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Interpretation of Human Rights In India

When you deprive people of their right to live in dignity, to hope for a better future, to have control over their lives, when you deprive them of that choice, then you expect them to fight for these rights. – Queen Rania Al Abdullah of Jordan

Human rights are essential for the overall development of individuals. The Constitution of India makes provisions for basic rights also known as Fundamental Rights for its citizens as well as for aliens. A distinction is made between Specific Fundamental Rights and Unspecified Fundamental Rights. The rights enshrined in the Constitution also at times are at par with the International Covenant on Civil and Political Right (ICPPR) which is an international treaty. The ICCPR is applicable to States rather than to individual.

Therefore, rights enshrined therein become the obligation of a state only when they have been incorporated in the State’s internal law.

After the Universal Declaration of Human Rights by the UN General Assembly on December 10, 1948, the concept of Human Rights assumed a significance of its own though earlier than this, International Labour Organisation in 1920 also initiated the Conventions on the rights of workers to form unions and organisations, abolition of forced labour and right to collective bargaining.

The UN Charter in 1945 affirmed faith in the fundamental human rights and appointed a Commission on Human Rights under Mrs. E. Roosevelt. This declaration was the outcome of the latter’s deliberations A.A. Said aptly remarked The concept of Human Rights may be difficult to define but impossible to ignore. The Human Rights are concerned with the dignity of the individual—the level of self esteem that secures personal identity and promotes human community.

As defined by OHCHR:

Human rights are rights inherent to all human beings, whatever our nationality, place of residence, sex, national or ethnic origin, colour, religion, language, or any other status. We are all equally entitled to our human rights without discrimination. These rights are all interrelated, interdependent and indivisible.

Universal human rights are often expressed and guaranteed by law, in the forms of treaties, customary international law , general principles and other sources of international law. International human rights law lays down obligations of Governments to act in certain ways or to refrain from certain acts, in order to promote and protect human rights and fundamental freedoms of individuals or groups.

Origin and Development of Human Rights in India

The Buddhist doctrine of non-violence in deed and thought says Nagendra Singh, is a humanitarian doctrine par excellence, dating back to the third century B.c. - Jainism too contained similar doctrines.

According to the Gita, he who has no ill will to any being, who is friendly and compassionate, who is free from egoism and self sense and who is even-minded in pain and pleasure and patient is dear to God. It also says that divinity in humans is represented by the virtues of non-violence, truth, freedom from anger, renunciation, aversion to fault-finding, compassion to living being, freedom from covetousness, gentleness, modesty and steadiness- the qualities that a good human being ought to have.

The historical account of ancient Bharat proves beyond doubt that human rights were as muck manifest in the ancient Hindu and Islamic civilizations as in the European Christian civilizations. Ashoka, the prophet Mohammed and Akbar cannot be excluded from the genealogy of human rights.

Human Rights in British India

The modern version of human rights jurisprudence may be said to have taken birth in India at tile time of the British rule. When the British ruled India, resistance to foreign rule manifested itself in the form of demand for fundamental freedoms and the civil and political rights of the people, Indians were humiliated and discriminated against by the Britishers. The freedom movement and the harsh repressive measures of the British rulers encouraged the fight for civil liberties and fundamental freedoms. Under the British rule, human rights and democracy were suspect and socialism was an anathema. In the Indian cultural history, the British colonial period remains the Indian equivalent of the Dark Ages.

Lord Macaulay rejected the ancient Indian legal political system as dotages of Brahmanical superstition, and condemned ancient legal heritage and its inner core as an immense apparatus of cruel absurdities. Lord Wellesley condemned the Indians as vulgar, ignorant, rude and stupid and Lord Cornwallis described as an axiom that every native of Hindustan is corrupt. The English East India Company debarred Indians from high offices an3 deprived them of their political, social and economic rights.

The impression created in the Indian minds was that their sacred inalienable human rights and vital interests had been ignored, denied, and trampled upon for the sake of England and the English rulers. Mahatma Gandhi organised the people of India under his leadership and launched his non-violent struggle to achieve self-government and fundamental rights for themselves. Lokmanya Tilak advocated that freedom was the birth right of Indians for which they will have to fight.

