South Asian Rеgion’s Rohingya

Critical Analysis of the South Asian Rеgion’s Rohingya Crisis: Indian Senerio

Research Reinforcement, A Peer Reviewed International Refereed Journal, ISSN 2348-3857

Vol. 8, Issue 2, November 2020 -April 2021, pp. 66-73

Dr. C.P. Gupta

Head and Associate Professor, Department of Law, Apex University, Jaipur (Rajasthan)

Dr. Monika Mishra

Assistant Professor, Department of Law, Apex University, Jaipur (Rajasthan)

Abstract

Rohingya are a community which belongs to the Rakhine state of Myanmar, they are at presently facing one of the biggest crises of the world and that is displacement from their place of origin. This all began during the exodus that took place during 1970’s and later 1991-92 wherein a large amount of the people from the community flee from Myanmar and settled in various countries like Bangladesh,Thailand, Malaysia and later on India due to high degree of violent behavior with the Rohingya Muslims from Myanmar have been facing the crisis of being stateless since the past 35 years. Due to lack of recognition in their own state the refuges started taking asylum in various neighboring countries such as Bangladesh, Thailand, Indonesia and then India. Initially Bangladesh welcomed the Migrants, later due to lack of support from the Bangladesh government, refugees looked for asylum in the country of Thailand wherein they were provided with food, medicines etc. but were not given access to land and property. Then again in search for shelter they reached the shores of Malaysia where they expectedto get food water and shelter as it was a Muslim country too but couldn’t get shelter, and later on with Indonesia by the time the government declared their entry illegal, thousand had already formed their shelters over there.[1] Rohingyas started to immigrate to India after the 2012 Rakhine state riots in Myanmar. At present round 40,000 Rohingya Refugees continue to live in India illegally and is increasing with years.[2]

Keywords: Rohingya Crisis, Recognition, Refuges, Shelter

Introduction

Rohingyas are the most persecuted ethnic minority in the world stated by the United Nations. They are a group of Burmese Muslim people from Rakhine state in Myanmar situatedon the western coast of Myanmar adjacent to the Bay of Bengal in the Indian ocean. In Myanmar, they are seen as “illegal immigrants” by the Buddhist and other communities. Rohingyas have continuously faced persecution, discrimination,mistreatment, massacre, and statelessness over the past four decades. Facing ethnic cleansing in Myanmar, Rohingyas have Led to various countries in the World. This article analyzes Rohingyas’ struggle for life and liberty in India from both humanitarian and legal perspectives. It examines the causes of resentment against the refugees in India. Minorities are often subjected to discrimination by the state or government and forced to live bare lives in society. Since the independence of Myanmar (1948), different minority groups have experienced conflicts and violence. Rohingyas reside in the north-western Rakhine (Arakan) state of Myanmar, one of the stateless ethnic com munities who face the worst challenges in Myanmar. In Myanmar, they are seen as illegal immigrants” by the Buddhists as well as other communities. After the concept of “citizenship was redefined in Burmese Citizenship Law 1982,

Rohingyas became noncitizens overnight, having their NRC (National Registration Card) replaced by the FRC (Foreign Registration Card). Their situation has been exacerbated by riots, conflicts, and discrimination, including the 2001 anti-Muslim riots and 2016 Rohingyas persecution. Persecution against Rohingyas was termed as “ethnic cleansing” or “genocide” by the United States Secretary of State Rex Tillerson and French president Emmanuel Jean-Michel Frederic Macron. After each massacre, Rohingyas fled to the neighboring countries such as Bangladesh or India. According to UN Refugee Agency (UNHCR), 723,000 Rohingyas have led to Bangladesh since 25 August 2015. Some of them have migrated to India via Bangladesh. Rohingya are a community which belongs to the Rakhine state of Myanmar, they are at presently facing one of the biggest crisis of the world and that is displacement from their place of origin. This all began during the exodus that took place during 1970’s and later 1991-92 wherein a large amount of the people from the community flee from Myanmar and settled in various countries like Bangladesh, Thailand, Malaysia and later on India due to high degree of violent behavior with the community in the form of rapes, mass killings, destroying their properties, religious places like Mosques etc. This oppressive attitude led to the migration of these people in large numbers. Later on, Myanmar refused to accept these Rohingya Muslims as their citizens, by formulating a new citizenship law in 1982[3]which stated categories in order to claim citizenship, ofwhich none of the categories gave Rohingya the status of citizen. Even if under one category they could claim, they were not educated enough to realize that. The largest number of Rohingya refugees at present is settled in the Cox Bazaar[4] area of Bangladesh at the border, this wide influx of refugees has also affected the relations between Myanmar and Bangladesh which has gone for a toss, due to variety of problems that Bangladesh is facing internally as well as due to refusal of Myanmar in accepting boat people[5] as their citizen.

