such as fish and other products of water bodies, grazing (both settled or transhumant) and traditional seasonal resource access; rights in or over disputes lands under any nomenclature in any State where claims are disputed; and the rights of settlement and conversion of all forest villages, old habitation, unsurveyed villages and other villages in forests, whether recorded, notified or not into revenue villages, among others. The rights conferred the Act was heritable, but not transferable or alienable.

The Preamble of the Act recognised that their ‘forest rights on ancestral lands and their habitat were not adequately recognised in the consolidation of State forests during the colonial period as well as in independent India resulting in historical injustice to the forest-dwelling Scheduled Tribes and other traditional forest dwellers who are integral to the very survival and sustainability of the forest ecosystem’.

The Act, therefore,  also enjoins upon the right-holders, the duties to (a) protect the wildlife, forest and biodiversity; (b) ensure that adjoining catchments area, water sources and other ecologically sensitive areas are adequately protected; (c) ensure that the habitat of forest-dwelling STs and OTFDs are preserved from any form of destructive practices affecting their cultural and natural heritage; (d) ensure that the decisions are taken in the Gram Sabha to regulate access to community forest resources and stop any activity which adversely affects the wild animals, forest and the biodiversity are complied with.

Into the Docket

The Act, which entered into force in 2007, was however immediately met with strong opposition from conservation groups that argued that its implementation would lead to deforestation and exacerbate encroachment upon forest lands. In March 2008, a writ petition was filed before the Supreme Court of India by Wildlife First, Nature Conservation Society, Tiger Research and Conservation Trust, and other conservationists, challenging the legality and constitutional validity of the Act on the grounds that the Act was violative of the petitioners’ fundamental rights guaranteed under Article 14 and 21 read with Articles 48A and 51A(g) of the Constitution of India. The other main issues raised were the validity of the process for filing claims under FRA and the due process guarantees set in place while rejecting such claims.

In 2014, the petitioners filed an interlocutory application, requesting the Court to order States to evict illegal forest dwellers.

The next major development in the case came on 13 February 2019, when the Supreme Court passed an order directing 21 states to evict illegal forest dwellers whose claims over these lands had been rejected by the authorities.2 The states of Andhra Pradesh, Assam, Bihar, Chhattisgarh, Goa, Gujarat, Himachal Pradesh, Jharkhand, Karnataka, Kerala, Madhya Pradesh, Maharashtra, Odisha, Rajasthan, Tamil Nadu, Telangana, Tripura, Uttarakhand, Uttar Pradesh and West Bengal had submitted status reports on the rejection of these claims. In Manipur, where the verification/reverification/review process was pending, the Court directed the Forest Survey of India (FSI) to make a satellite survey and place on record the encroachment positions and to also state the positions after the eviction as far as possible.

Noting that no evictions had been carried out despite rejection of claims, the Supreme Court stated that ‘Once the orders of eviction have been passed, the eviction ought to have taken place… Let action be taken on or before next date.’ This eviction order would have impacted over 1 million forest dwellers who lived on forest lands across the country.

In response to the 13 February order, the Ministry of Tribal Affairs sought an urgent hearing seeking modification of this order requesting the Court to direct states to file detailed affidavits on the procedure followed while examining claims and details on why claims were rejected. The Centre pleaded that it couldn’t ascertain whether due process had been followed and all appeal mechanisms exhausted in cases where the claims had been rejected. It was also stressed that the Act did not envisage any provision for eviction if an individual’s claim for land was rejected.

On 28 February 2019, the Court passed a stay on its previous order while directing the states to produce affidavits detailing the procedures adopted by their respective authorities in rejecting claims filed under the FRA. The Court, however, noted the Centre’s delayed response in seeking to modify the order given that the exercise for seeking details of the rejection of claims and the follow-up action taken by the States was undertaken by the Court in 2016.4 Keeping in mind the possibility of illegal encroachment upon forest lands, the Court also directed the states to ‘point out the category wise details of such incumbents who have been occupying these areas belonging to Scheduled Tribe category and OTFD category and such persons who cannot be treated as Tribals’. The order also directed the FSI to undertake a satellite survey and place on record the encroachment positions before its next hearing. The petitioners had opposed this plea for stay contending that the rights of those claimants who had already been granted pattas would not be impacted by the 13 February eviction order.