It was because of the stiff opposition from the people of India that the Charter Act of 1813 was enacted to promote the interest and happiness of the native inhabitants of India. Similarly, the Government of India Act, 1833 was passed to allow the Indians to enjoy some political rights. The proclamation of Queen Victoria on 1 November 1858 contained :some principles of state policy, which were similar to fundamental rights in nature. The concrete demand for fundamental rights came logically in the wake of the nationalist movement , which coincided with the birth of the Indian National Congress in 1885.

The Constitution of India Bill 1895 known as the Home Rule Document prepared by the Indian National Congress paved the way for a constitution guaranteeing everyone of the citizens the basic human rights like freedom of expression, inviolability of ones own house, right to property and equality before law. The Government of India Act, 1915, in pursuance of the demands for fundamental rights, guaranteed equality of opportunity in public services. A series of resolutions adopted by the National Congress between 1917 and 1919 repeated the demand for civil rights and equality of status with the English.

Human Rights and The Indian Constitution

The Constitution of the Republic of India which came into force on 26th January 1950 with 395 Articles and 8 Schedules, is one of the most elaborate fundamental laws ever adopted. The Preamble to the Constitution declares India to be a Sovereign, Socialist, Secular and Democratic Republic. The term democratic denotes that the Government gets its authority from the will of the people. It gives a feeling that they all are equal irrespective of the race, religion, language, sex and culture. The Preamble to the Constitution pledges justice, social, economic and political, liberty of thought, expression, belief, faith and worship, equality of status and of opportunity and fraternity assuring the dignity of the individual and the unity and integrity of the nation to aid its citizens.

India was a signatory to the Universal Declaration of Human Rights. A number of fundamental rights guaranteed ta the individuals in Part III of the Indian Constitution are similar to the provisions of the Universal Declaration of Human Rights.

The following chart makes it very clear:

Civil and Political Rights in the Universal Declaration of Human Rights and in the Indian Constitution

Article Declaration Constitution
Equality before law Article 7 Article 14
Prohibition of  discrimination Article 7 Article 15(1)
Equality of opportunity Article 21(2) Article 16(1)
Freedom of speech and expression Article 19 Article 19(1)(a)
Freedom of peaceful assembly Article 20(1) Article 19(1)(b)
Freedom to form associations or unions Article 23(4) Article 19(1)(c)
Freedom of movement within border Article 13(1) Article 19(1)(d)
Protection ion respect of conviction for offences Article 11(2) Article 20
Protection of life and personal liberty Article 3 Article 21
Protection of slavery and forced labour Article 4 Article 23
Freedom of conscience and religion  Article 18 Article 25(1)
Remedy for enforcement of rights Article 8 Article 32
Right against arbitrary arrest and detention Article 9 Article 22

The table below shows that most of the economic, social and cultural rights proclaimed in the Universal Declaration of Human Rights have been incorporated in part IV of the Indian Constitution

Economic, Social and Cultural Rights in the Universal Declaration of Human Rights and in the Indian Constitution

Article Declaration Constitution
Right to work, to just and favourable condition of work Article 23(1) Article 41
Right to equal pay for equal work Article 23(2) Article 39(d)
Right to education Article 26(1) Article 21(a),41,45,51A(k)
Right to just and favourable remuneration Article 23(3) Article 43
Right to rest and leisure Article 24 Article 43
Right of everyone to a standard of living adequate for him and family Article 25(1) Article 39(a), 47
Right to proper social order Article 28 Article 38

In Keshavnanda Bharati v. State of Kerala, the Supreme Court observed, The Universal Declaration of Human Rights may not be a legally binding instrument but it shows how India understood the nature of human rights at the time the Constitution was adopted.

In the case of Jolly George Varghese v. Bank of Cochin the point involved was whether a right incorporated in the Covenant on Civil and Political Rights, which is not recognised in tie Indian Constitution, shall be available to the individuals in lndia. Justice Krishna Iyer reiterated dualism and asserted that the positive commitment of the State Parties ignites legislative action at home but does not automatically make the Covenant an enforceable part of the Corpus Juris in India. Thus, although the Supreme Court has stated that the Universal Declaration cannot create a binding set of rules and that even international treaties may at best inform judicial institutions and inspire legislative action.

In the judgement given in the Chairman, Railway Board and others v. Mrs. Chandrima Das, the Supreme Court observed that the Declaration has the international recognition as the Moral Code of Conduct having been adopted by the General Assembly of the United Nations. The applicability of the Universal Declaration of Human Rights and principles thereof may have to be read, if need be, into the domestic jurisprudence.