India at present is not signatory of any of the refugee convention by UN, or the one which was discussing about the status of refugees. regards to Rohingya almost 40,000 Rohingya[6] at present are residing in India which are regarded as Illegal migrants by the Foreign National’s Act 1946[7], which comes under central legislative bodies. Even though India has been a country providing refuge than one giving them out, it does not have a set framework for refugees, as to how they should be governed. The way India deals with refugees is usually on an ad hoc basis or case to case, this leads to discrimination as countries who are important India or are beneficial to it there are refugees are given preferential treatment,⁹ by giving stake in properties etc., whereas on the other hand when they talk about Rohingya, the Indian ministries are fighting case in The Supreme Court for deportation of Rohingya and as they are seen as a major threat to the population as are easy targets to the terrorist groups.

Historical Background

There’s a popular Muslim saying during the beginning of the crisis that goes as: “If the Burmese army sees a Muslim in the village, he is an alien; if he is fishing on the river, he is a smuggler and if he is working in the forest, he is an insurgent” The terms Ethnicity, Identity and Nationality are generally understood to mean the following:

• Ethnicity: It is related to membership of a particular racial, national, or cultural group and observance of that group’s customs, beliefs and language.
• Identity: The Cambridge English Dictionary defines identity as related to a person or the qualities of a person or group that makes them different from others. In reality, what people perceive as ‘identity’ matters much more than definitions.
• Nationality: It confers the official right to belong to a country. It is also used in relation to a group of people of the same race, religion, traditions etc. This right is enshrined in law of the land, usually in conformity with international conventions:

However, peoples’ understanding of these terms are conditioned by ethnic affinities, cultural, religious and historical experiences of the community and their socio-political interactions with other ethnic communities. Often, this gives rise to prejudices and friction between communities fanned by religious and ideological obscurantism. Rohjngyas of Myanmar have been called “the most persecuted people on earth” ever since over 600,000 of them fled their homes to neighbouring Bangladesh to escape persecution at the hands of the army and Buddhist fringe elements August 2017 onwards. Rohingya community has been chosen for this case study as their plight has all the ingredients that cause ethnic conflict not only in Myanmar, but in many other multi-ethnic societies. Geographically, Indian subcontinent is the peninsular region of South -Central Asia bound by the Himalayas in the north, the Hindu Kush mountains in the west and the Arakan mountains (in Myanmar) in the east. The region is home to over 1.7 billion people of different religions, ethnicities, nationalities and identity groups speaking a variety of languages and myriads of dialects. The British East India Company, which entered Indian subcontinent in 1600, had established control over three provinces of Madras (now Chennai), Bombay (now Mumbai) and Calcutta (now Kolkata) by 1708. After defeating the Burmese rulers of Konbaung dynasty in the First Anglo Burmese War (5 March 1824 to 24 February 1826), the British gained control of Assam, Cachar (now part of Assam state) and Jaintia (now part of Meghalaya state) in India and Arakan (now Rakhine state) and Tenasserim in Burma. Burma was placed under a separate colonial authority from 1824 onwards till 1948, when Burma gained independence.

Overview

The Rohingya is a predominantly Muslim ethnic group living in the Arakan State of western Myanmar. Section 3 of the Burma Citizenship Law, 1982 provided: “Nationals such as the Kachin, Kayah, Karen, Chin, Myanmarn, Mon, Rakhine or Shah and ethnic groups as have settled in any of the territories included within the State as their permanent home from a period anterior to 1185 B.E., 1823 A.D. are Myanmar citizens.” So the Rohingras were excluded by this Act as a citizen of Myanmar. This actually made them Stateless as per the 1954 Convention Relating to the Status of Stateless Persons. At present Myanmar has about 800,000 stateless Rohingyas, without access to basic healthcare or education. Rohingya are a community from the state of Rakhine, who have been facing a lot of oppression since the last 30 years beginning from 1978 Dragon king’s operation[8] wherein the Burmese army committed widespread rapes, mass killings[9], destruction of Rohingya Muslims religious properties like Mosques[10] and other religious persecution. In the year 1991-1992[11]approximately 250,000 Rohingya Muslims due to oppressive conditions, discrimination, violence and forced labor practices fled from the state of Myanmar seeking refuge in various countries like Bangladesh. Then in the year 2001, there was a situation of communal violence between Muslim and Buddhist populations in Sittwe(  wherein a lot of Muslim population was killed and their properties destroyed. Then in the Amnesty International) year 2008-09 (Equal rights Trust 2012)authorities of state of Thailand pushed back various boats of the refuges back in the sea which led to weeks of lack of food, water and lack of transportation for the community.

