Introduction:
How can Ahamdiyas and Rohingyas be religiously persecuted? After all, they belong to Muslim communities in Muslim countries. How can a Muslim be persecuted in a Muslim country? Should India be declared as a Hindu Rashtra? Matters related to citizenship has been discussed in part (ii) Article 5-11 of the constitution and citizenship act 1955. This issue has always been in question whether it was at the time of partition or in the current times. The main purpose of this act was to provide for the acquisition and determination of Indian citizenship and to protect the ethnicity, cultural and social values of Indian citizens. From the past few decades, the illegal immigration of Bangladeshis and other refugees into the north-eastern Indian states, especially Assam has been a bone of contention. Hence, to filter and deport the illegal immigrants, The National Register of Citizens (NRC) was formed in 1951. Initially it was formed for Assam.
Background
Before India got independence, several acts were enacted to regulate the influx of immigrants into the country for example Foreigners act 1864[1] , Passport (Entry into India) Act, 1920[2] etc. During the partition, a large number of people from Pakistan migrated to India and vice-versa. Government of India promulgated “Ordinance” on January 6, 1950, to tackle the migrants’ influx from East Pakistan. The Ordinance was replaced by Immigrants (Expulsion from Assam) Act, 1950[3] which came into effect on March 1, 1950. Then, The Citizenship Act 1955 came into effect five years after India’s constitution as a Republic and eight years after Independence.[4] The act mentions five ways of acquiring and three ways of loss of the Indian citizenship.
Citizenship Act 1955[5]
To expand the dimensions of Indian citizenship, the act was amended several times. The major amendments were of 1986, 1992, 2003, 2005, 2015 and the very recent 2019.
Section 3: By Birth
(a) on or after the 26th day of January, 1950, but before the 1st day of July, 1987;
(b) on or after the 1st day of July, 1987, but before the commencement of the Citizenship (Amendment) Act, 2003 (6 of 2004) and either of whose parents is a citizen of India at the time of his birth;[6]
(c) Those born in India on or after 3 December 2004 are considered citizens of India only if both of their parents are citizens of India or if one parent is a citizen of India and the other is not an illegal migrant at the time of their birth.[7]
Section 4: By Descent
Person born outside India shall be a citizen of India by descent,
(a) on or after the 26th day of January, 1950, but before the 10th day of December, 1992, if his father is a citizen of India at the time of his birth[8]; or
(b) on or after the 10th day of December, 1992, if either of his parents is a citizen of India at the time of his birth[9]
(c) From 3 December 2004 onwards, persons born outside of India shall not be considered citizens of India unless their birth is registered at an Indian diplomatic mission within one year of the date of birth. The application for registration of the birth of a child must be made to an Indian diplomatic mission and must be accompanied by an undertaking in writing from the parents of the child that he or she does not hold the passport of another country.[10]
Section 5: By Registration[11]
(1) This section specifically deals with certain categories i.e. person of Indian origins (POI) who himself or his parents were born in undivided India or
(2) who himself or his parents were born in a territory which became a part of India after 15th August 1947. A person of Indian origin who is ordinarily resident in India for seven years before making an application under Section 5(1)(a) (throughout the period of twelve months immediately before making application and for six years in the aggregate in the eight years preceding the 12 months).
- A person of Indian origin who is ordinarily resident in any country or place outside undivided India;
- a person who is married to a citizen of India and is ordinarily resident in India for seven years before making an application for registration;
- minor children of persons who are citizens of India;
- a person of full age and capacity whose parents are registered as citizens of India.
- a person of full age and capacity who, or either of his parents, was earlier citizen of independent India, and has been residing in India for one year immediately before making an application for registration;
a person of full age and capacity who has been registered as an overseas citizen of India for five years, and who has been residing in India for one year before making an application for registration.
Section 6: By Naturalisation[12]
Where an application is made in the prescribed manner by any person of full age and capacity [not being an illegal migrant] for the grant of a certificate of naturalisation to him, the Central Government may, if satisfied that the applicant is qualified for naturalisation under the provisions of the Third Schedule, grant to him a certificate of naturalisation:
Provided that, if in the opinion of the Central Government, the applicant is a person who has rendered distinguished service to the cause of science, philosophy, art, literature, world peace or human progress generally, it may waive all or any of the conditions specified in the Third Schedule.
Section 7: By Incorporation of Territory[13]
If any territory becomes a part of India, the Central Government may, by order notified in the Official Gazette, specify the persons who shall be citizens of India by reason of their connection with that territory; and those persons shall be citizens of India as from the date to be specified in the order.
IMDT Act, 1983
Illegal Migrants (Determination by Tribunals) Act, 1983 was enacted by Parliament and it was applicable in Assam since October 15, 1983. But certain provisions of this Act were controversial.
Hence, people started objecting this Act. Some points of objection were:
(1) It was applicable only to Assam, although, there were provisions to apply this Act all over India.