Fundamental Rights and Human Rights

The judicially enforceable fundamental rights which encompass all seminal civil and political rights and some of the rights of minorities are enshrined in part Ill of the Constitution (Articles 12 to 35). These include the right to equality, the right to freedom, the right against exploitation, the right to freedom of religion, cultural and educational rights and the right to Constitutional remedies.

Fundamental rights differ from ordinary rights in the sense that the former are inviolable. No law, ordinance, custom, usage, or administrative order can abridge or take them away. Any law, which is violative of any of the fundamental right, is void.

In ADM Jabalpur v. Shukla, Justice Beg observed the object of making certain general aspects of rights fundamental is to guarantee them against illegal invasion of these rights by executive, legislative, or judicial organ of the State. Earlier, Chief Justice Subba Rao in Golak Nath v. State of Punjab had rightly observed, Fundamental rights are the modern name for what have been traditionally known as natural rights,

The Supreme Court of India recognises these fundamental rights as Natural Rights or Human Rights. While referring to the fundamental rights contained in Part Ill of the Constitution, Sikri the then Chief Justice of the Supreme Court, in Keshavananda Bharati v. State of Kerala, observed, I am unable to hold these provisions to show that rights are not natural or inalienable rights. As a matter of fact India was a party to the Universal Declaration of Rights and that Declaration describes some fundamental rights as inalienable.

The Chief Justice Patanjali Shastri in State of West Bengal v. Subodh Gopal Bose  referred to fundamental rights as those great and basic rights, which are recognised and guaranteed as the natu-a1 rights inherent in the status of a citizen of a free country.

Article 14 of the Indian Constitution proclaims the general right of all persons to equality before the law, while Article 15 prohibits the State from discriminating against any citizen on grounds of religion, race, caste, sex or place of birth, and prohibits any restriction on any citizen’s access to any public place, including wells and tanks. Equality of opportunity for all citizens in matters of pubic employment is guaranteed under Article 16. Article 17 abolishes untouchability and makes its practice an offense punishable under law.

Both Articles 15 and 16 enable the State to make special provisions for the advancement of socially and educationally backward classes, for such castes and tribes as recognized in the Constitution (known as the Scheduled Castes and Scheduled Tribes) require very special treatment for their advancement. Article 18 abolishes all non-military or non-academic titles.

The right to freedom guaranteed to all citizens under Article 19 encompasses the right to freedom of speech and expression, the right to assemble peaceably without arms, the right to form associations or unions, the right to move freely throughout the territory of India, the right of residence, and the right to practice any profession, or to carry on any occupation, trade or business.

The protection of a person in respect of conviction of offense under Article 20 includes protection against ex post facto criminal laws, the principle of autre fois convict and the right against self-incrimination. Article 21, the core of all fundamental rights provisions in the Indian Constitution, ordains: No person shall be deprived of his life or personal liberty except according to procedure established by law.

Article 21A was added to the Constitution by the Eighty Sixth Constitutional Amendment Act 2002. Article 21A proclaims the State shall provide free and compulsory education to all children of the age of six to fourteen years in such manner as the State may, by law, determine. The rights of a person, arrested and detained by the State authorities, are provided in Article 22. These include the, right to be informed of the grounds of arrest, the right to legal advice and the right to be produced before a magistrate within 24 hours of arrest (except where one is arrested under a preventive detention law).

The right against exploitation includes prohibition of trafficking in human beings and forced labour (Article 23), and prohibition of employment of children below 14 years of age to work in any factory or mine or in any other hazardous employment. Subject to public order and morality, all persons are equally entitled to freedom of conscience and the right to profess, practice and propagate religion (Article 25). Every religious denomination or section also has the right to establish and maintain religious institutions and manage their religious affairs (Article 26). No one may be compelled to pay any religious taxes (Article 27).

The wholly State-funded educational institutions are barred from imparting religious instructions (Article 28).10 The rights of any section of citizens or a minority to promote its distinct language, script or culture, to have access to Statefunded educational institutions (Article 29), and to establish and maintain educational institutions of its choice (Article 30) are also guaranteed.10 The right to Constitutional remedies is essentially the right to move the Supreme Court of India for 2nforcement of the above rights (Article 32). The Supreme Court is vested with wide Constitutional powers in this regard. They include the power to issue directions, orders or writs for the enforcement of the fundamental rights (Article 32(2)). State (i.e. provincial) High Courts too have identical powers (Article 226).