Struggle for Life and Liberty: Rohingyas in India

Rohingyas started to immigrate to India after the 2012 Rakhine state riots in Myanmar. They dispersed in several states like Jammu Kashmir, Delhi, Uttar Pradesh. On 9 August 2017, Minister of State of the Ministry of Minority affairs in India, Kiren Rijiju addressed in the Parliyament that 40,000 Rohingyas are living illegally in the country and insisted on the deportation of the illegal immigrants from India. The state has denied to give the Rohingyas the status of refugees and continuously portrayed them as “illegal immigrants.” A refugee used to be a person driven to seek refuge because of some act committed or some political opinion held.

Well, it is true we have had to seek refuge; but we cotnmitted no act, and most of us never dreamt of having any radical political opinion.” According to the 1951 Refugee Convention by the UN, refugees should have fundamental rights such as non- discrimination (Article 3), freedom of religion (Article 4), right to work (Article 17), and right to education (Article 22). Rohingyas got attention in India when the Indian government announced to deport seven Rohingyas back to Myanmar and announced the plans to deport all the illegal foreign nationals including the Rohingya people who are registered with the UN Refugee Agency(UNHCR). Currently, 16,500 Rohingyas have the refugee identity card given by UNHCR; however, they are considered “illegal immigrants” by the government officials of India. Historically, because of polite and welcoming nature, India is regarded as the safest place for aliens, mainly from neighboring countries like Bangladesh. According to Meenakshi Ganguly, director of Human Rights Watch in South Asia, “The Indian government has disregarded its long tradition of protecting those seeking refuge within its borders.”

Rohingyas in India: Victims or Illegal Immigrants?

In India, the Rohingya are viewed from two opposite perspectives, the rest as “victims” and the second as “illegal immigrants”. In 2014, the independent newspapers (e.g., Anandabazar Patrika, the Hindu) often reported the increasing number of Rohingyas trying to cross the international border of India-Bangladesh arrested by the police to protect the internal security. The Anandabazar Patrika associated Rohingyas with the Bodh Gaya blasts and Khagragarh blast in Bardhaman in 2014. The solidarity expressions of separatist groups (e.g. Al- Qaeda’s offshoot, Aqa Mul Mujahideen or Arakan Rohingya Salvation Army (ARSA), Jaish-e- Mohammed (JeM) and Lashkar-e-Taiba (LeT)) in favour of Rohingyas create uncertainty of identities in the region. These are some basic reasons that cause the Indian government to view Rohingya refugees as “illegal immigrants” and “threat to the national security.”