(2) Definition of “Illegal migrant” as define in section 3(1) (c) of the Act was disputed. According to this provision March 25, 1971, was the deadline to decide whether a person is an illegal migrant or not, while Assamese were demanding that 1951 (First NRC was prepared) must be the deadline. For rest of the country July 19, 1948, was the deadline, therefore, March 25, 1971, as the deadline for Assam is arbitrary and capricious.
(3) According to section 8 (2) complain regarding illegal migrant can be made only by that person when a migrant is found or resides at the place within three kilometres from the place of residence of the applicant. Such application must be accompanied with an affidavit sworn by not less than two persons residing within three kilometres from where illegal migrant resides or found and the application must be accompanied by not less than 25 rupees and not more than hundred rupees as prescribed by the authority. Complain procedures were very hectic, expensive and impractical.
(4) According to section 11, the burden of proof was on the prescribed authority to prove that another person is illegal migrant while in other countries, the burden of proof for proving his/her legality was on the person itself.
Due to many discrepancies in the act, the supreme court declared the act unconstitutional.
Assam Accord, 1983
The issue of illegal immigration is not new in India especially Assam. If we delve deep into the history of our country, we will find that different communities travelled and migrated to India such as Aryans, Mughals etc. During India- Pak partition, Bangladesh war, Soviet-Afghan War and various other agitations in the neighbouring countries led to a large number of people to migrate into the Indian territories (Bangladeshis in Assam), consequences of which led to a huge crisis related to the nationality of people. [14]The issue of illegal immigrants fuelled massive protests for six years beginning 1979, Mr Hiralal Patwari who was M.P. from Mangaldoi died on March 28, 1979, hence, a Lok Sabha by-poll was to be held at Mangaldoi seat.
Various outfits with All Assam Students Union (AASU) forming the nerve centre of the protests complained about foreigners – mainly Bangladeshis – having been included in the voters’ list. The Indira Gandhi government continued to engage with the protesters between 1980 and 1984 but without reaching an agreement. After her assassination, the Rajiv Gandhi government signed an agreement with the protesters – AASU and All Assam Gan Sangram Parishad – bringing the agitation to an end. The agreement between the Centre and the protesters is called the Assam Accord. It was signed on the Independence Day in 1985. Under Assam Accord, foreigners who had entered Assam before March 25, 1971, were to be given citizenship
In the 15 clauses of the Assam Accord, the key focus areas were:
- Foreigners issue
- Economic development
- Restricting the acquisition of immovable property by foreigners
- Prevention encroachment of government lands
- Registration of births and deaths
This was done to ensure the protection of the political, social, economic and cultural identity of the local people.[15] Citizenship act was amended, section 6A was inserted whereby special provisions as to the citizenship of persons covered by the Assam Accord was inserted. Certain modifications were also done in the IMDT Act, 1983. NRC was formed again to fulfil the objective of the Assam Accord.
What is NRC?
At its core, the NRC is an official record of those who are legal Indian citizens. It includes demographic information about all those individuals who qualify as citizens of India as per the Citizenship Act, 1955. The register was first prepared after the 1951 Census of India and since then it has not been updated until 2019.[16]
Role of Supreme Court
Sonowal case (I) 2005
A writ petition was filed in Supreme Court by Sarbananda Sonowal in 2000 (he was former President of AASU and in 2016 he took the oath of Chief Minister of Assam). He challenged the validity of the IMDT Act, 1983, the influx of foreigners into Assam as a threat for sovereignty and integrity of India and change of demography of Assam. Sarbananda Sonowal v. Union of India & Anr[17]. (Sonowal I case) was decided by Bench of three judges on July 12, 2005. In this case, the Supreme Court observed the following important points:
(1) Every citizen of India has a duty to uphold and protect the sovereignty, unity and integrity of India under Article 51-A (c). Hence, he was entitled to file a writ petition under Article 32.
(2) Influx of foreigners at large scale would be amount “aggression” under Article 355. Therefore, it is the duty of the Union Government to protect the States from such aggression.
(3) IMDT Act is unconstitutional. For classification under article 14, “intelligible differentia” itself is not sufficient. Such legislation must have a rational relation to the object sought to be achieved by the Act and should not be arbitrary.
(4) Illegal Migrants (Determination by Tribunals) Act, 1983 and Illegal Migrants (Determination by Tribunals) Rules, 1984 were declared unconstitutional. Therefore, all the matters pending before IMD Tribunals were transferred to Foreigner Tribunals.
(5) Foreigner Act, 1946 would be applicable to Assam also and matters shall be decided by Tribunals constituted under the Foreigners (Tribunals) Order, 1964.
(6) There is no reason to bifurcate illegal migrants coming into Assam and the rest of the Country.
Sonowal case (II) 2006[18]
To nullify the mandate issued by Supreme Court in Sarbananda Sonowal case on July 12, 2005, UPA Government led by Dr Manmohan Singh by using power conferred by section 3 of the Foreigner Act,1946 made an “Order” i.e. the Foreigners (Tribunal) Amendment Order, 2006 which was published in Official Gazette on February 10, 2006. By this Amendment, Foreigners (Tribunal) Order, 1964 was amended and it was provided that the Order, 1964 would be applicable to the whole of India except State of Assam. This Amendment was challenged by Sarbananda Sonowal in 2006. Supreme Court struck down the Foreigners (Tribunal) Amendment Order, 2006 in the case of Sarbananda Sonowal v. Union of India (Sonowal II case) on December 5, 2006. Supreme Court criticized the Government for not protecting Assam in proper manner. The Citizenship (Registration of Citizens & Issue of National Identity Cards) Rules, 2003 was amended on November 9, 2009. Rule 4A and one schedule were inserted in The Citizenship Rules, 2003 for updating NRC in Assam.