In a latter hearing, the Court sought feedback from all states on what procedure must be established for the processing of claims over the forest lands before it proceeds further with the case.5 The FSI notified the Court that a complete survey would require at least 16 years to be completed without additional resources and would require permission to perform the survey by all States and Union Territories.

By September 2019, two of the main petitioners, the Wildlife Trust of India and the Bombay Natural History Society, had withdrawn their petitions in the case, while the Forest Survey of India had been added by the Court as a party to the case. Several new NGOs and Adivasi groups parties have also been made parties to the case

The matter remains pending before the Supreme Court with it being lasted listed on the Court’s cause list on 22 January 2020.6 It is notable that the legal proceedings have effectively narrowed down to the matter of evictions and due process, though it remains to be seen whether the court will address the broader question of constitutionality when the matters come before it again.

The question remains: is the Forest Rights Act constitutionally valid? To surmise the main contentions in the original writ petition, the constitutional validity of the Act is questioned based on the following:

1. The legislative competence of the Parliament to pass the FRA

The petitioners’ contention is that the subject covered by the Act is right in and over the forest land and the conversion of forest land into revenue land. It is argued that the Act is a colourable piece of legislation that is outside the legislative competence of the Parliament as it falls under the State List, and therefore, ultra vires the Constitution. The petitioners contend that the forest lands referred to in the Act are more closely associated with the item ‘Land’ instead of ‘Forests’ because it deals with the conversion of forest lands into revenue lands and pertains to rights accrued in and over such land.

The writ petition contends that the ‘pith and substance’ of the Act deals with the Item 18 ‘Land’ that falls under List II of Schedule VII of the Constitution (the State List) and not under Item 17A ‘Forests’ under List III of Schedule VII (the Concurrent List). Item 18 of List II is stated as ‘Land, that is to say, rights in or over land, land tenures including the relation of landlord and tenant, and the collection of rents; transfer and alienation of agricultural land; land improvement and agricultural loans; colonization’, while Item 17A only states ‘Forests’.

To glean the correct understanding of the law, by determining the intention of the legislature, courts use these cardinal rules of statutory interpretation: Literal Rule (the text is interpreted in its natural or ordinary meaning), Golden Rule (where adopting the literal rule may lead to injustice or absurdity, the courts modify the meaning to the extent of such injustice or absurdity caused and no further so as to prevent unintended objects from coming to fruition), and the  Mischief Rule (also known as the purposive rule, wherein the court examines the purpose for the enactment of a statute, i.e., the mischief it sought to remedy and the remedial course laid out by the said statute).

In Union of India v. Shah Gobardhan L. Kabra Teachers’ College (2002), the Supreme Court held that in order to examine the true character of the enactment, (i.e. the ‘pith and substance’) the entire Act, its object and scope is required to be gone into.7 In Bhatia International  vs. Bulk Trading (2003), it was held that where multiple interpretations are possible, the one that supports the legislative intent should be adopted.8 Furthermore, in Kashi Prasad Saksena v. State of Uttar Pradesh (1967), the apex court held that while ‘the preamble cannot be used to defeat the enacting clauses of a Statute, it has been treated to be a key for the interpretation of the Statute’.9 Therefore, the preamble of an Act can be used to glean the intent of the legislature.