Having been active in India since 1982 with the motive of ^t‘leave no one behind”, UNHCR promotes the protection and inclusion of refugees into existing national services such as health and education. However, Rohingyas in India have no identity documents and certificates that help them to get national services. Moreover, they are living in poverty, health inconvenience and lack of employment. As mentioned above, India does not have any legal framework and national refugee status determination system, as a result, UNHCR has been making efforts to claim refugee status for the hitherto “illegal immigrants” in India. By the end of December 2014, 25,865 refugees had registered with UNHCR India. “Human rights are the simple rights granted to each character equally with none distinction. far considered as a universally acknowledged well known of behaviors. The violation of those standards through the kingdom gives rise to a situation that creates refugees. Refugees with the aid of definition are the victims of human right violation.” (Okiemute, 2017, p-126) The following section discusses the causes of resentment towards refugees in India. From ancient to medieval and medieval to modern, Indian history is full of migration events and examples of hospitality for migrants. In the time of partition of India (1947), India opened the door for millions of migrants or refugees for a specific time period and welcomed them to the country. However, resentment has thrived for years against illegal immigrants and refugees in India. Residents were accusing outsiders of stealing their jobs, grabbing the lands, involving in the small crimes in the state, that’s the root where the resentment was started being born in the society and conflict reported between the groups. Initially, irritation was seen in North-eastern India, especially in Assam. In Assam, the perceptible changes in the demographic pattern of the state led by the remarkable influx of people from Bangladesh threaten to reduce the Assamese people to a minority in their own state. This is the reason behind the resentment of the Assam Students Movement called “All Assam Student’s Union” or “AASU” against the illegal immigrants. From the perspective of the racialization of refugees, increasing terrorist attacks in the region creates many kinds of doubts and questions regarding the  security threat as well as the national security of any country. There are several catalysts involved directly or indirectly that lead to the radicalization of refugees such as stigmatization, segregation, alienation, and marginalization by the host countries could be one of the cause for radicalization among the refugees, for instance, Rohingyas in India formed as “illegal”, or “terrorist” may lead to the radical activities to express their resentment against the state. The feeling of “we” and “them” is the preparatory boundary to make a distinction between peoples often caused the distance between two communities and segregate them from each other. Government policies of the exclusion of the refugees in the society, exaggeration or less attention of refugees issues through the media, the difference between the status of refugees in the state, worst treatment of refugees and less assistance often works as a catalyst for refugees. Finally, an increasing number of refugee populations over the population of the region often causes conflict with the others in society. For example, some people criticized the issue of “illegal immigration” that the state government of Assam and the central government of India should take measures to stop the continuous own of immigration to Assam. Otherwise, it will jeopardize the demographic situation of the state and will arise more clashes with the ethnic communities of Assam. The large scale immigration had brought a change in the political, economic and social structure in Assam. The social and economic impact of a large number of refugees within a territory of the host developing countries may cause a resentment without much nancial support of international organizations as well as a regional government.