As laws inconsistent with or in derogation of the rights conferred by part III of the Constitution are void (Article 13), the Courts have the power to adjudge the Constitutional validity of all laws. Furthermore, by virtue of Article 141,the law declared by the Supreme Court shall be binding on all courts in India. Fundamental rights guaranteed under the Indian Constitution may be divided, for the sake of convenience, into two categories viz., specified fundamental rights and other fundamental rights (rights not specifically enumerated).

Case Laws

Article 14

In National Legal Services Authority versus U.O.I (AIR 2014 SC 1863), the Supreme Court has held that Article 14 does not restrict word ‘person’ and its application to only males and females and hijras/transgender who are neither male or female falls within the expression ‘person’. They are entitled to legal protection of laws in all spheres of state activity including health care, employment , education as well as equal civil citizenship rights, as enjoyed by every other citizen of this country.

Naz Foundation v. Govt of NCT of Delhi:- The Delhi High Court declared Section 377 of IPC, which criminalizes Homosexuality in India, as unconstitutional and violative of fundamental rights guaranteed under Article 14, 15 and 21 of the Constitution. Later on in Suresh Kumar Kaushal & Anr. V. NAZ Foundation & Others, the Supreme Court of India struck down the decision of Delhi High Court and held the Section 377 of IPC does not suffer from any constitutional infirmity and has left on the legislature to deal with the legality of the Section.

Article 19

In Romesh Thapar v/s State of Madras, Patanjali Shastri,CJ, observed that Freedom of speech & of the press lay at the foundation of all democratic organization, for without free political discussion no public education, so essential for the proper functioning of the process of popular government, is possible. In this case, entry and circulation of the English journal Cross Road, printed and published in Bombay, was banned by the Government of Madras. The same was held to be violative of the freedom of speech and expression, as without liberty of circulation, publication would be of little value.

The Hon’ble Supreme Court observed in Union of India v/s Association for Democratic Reforms, One-sided information, disinformation, misinformation and non information, all equally create an uninformed citizenry which makes democracy a farce. Freedom of speech and expression includes right to impart and receive information which includes freedom to hold opinions.

In Indian Express Newspapers v/s Union of India, it has been held that the press plays a very significant role in the democratic machinery. The courts have duty to uphold the freedom of press and invalidate all laws and administrative actions that abridge that freedom. Freedom of press has three essential elements. They are:

  1. Freedom of access to all sources of information,
  2. Freedom of publication, and
  3. Freedom of circulation.

In Sakal Papers v/s Union of India, the Daily Newspapers (Price and Page) Order, 1960, which fixed the number of pages and size which a newspaper could publish at a price was held to be violative of freedom of press and not a reasonable restriction under the Article 19(2). Similarly, in Bennett Coleman and Co. v/s Union of India, the validity of the Newsprint Control Order, which fixed the maximum number of pages, was struck down by the Court holding it to be violative of provision of Article 19(1)(a) and not to be reasonable restriction under Article 19(2). The Court also rejected the plea of the Government that it would help small newspapers to grow.

Article 21

In Maneka Gandhi v. Union of India, the Supreme Court gave a new dimension to Art. 21 and held that the right to live the right to live is not merely a physical right but includes within its ambit the right to live with human dignity. Elaborating the same view, the Court in Francis Coralie v. Union Territory of Delhi[, observed that:

The right to live includes the right to live with human dignity and all that goes along with it, viz., the bare necessities of life such as adequate nutrition, clothing and shelter over the head and facilities for reading writing and expressing oneself in diverse forms, freely moving about and mixing and mingling with fellow human beings and must include the right to basic necessities the basic necessities of life and also the right to carry on functions and activities as constitute the bare minimum expression of human self.

The Supreme Court in Peoples Union for Democratic Rights v. Union of India, held that non-payment of minimum wages to the workers employed in various Asiad Projects in Delhi was a denial to them of their right to live with basic human dignity and violative of Article 21 of the Constitution. Bhagwati J. held that, rights and benefits conferred on workmen employed by a contractor under various labour laws are clearly intended to ensure basic human dignity to workmen. He held that the non-implementation by the private contractors engaged for constructing building for holding Asian Games in Delhi, and non-enforcement of these laws by the State Authorities of the provisions of these laws was held to be violative of fundamental right of workers to live with human dignity contained in Art. 21.