The preamble to the FRA clearly states it be ‘an Act to recognize and vest the forest rights and occupation in forest land in forest-dwelling Scheduled Tribes and other traditional forest dwellers who have been residing in such forests for generations but whose rights could not be recorded; to provide for a framework for recording the forest rights so vested and the nature of evidence required for such recognition and vesting in respect of forest land.’ Furthermore, the preamble also explicitly mentions the ‘mischief’ the Act seeks to remedy: ‘AND WHEREAS it has become necessary to address the long-standing insecurity of tenurial and access rights of forest-dwelling Scheduled Tribes and other traditional forest dwellers including those who were forced to relocate their dwelling due to State development interventions’

It must also be noted that section 4(4) states that the titles granted under FRA while heritable is not alienable or transferable. This also indicates that the right of ownership and right of land granted under the Act is also not alienable or transferable. However, where it was found to be necessary to record every conversion of forest village to revenue village to ensure the security of the new legal status, the specific method for it has been left to the State-level Land Revenue laws. Therefore, to the extent that any implementing measures under the Act would infringe upon State powers, the Act leaves it to the State legislature to enact upon. Furthermore, Article 339(2) of the Constitution states that the executive power of the Union shall extend to the giving of directions to a State as to the drawing up and execution of schemes specified in the direction to be essential for the welfare of the STs in the State.

The contention of the petitioners is that ‘Forests’ under List III only pertains to the protection and preservation of forests. Even in the event that this interpretation is accepted, it must be noted that the Supreme Court in its previous judgement in Orissa Mining Corporation vs. Union of India and Ors (2013) has observed: ‘… we have realized that forests have the best chance to survive if communities participate in their conservation and regeneration measures. The Legislature also has addressed the long-standing and genuine felt need of granting a secure and inalienable right to those communities whose right to life depends on the right to forests and thereby strengthening the entire conservation regime by giving a permanent stake to the STs dwelling in the forests for generations in a symbiotic relationship with the entire ecosystem… Legislative intention is, therefore, clear that the Act intends to protect custom, usage, forms, practices and ceremonies which are appropriate to the traditional practices of forest dwellers.’10

In any case, the ‘pith and substance’ of the Act is not the conversion of such lands into revenue villages but instead to ensure that the forest rights of the FDST and OTFD are recognised and duly vested upon. It has been officially clarified vide Ministry of Tribal Affairs’ circular dated 08.11.2013 to all state governments and union territories that the conversion of forest villages et al., into revenue villages under s 3(1)(h) is not a precondition for the recognition and vesting of forest rights.11

2. The Wildlife (Protection) Act of 1972 and the FRA

The petitioners contend that the Wildlife (Protection) Act, 1972 enacted by the Parliament with the specific purpose of protecting endangered fauna and flora and its environment, being a special law would trump the FRA which is a general law. The petitioners argue that the 1972 Act provides a complete machinery for settlement of rights pertaining to peoples living within the Protected Areas and that the FRA attempts to circumvent the laws in force under the earlier legislation. The petitioners also claim that the conditions specified under section 4(2) that provides for special measures for the establishment of critical wildlife habitats are too onerous, making resettlement impossible in practice.

Another rule of statutory interpretation is that the general yields to the specific. While the Wildlife Act is specific to the protection of endangered fauna and flora, the provisions of the FRA on the rights of traditional forest dwellers are specific provisions despite being a general law on the subject of protected areas and/or wildlife. In Justiniane Augusto De Piedade Barreto v. Antonio Vicente Da Fortseca (1979), the Supreme Court observed that a law that is essentially general in nature may contain special provisions on certain matters and in respect of these matters it would be classified as a special law.12

However, it is not to say that the FRA by virtue of being a later general law with specific provisions would automatically negate the provisions of the Wildlife Act. In Maharaja Pratap Singh Bahadur v. Man Mohan Dev (1966), the Supreme Court held that a general, later law does not abrogate an earlier special one by mere implication.13 However, this should be read with the court’s observation in R S Raghunath v. State of Karnataka (1991), where it was clarified that there should be a clear inconsistency between the two enactments before giving an overriding effect to the non-obstante clause but when the scope of the provisions of an earlier enactment is clear the same cannot be cut down by resort to the non-obstante clause.14

The non-obstante clause in section 4(1) of the FRA allows it to supersede all pre-existing applicable laws on the matter, limiting the vested rights only through the provisions set out under the FRA itself. In section 4(2) the Act addresses the issues of critical wildlife habitats and envisions the creation of ‘inviolate areas of wildlife conservation’ where once the process of recognition and vesting of rights have been completed, it has been established by the concerned agencies of the State government under the Wildlife Act that the activities or impact of the presence of holders of rights upon wild animals is sufficient to cause irreversible damage and threaten the existence of said species and their habitat. Therefore, the dichotomy between the two pieces of legislation is fallacious and there is no clear inconsistency.