The Rohingya Crisis is one of the biggest issues in the south Asian region, wherein this particular community is facing a huge amount ofoppression, adversities and are living miserable lives to an extent that their origin country is not ready to accept them as citizens and they are being treated as outsiders  or illegal foreigners in their  native land. Also, the fact that they are seeking refuge in foreign lands due to fear of persecution in their native state. They are irrespective of whether countries have signed conventions for refugee protection or not and also countries of Myanmar and Bangladesh should come together and solve the issue rather than putting the burden on each other. With regards to India, even though the country accepts a large number of refuges and under international human rights conventions takes care of their protection still India has to remove its ad hoc policy and treating refugees on case to case basis and should adopt a uniform framework taking into consideration united nation convention[12] on refugees, European convention[13], Bangkok convention[14] in order to safeguards rights of all kinds of refugees without any discrimination, whether it be Rohingya or anybody else by taking cue from policy of minimum standards of treatment, right to repatriation as well as protection of their human rights. History may be repeating itself in Myanmar. For many years, the country’s internal political struggle between the military regime and the pro-democracy supporters divided the international community: the West led by the US adopted isolation and sanctions policy towards Myanmar, while Myanmar’s neighbours including India and ASEAN maintained constructive engagement. When the Myanmar military regime decided to take the path of democratisation and the country witnessed its first elections in 20 years, both the West and Myanmar’s neighbours claimed their policies have worked in bringing about change in the country. Academic debate continues on whether the “isolationist” or the “constructive” strategy was more effective. Meanwhile, the West led by the US has been increasingly taking a hard position against the Myanmar government over the Rohingya issue, while Myanmar’s neighbors including India and ASEAN have taken a constructive engagement. The international community may be entering into another phase of international divide. If  history is any indication, at best, this will end up with claims and counterclaims over which strategy was more effective. Meanwhile, the international divide only makes things more difficult for anyone to help those suffering from conflicts. So far, the Indian approach towards the Rohingya crisis has been viewed as contradicting its traditional position on refugees. As the Rohingya crisis unfolds, there is still a lot that India can do to facilitate the finding of long-term solutions. These actions will be key in determining India’s regional and global standing. Minister Swaraj’s Myanmar visit suggests that Delhi is committed to remain an active partner in ending the crisis, but this is only the beginning of what India can and must do. As a rising power with global aspirations, and with a long tradition in dealing with refugees, India is duty-bound. In the end, India may be in a better position to shape regional and global discourses on emerging issues affecting global governance, including on refugees. Rohingya’s have for long sought to lead a normal and peaceful life, in the Rakhine state where they have probably been living since 14th century. However, after 1978 military crackdown and the denial of citizenship rendering them stateless under the new citizenship and nationalities act, they have been periodically leaving Myanmar periodically as refugees or to emigrate overseas. According to the Arakan Project quoted by BBC in January 2018, Rohingyas population estimates in various countries are: Myanmar 484,000, Bangladesh947,000 (including those who migrated since August 2017), India 40,000, Indonesia-1000, Malaysia-150,000, Pakistan-350,000, Saudi Arabia-500,000, Thailand-5000 and UAE-50,000. Nearly two million expatriate Rohingyas are supporting the struggle for preserving the Rohingya identity and culture and to seek justice in Myanmar. So the Rohingya struggle both Within and outside Myanmar is likely to continue. The rise of Jihadi terrorism is probably increasingly finds favour with disillusioned Rohingya population; this segment could overwhelm the moderate segment of Rohingya population. Thus at present condition in Rakhine State provides perhaps ideal conditions of radical Islamic groups supported by expatriate Rohingyas community and armed and trained by Jihadi extremist groups, particularly in Bangladesh. Myanmar has so far been tardy in implementing strategies to create a safe environment for refugees to return to Rakhine State with confidence. Myanmar has no option but to progressively implements an action plan based on the Koffi Annan Advisory Commission’s recommendations to create a safe and friendly environment. Aung San Suu Kyi as a leader of international stature, should be encouraged to draw up plans to integrate Rohingyas in the national mainstream. The government will have to systematically carry out a nationwide integration campaign in schools and workplaces to create better understanding between Buddhist Bamar community and Muslims as a whole. Only then the government structural and systemic reforms both in the constitution and governance would become meaningful to yield long term results to usher in permanent peace. Unless the 2008 constitution is amended to end army’s role in the legislature and government, the elected civilian government cannot be expected to function effectively. Then only it can take charge and be accountable for defence, internal security and border security which are at present controlled by the commander in chief. Till Aung San Suu Kyi gathers enough support among the people and political parties to amend the constitution to make it truly democratic, she will continue to be compelled to make compromises on the Rohingya issue. In the near term, international community has to ensure that Bangladesh is provided all assistance and resources to look after nearly a million Rohingya refugees. It should also assist Bangladesh in preventing spread of extremism among Rohingya refugees. Both Bangladesh and Myanmar should be encouraged to continue their bilateral interactions to evolve and implement a time bound plan for systematic repatriation refugees. Political and diplomatic intervention and development assistance by India, China and ASEAN can help this process to progress. They can also use their influence to ensure Myanmar creates suitable conditions are created in Rakhine State for Rohingyas to return home and settle down to resume their normal lives. Rohingya insurgency in Rakhine State has the potential to grow in strength with the support of expatriate Rohingyas with its international fall out. As Kofi Annan cautioned “unless concerted action – led by the government and aided by all sectors of the government and society – is taken soon, we risk another cycle of violence and radicalization, which will further deepen the chronic poverty that afflicts Rakhine State.” International community has to understand Myanmar government’s limitations in acting positively due to constitutional and legal roadblocks. Rather than periodically threatening to impose sanctions, UN interlocutors can be usefully engaged to work out solutions with the military hierarchy and the government to cooperate in amending the citizenship and nationalities enactments. Major Powers involved in the region can use their strength to influence Myanmar to take measures to act positively on this aspect. The Rohingya have since the middle of the 20th century endured unimaginable hardships and the worst form of persecution at the hands of successive regimes in Myanmar. It is in the interest of the international community, especially regional countries most directly affected including Myanmar, Bangladesh and India, to work together to ensure a just solution that is acceptable to the Rohingya. Despite the recent externally-induced jihadist resurgence amongst a section of the Rohingya, what the predominant majority of the community desires is to return back home and live life with dignity. Reports indicate that in the aftermath of the August 2017 attacks, most of the Rohingya were livid with ARSA for providing an excuse to the Myanmar army to drive them into exile. The need of the hour is to find a lasting solution urgently lest Islamic jihadist forces take over and exploit the issue to further their own destructive agenda. As Malaysian Prime Minister Najib Razak warned in his speech at an Organization of Islamic Cooperation (OIC) meeting early last year, the Rohingya could be ‘infiltrated’ by Islamic State of Iraq and the Levant (ISIL) if their plight is not resolved, and this could threaten the whole region. ISIL is in disarray after the pounding it took in Syria and Iraq last year. The real danger emanates from Pakistan, especially the ISI, which has actually launched a concerted effort to exploit the plight of the Rohingya to the full, even if at the cost of the future of the Rohingya themselves. For the international community, highlighting the woes of the Rohingya by itself may not provide the desired long-lasting solution. Pakistan needs to be taken to task and told in no uncertain terms, through imposition of sanctions if necessary, that its despicable policies vis-å-vis the Rohingya would no longer be tolerated. Unless that happens, a Harakah al-Yaqin or an ARSA would invariably emerge on the horizon every time a solution appears likely. The crisis in the Rakhine region of Myanmar has important lessons for India. Not only is the region in the doorstep of India’s North East, but as is well known in India the continuous flow of illegal Bangladeshi immigrants may turn into the more dangerous flood of Rohingyas a group of which the Harakah al-Yaqin (HaY) or ARSA is known to have participated in mass murder of Hindus in Kha Maung Seik.