In Vishakha v. State of Rajasthan, the Supreme Court has declared sexual harassment of a working woman at her work as amounting to violation of rights of gender equality and rights to life and liberty which is clear violation of Articles 14, 15 and 21 of the Constitution. In the landmark judgment, Supreme Court in the absence of enacted law to provide for effective enforcement of basic human rights of gender equality and guarantee against sexual harassment laid down the following guidelines:

  1. All employers or persons in charge of work place whether in the public or private sector should take appropriate steps to prevent sexual harassment. Without prejudice to the generality of this obligation they should take the following steps:
    1. Express prohibition of sexual harassment as defined above at the work place should be notified, published and circulated in appropriate ways.
    2. The Rules/Regulations of Government and Public Sector bodies relating to conduct and discipline should include rules/regulations prohibiting sexual harassment and provide for appropriate penalties in such rules against the offender.
    3. As regards private employers steps should be taken to include the aforesaid prohibitions in the standing orders under the Industrial Employment (Standing Orders) Act, 1946.
    4. Appropriate work conditions should be provided in respect of work, leisure, health and hygiene to further ensure that there is no hostile environment towards women at work places and no employee woman should have reasonable grounds to believe that she is disadvantaged in connection with her employment.
  2. Where such conduct amounts to specific offences under I,P,C, or under any other law, the employer shall initiate appropriate action in accordance with law by making a complaint with appropriate authority.
  3. The victims of Sexual harassment should have the option to seek transfer of perpetrator or their own transfer.

In Jeeja Ghosh V UOI , Supreme Court asked the SpiceJet Ltd to pay Rupees Ten Lakhs to Jeeja Ghosh, an eminent activist involved in disability rights, for forcibly de-boarding her by the flight crew, because of her disability. Apex Court bench comprising of Justices A.K. Sikri and R.K. Agrawal also issued the guidelines with regard to ‘carriage’ by persons with disabilities and/or persons with reduced mobility and observed that People with disabilities also have the Right to live with dignity

In Parmananda Katara v. Union of India, the Supreme Court has very specifically clarified that preservation of life is of paramount importance. The Apex Court stated that ‘once life is lost, status quo ante cannot be restored.’ It was held that it is the professional obligation of all doctors (government or private) to extent medical aid to the injured immediately to preserve life without legal formalities to be complied with the police. Article21 casts the obligation on the state to preserve life. It is the obligation of those who are in charge of the health of the community to preserve life so that the innocent may be protected and the guilty may be punished.

In Jagmohan v. State of U.P, the Supreme Court had held that death penalty was not violative of articles 14, 19 and was said that the judge was to make the choice between death penalty and imprisonment for life on the basis of circumstances, facts and nature of crime brought on record during trail. Therefore, the choice of awarding death sentence was done in accordance with the procedure established by law as required under article 21.

In M.H. Hoskot v. State of Maharashtra, the Supreme Court said while holding free legal aid as an integral part of fair procedure the Court explained that  the two important ingredients of the right of appeal are; firstly, service of a copy of a judgement to the prisoner in time to enable him to file an appeal and secondly, provision of free legal service to the prisoner who is indigent or otherwise disabled from securing legal assistance. This right to free legal aid is the duty of the government and is an implicit aspect of Article 21 in ensuring fairness and reasonableness; this cannot be termed as government charity.

The judgment by the Supreme Court of India in Justice K.S. Puttaswamy (Retd) vs Union of India is a resounding victory for privacy. The ruling is the outcome of a petition challenging the constitutional validity of the Indian biometric identity scheme Aadhaar. The judgments ringing endorsement of the right to privacy as a fundamental right marks a watershed moment in the constitutional history of India.

The one-page order signed by all nine judges declares:
The right to privacy is protected as an intrinsic part of the right to life and personal liberty under Article 21 and as a part of the freedoms guaranteed by Part III of the Constitution.