In the event that the FRA is seen as a general law, the apex court in Maya Mathew  v. State of Kerala (2010) has noted that it is a well-settled rule that where a clear intention to make a rule of universal application by superseding the earlier special law is evident from the later general law, then the later, general law, will prevail over the prior special law.15

In 2018, the Ministry of Tribal Affairs issued a clarification on its guidelines for determination and notification of Critical Wildlife Habitats within National Parks and Sanctuaries under the FRA.16 The circular notes that the guidelines will serve the purpose of harmonising the provisions of the FRA vis-à-vis the Wildlife Protection Act. The guidelines envisage the creation of an expert committee consisting of the respective Chief Conservator of Forests, Ministry representative, social scientist, experts on life sciences, Panchayat presidents, and the officer-in-charge of the National Park/Sanctuary, who are mandated with the power to identify inviolate areas based on relevant scientific and objective criteria. They also required to hold wide and open consultations with all relevant stakeholders, including discussions on resettlement plans before the recommendation is made to the State. In determining a Critical Wildlife Habitat, current pressures and future demands are also taken into account, including present and future levels of human-wildlife conflict, and discussed with the local communities to evaluate the long term viability of residing and earning their livelihoods within such proposed CWH. Ultimately, the guidelines empower the Expert Committee to take a scientific and objective decision on such designation.

3. The constitutionality validity of the FRA vis-à-vis Article 21 read with Articles 48A and 51 A (g)

The petitioners also argue that the ‘indiscriminate commercial extraction or collection of minor forest produce’ within an area declared as a national park or sanctuary would be against public interest and therefore violative of the petitioners’ fundamental rights guaranteed under Article 21 read with Articles 48A and 51 A (g) of the Constitution. The petitioners claim that their fundamental right to a clean and unpolluted environment under Article 21 has been infringed upon. Articles 48A enjoins the state to endeavour to protect and improve the environment and to safeguard the forests and wildlife of the country and Article 51 A(g) refers to the fundamental duty of a citizen of India to protect and improve the natural environment and have compassion for all living creatures. The petitioners allege that the Act goes against the doctrine of public trust and sustainable development. The doctrine states the principle that certain natural and cultural resources are preserved for public use, and that the government owns and must protect and maintain these resources for the public’s use.17

It is also contended that the assumption that FDST and OTFD have not been able to record their rights despite residing in forests for generations is ‘unfounded ad not supported by any scientific data or examined by experts or based on any credible report’ making it an arbitrary exercise of power. However, this argument has been addressed by the Supreme Court in the aforementioned Orissa Mining Corporation judgement.18 The same judgement also recognised and acknowledged the crucial role played by the forest-dwelling communities in the protection, preservation, and management of its natural resources. Therefrom, it can be surmised that the enactment of the FRA does in fact reflect the State’s effort to protect and improve the environment and to safeguard the forests and wildlife of the country. It is. Thus, in furtherance of the State’s duty under the public trust doctrine and follows the principles of sustainable development.  This construction also supports the legislative intent to protect the fundamental rights of the forest-dwelling tribes of India.