Conclusion

India as a country is always ready to help refugees or problems faced by people around due to natural calamities. India as discussed above is not signatory to neither the 1951 UN conventions nor the protocol on status of refugees, it takes care of refugees on case to case basis, depending on the gravity as well as on an ad hoc basis.[15] There is no International law or any other specific law for the governances of refugees in India but previously also India has opened its doors for people in need like the Tibetan refugees, Chakma of Bangladesh, Afghans and ethnic Tamils are among those.[16]  The Tibetans have in fact given rights to take land and property on lease as well as seek jobs in the private sectors, whereas with regards to Tamil refugees, there are getting state government aid worth a lakh, also the present Modi government in 2016 allowed Hindus, Sikhs, Buddhist, Jains, parsis, Christians from neighboring countries to but properties as well as get driving licenses, Aadhar, PAN cards etc. The fact that the Rohingya Crisis is one of the biggest issues in the south Asian region, wherein this particular community is facing a huge amount of oppression, adversities and are living miserable lives to an extent that their origin county is not ready to accept them as citizens and they are being treated as outsiders or illegal foreigners in their native land. Also, the fact that they are seeking refuge in foreign lands due to fear of persecution in their native state. They are to be protected irrespective of whether countries have signed conventions for refugee protection or not and also countries of Myanmar and Bangladesh should come together and solve the issue rather than putting the burden on each other. With regards to India, even though the country accepts a large number of refuges and under international human rights conventions takes care of their protection still India has to remove its ad hoc policy and treating refugees on case to case basis and should adopt a uniform framework taking into consideration united nation conventions[17] on refugees, European conventions[18], Bangkok conventions[19] in order to safeguards rights of all kinds of refugees without any discrimination, whether it be Rohingya or anybody also by taking cue from policy of minimum standards of treatment, right to repatriation as well as protection of their human rights.

[1] Indians News, ( March 22, 2019). https://indiansnews.com/india/understanding-problems-created-rohingya-muslims-india.

[2] Supra Note(India News)

[3] International Labour Organization, (March22, 2019). Retrieved from www.ilo.org/dyn/ natlEx/docs/ ELECTRONIC/87413/99608/…/ MMR87413.pdf

[4] Martin, S. (1995). The Muslim Rohingya ofBurma.

[5] The Sydney Morning Herald, (March 22, 2019). Retrieved from https://www.smh.com.au/world/ asia/bangladEsh-rEjEcts-myanmar-s-rohingya- rEsEttlEmEnt-claim-20180416- p4z9y8.html

[6]The First Post, (March 22, 2019). Retrieved from https://www.firstpost.com/india/rohingya- illEgal-rEfugEEs-tomyanmar-whEn-it-cant-EvEn- dEport-11-4054169.html.

[7] The Foreigners Act, 1946, Act No. 31, 1946, (India)

[8]

[9]Human Rights Watch, All you can do is Pray

[10]

[11]

Id. (Human rightsWatch),at  Note 7

[12] Supra Note ( United Nations)

[13] Id. at Note 81 ( Council of Europe)

[14] Id  at Note 77( UNHCR)

[15]

[16] Bhattacharj, Saurabh (2008). India needs a Refugee Law, (2008), p 71-75.

[17] Supra Note ( United Nations)

[18] Id.at Note 81 ( Council of Europe)

[19] Id.at Note 77( UNHCR)

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