Recent Events of Human Rights Violation

Limits on free speech and attacks on religious minorities, often led by vigilante groups that claim to be supporters of the ruling Bharatiya Janata Party (BJP), are an increasing concern in India. In 2016, students were accused of sedition for expressing their views; people who raised concerns over challenges to civil liberties were deemed anti-Indian; Dalits and Muslims were attacked on suspicion they had killed, stolen, or sold cows for beef; and nongovernmental organizations (NGOs) came under pressure due to India’s restrictive foreign funding regulations.

A crackdown on violent protests in Jammu and Kashmir beginning in July killed over 90 people and injured hundreds, fueling further discontent against government forces. Impunity for police and security forces largely continued amid new allegations of torture and extrajudicial killings, including reports of sexual assault and other abuses by security forces in the central Indian state of Chhattisgarh.

There were also some positive developments in 2016. The Narendra Modi government took steps toward ensuring greater access to financial services such as banking, insurance, and pensions for economically marginalized Indians and launched a campaign to make modern sanitation available to more households. In July, the Supreme Court of India took a strong stand against impunity for security forces, ruling that the Armed Forces (Special Powers) Act (AFSPA) does not protect soldiers from prosecution for abuses committed while deployed in internal armed conflicts. The court also gave new life to a challenge to a discriminatory colonial-era law criminalizing homosexuality.

Treatment of Dalits, Tribal Groups, and Religious Minorities

Hindu vigilante groups attacked Muslims and Dalits over suspicions that they had killed, stolen, or sold cows for beef. The violence took place amid an aggressive push by several BJP leaders and militant Hindu groups to protect cows and ban beef consumption.

In March 2016, a Muslim cattle trader, Mohammed Mazlum Ansari, 35, and a 12-year-old boy, Mohammed Imteyaz Khan, were found hanging from a tree in Jharkhand state, their hands tied behind their backs and their bodies bruised. In August, a man was killed in Karnataka state by members of a nationalist Hindu group while transporting cows.

In July, four men in Gujarat were stripped, tied to a car, and publicly beaten with sticks and belts over suspicions of cow slaughter.

The government’s continuing failure to rein in militant groups, combined with inflammatory remarks made by some BJP leaders, has contributed to the impression that leaders are indifferent to growing intolerance.
A 2016 report on caste-based discrimination by the UN special rapporteur on minority issues noted that caste-affected groups continue to suffer exclusion and dehumanization. In January, the suicide of Rohith Vemula, a 25-year-old Dalit student, drew renewed attention to entrenched caste-based discrimination in Indian society, and sparked nationwide protests by students and activists calling for reforms in higher education.

In June, a special court in Gujarat convicted 24 people for their involvement in the mass killing of 69 people by a Hindu mob in Gulberg Society, a Muslim neighborhood in Ahmedabad, during the 2002 Gujarat riots. While pronouncing the verdict, the court called the killings the darkest day in the history of civil society. But some victims’ families, lawyers, and rights activists criticized the acquittals of senior BJP leaders and a police official.

Freedom of Speech

The Indian authorities routinely use vaguely worded, overly broad laws as political tools to silence and harass critics.
Authorities continue to use sedition and criminal defamation laws to prosecute citizens who criticize government officials or oppose state policies. In a blow to free speech, the government in 2016 argued before the Supreme Court in favor of retaining criminal penalties for defamation. The court upheld the law.

In February, authorities arrested three students at the Jawaharlal Nehru University in Delhi under the sedition law for alleged anti-national speech, acting on complaints by members of the Akhil Bharatiya Vidyarthi Parishad (ABVP), the student wing of the ruling BJP. These arrests led to widespread protests over the arbitrary use of the sedition law.

In August, police in southern Karnataka state filed a sedition case against Amnesty International India based on a complaint by ABVP, alleging that anti-Indian slogans were raised at a meeting organized by Amnesty on abuses in Kashmir. Police later claimed, however, that they did not have sufficient evidence to proceed with charges. The same month, an actor-turned-politician in the state also faced sedition charges after she praised the friendship and courtesy she received in Pakistan.

In August, the Karnataka High Court called the state government clearly paranoid for pressing sedition charges against three people, including two former policemen, for organizing a protest seeking better police wages and working conditions.

In Chhattisgarh, journalists, lawyers, and civil society activists faced harassment and arrest. In March 2016, the Editors Guild of India reported that media in Chhattisgarh state were working under tremendous pressure from authorities, Maoist rebels, and vigilante groups.

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