It must also be noted that Article 46 provides that the State must promote with special care the economic interests of the STs and to protect them from all forms of exploitation. In Re Education Bill (1951), the Supreme Court held that in interpreting fundamental rights, directive principles must be given due consideration.19 And later in Qureshi v. State of Bihar (1958), the court also held that directive principles must be implemented only in such a way that it does not infringe upon fundamental rights.20

In ML Kamra v New India Assurance (1992), the Supreme Court noted that it ought not to interpret the statutory provisions, unless compelled by their language, in such a manner as would involve its unconstitutionality, since the legislature of the rule-making authority is presumed to enact a law which does not contravene or violate the constitutional provisions.21 Therefore, there is a presumption in favour of the constitutionality of a legislation or statutory rule unless it ex facie violates the fundamental rights guaranteed under Part III of the Constitution. If the provisions of a law or the rule are construed in such a way as would make it consistent with the Constitution and another interpretation would render the provision or the rule unconstitutional, the Court would lean in favour of the former construction.

The Ministry of Tribal Affairs (2019) also clarified its position that the FRA only recognises pre-existing rights which are already being exercised by the eligible persons; other than securing tenure, no new rights are being created that would affect ecologically sensitive areas.22 Furthermore, where the exercise of such rights has the potential of causing irreversible damage to the wildlife, the Act envisages the creation of Critical Wildlife Habitats with ‘inviolate areas for wildlife protection’ through a democratic and transparent process after the recognition of rights under FRA have been completed. The basic premise of the FRA was that forest-dwelling communities are integral to the very survival and sustainability of forest ecosystems. While previous legislations have sought to compensate and thereby extinguish these rights, the FRA aims to recognise and vest these forest rights in a sustainable manner.

4. Due process guarantees and natural justice principles

The petitioners argue that the Gram Sabha is ‘incompetent, untrained and unsuitable for determining the nature and extent of individual or community forest rights’ as they involve an element of adjudication and appreciation of evidence, maps, documents, consideration of Courts and recording of evidence, which are quasi-judicial functions. It is also argued that granting the power of vesting the rights to the Gram Sabha whose members may have the interests in the claims being considered is violative of principles of natural justice and arbitrary. They claim that section 6 of the FRA is unconstitutional since the Forest Rights Committee elected from the Gram Sabha cannot be conferred the authority to determine the nature and extend of individual or community forests rights of forest-dwelling STs and other traditional forest dwellers.

Similarly, the petitioners also argue that the Sub-divisional Level Committee (SDLC) and District Level Committee (DLC) is ‘illegal, arbitrary and against all principles of justice’. It is also contended that making the decision of the DLC on forest rights final and binding is unconstitutional. It is argued that since the authorities comprise of officers of the revenue, forests and tribal affairs and appeal or petition can be filed only by a person aggrieved by a resolution passed by the Gram Sabha, there is no authority or agency to represent the case of State or to counter the claim put by a member of the Gram Sabha claiming possession the forest land.

The primary tenet of a direct participatory democracy is that the people who are governed are, as directly involved in their governance as possible. The Panchayati Raj system is a reflection and manifestation of this objective. Schedule XI of the Constitution lists the functional Items that come under the purview of the Panchayat and Item 21 under it relates to ‘welfare of the weaker sections of the in particular of the schedule caste and schedule tribes.’ The petitioners’ contention on the inadequacy of the Gram Sabha, the lowest tier of this participatory democracy, in determining and fulfilling its quasi-judicial function does not give due credence to the decades of progress in this area. Though advancements have admittedly been staggered, the solution to a more effective governance is most certainly not through further disenfranchisement of their rights. This is especially relevant as one of the main issues that plagued the protection of the rights of forest dwellers was the muffling of their voices when it came to forest resource management.

In order to address the implementation challenges in the enforcement of the FRA, the Ministry of Tribal Affairs issued guidelines and communicated them to all the States and Union Territories in 2012.23 It should be noted that the original writ petition predates the guidelines; in that interval, the FRA regime has developed more procedural details on the processing and verification of claims.

The guidelines require that officials of the Forest and Revenue departments remain present during the verification of the claims and the evidence on the site. The guidelines give a claimant whose claim has been modified or rejected, a reasonable opportunity to present his case. The procedural safeguards put in place include scenarios where the Grama Sabha decision is found to be incomplete or prima facie requires additional examination, the Sub-Divisional Committee is empowered to remand the claim to the Gram Sabha for reconsideration. The guidelines require that decisions be accompanied by speaking orders and claims be rejected only for valid reasons duly recorded.

Furthermore, the Supreme Court in the Orissa Mining Corporation case has also noted that the procedure to be followed and the process of verification of claims have already been elaborately dealt with in the Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Amendment Rules 2007 read with the 2012 Amendment Rules24 and observed the centrality of the Gram Sabha in ensuring that the objectives of the Act are met, including the determination of community rights.25 Furthermore, Rule 3(3) of the 2007 Rules explicitly states that a person whose claim is being considered cannot be part of the Forest Rights Committee adjudicating upon his claim and Rule 4(4) requires that the Gram Sabha be provided with the necessary assistance by the authorities in the State. It should also be clarified that the decision of the DLC, while final when it considers and approves the claims and records of forest rights prepared by the SDLC, the Rules also provide a claimant aggrieved by the SDLC decision the opportunity to be heard before the DLC before the final decision is made. This is in line with the legislative intent to provide the forest dwellers with the most opportunity to present their claims at the local level while also providing access to appeal mechanisms that remain readily accessible to them.

5. Alleged arbitrariness in granting similar rights to FDST and OTFDs

The petitioners contend that the Act is also unconstitutional to the extent that it equates forest-dwelling STs with OTFDs, and thereby treating unequals, equally. The petitioners claim that this is violative of the principle of equality enshrined under Article 14 of the Constitution.

While the criteria used to designate tribes as Scheduled is not explicitly mentioned in the Constitution, the Ministry of Tribal Affairs vide circular dated 28.12.2017 notified the specification of a community that is categorised as a Scheduled Tribe: (i) indications of primitive traits, (ii) distinctive culture, (iii) geographical isolation, (iv) shyness of contact with the community at large, and (v) backwardness.26

The Forest Rights Act lays down very clear requirements for an OTFD and states that a claimant/community would be eligible as an OTFD only when they can fulfil the following conditions:

  1. Primarily resided in forests or forests lands for three generations (or 75 years) prior to 13-12-2005, i.e., since 1930, and
  2. Depend on the forest or forests land for bona fide livelihood needs.

The phrase ‘primarily resided’ does not mean occupation nor does the law require proof of 75 continuous years in the same village as the burden of proof would be too onerous and would defeat the purpose of the law. Bonafide livelihood needs do not mean mere survival but refer to the fulfilment of livelihood needs of self and family through the exercise of any of the rights mentioned under the FRA. The law does not envision a primary livelihood dependence on forests for this purpose.

The Preamble of the Act itself recognises that ‘the forest rights on ancestral lands and their habitat were not adequately recognised in the consolidation of State forests during the colonial period as well as in independent India resulting in historical injustice to the forest-dwelling Scheduled Tribes and other traditional forest dwellers’. The apex court in Orissa Mining Corporation has characterised the FRA as a remedial statute that seeks to address this injustice.27 Therefore, it would be incorrect to conclude that the treatment of OTFDs on the same footing as the STs is in any way contrary to the right to equality enshrined under the Constitution.

Conclusion

As previously stated, the Supreme Court in Orissa Mining Corporation has explicitly recognised the role played by communities in conservation and regeneration measures.28 Thus, the conservationist argument must also grapple with the proven and accepted benefits of community-based forest management. The work of Nobel Laureate Elinor Ostrom has shown that community-based natural resource management not only supports livelihoods but is also ecologically sustainable.29 Researchers have shown that with secure rights, local communities can conserve resources and prevent environmental degradation.30

The study conducted on the governance challenges faced in the implementation of the FRA can provide valuable insights towards solving this false dichotomy between securing the rights of the forest dwellers and conservation efforts.

AUTHORS

Devashree Pillai, Consultant, Disaster Management, Crisis Management Branch, Policy and Program Division, United Nations Environment Program, Geneva

Amrita C, Research Associate, Azim Premji University, Bangalore

Featured photo by Punid Ramesh on Unsplash

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