Assam Public Works v. Union of India & Ors. (2013)[19]
Assam Public Works v. Union of India & Ors. 2013 Assam Public Works filed a writ petition in 2009. This writ petition is known as Assam Public Works Petitioner(S) v. Union of India & Ors. Supreme Court had passed several orders in 2013. Process of NRC update was started in Assam according to these Orders.
Assam Sanmilita Mahasangha & Ors. v. Union of India & Ors (2014)[20]
In 2012 a writ petition was filed in Supreme Court challenging the Section 6A of Citizenship Act, 1955 which was inserted in 1985 for implementation of Assam Accord. In the case of Assam Sanmilita Mahasangha & Ors. v. Union of India & Ors., Supreme Court by using power conferred by Article 142 issued guidelines for updating NRC which was first and last time prepared in 1951. Eleven months were given and the last date for updating NRC was January 1, 2016. Supreme Court issued these guidelines on December 17, 2014. Court fixed next hearing in March 2015 to note the progress of implementation of directions issued by it.
Assam Public Works v. Union of India & Ors (2019)[21]
Assam Public Works filed a writ petition in 2009. This writ petition is known as Assam Public Works v. Union of India & Ors. Supreme Court has passed several orders. Recent judgement was delivered on August 13, 2019.
Citizenship (Amendment) Bill (2016)[22]
This Bill was introduced in Lok Sabha on July 19, 2016, to give protection regarding citizenship for Hindus, Sikhs, Jains, Buddhists, Parsis and Christians from Afghanistan, Bangladesh and Pakistan.
Citizenship (Amendment) Act 2019
The Citizenship (Amendment) Act, 2019 was introduced in Lok Sabha on 9th December 2019 passed by the Parliament of India on 11 December 2019. It amended the Citizenship Act of 1955 by providing the path of Indian citizenship for illegal migrants of Hindu, Jain, Parsi, Buddhist, Sikh and Christian minorities who had fled religious persecution from Pakistan, Bangladesh and Afghanistan on or before December 31, 2014.[23]
Comparison of the Citizenship (Amendment) Bill, 2016 with the Citizenship (Amendment) Act, 2019[24]
| The Citizenship (Amendment) Bill, 2016 (as passed by Lok Sabha) | The Citizenship (Amendment) Act, 2019 |
| Eligibility for citizenship for certain illegal migrants:The Act prohibits illegal migrants from acquiring Indian citizenship. Illegal migrants are foreigners who enter India without a valid passport or travel document, or stay beyond the permitted time.The Bill amended the Act to provide that Hindus, Sikhs, Buddhists, Jains, Parsis and Christians from Afghanistan, Bangladesh and Pakistan will not be treated as illegal migrants. In order to get this benefit, they must have also been exempted from the Foreigners Act, 1946 and the Passport (Entry into India) Act, 1920 by the central government. The 1920 Act mandates foreigners to carry passport, while the1946 Act regulates the entry and departure of foreigners in India. The Bill further stated from the date of its enactment, all legal proceedings pending against such an illegal migrant will be closed. | The Bill adds two additional provisions on citizenship to illegal migrants belonging to these religions from the three countries.Consequences of acquiring citizenship:The Bill says that on acquiring citizenship: (i) such persons shall be deemed to be citizens of India from the date of their entry into India, and (ii) all legal proceedings against them in respect of their illegal migration or citizenship will be closed. Exception: Further, the Bill adds that the provisions on citizenship for illegal migrants will not apply to the tribal areas of Assam, Meghalaya, Mizoram, or Tripura, as included in the Sixth Schedule to the Constitution. These tribal areas include Karbi Anglong (in Assam), Garo Hills (in Meghalaya), Chakma District (in Mizoram), and Tripura Tribal Areas District. It will also not apply to the areas under the Inner Line” under the Bengal Eastern Frontier Regulation, 1873. The Inner Line Permit regulates visit of Indians to Arunachal Pradesh, Mizoram, and Nagaland. |
| Citizenship by naturalisation: The Act allows a person to apply for citizenship by naturalisation, if the person meets certain qualifications. One of the qualifications is that the person must have resided in India or been in central government service for the last 12 months and at least 11 years of the preceding 14 years.The Bill created an exception for Hindus, Sikhs, Buddhists, Jains, Parsis and Christians from Afghanistan, Bangladesh and Pakistan, with regard to this qualification. For these groups of persons, the 11 years’ requirement will be reduced to six years. | The Bill further reduces the period of naturalisation for such group of persons from six years to five years. |
Issues to Consider
(1) Our Constitution does not mention anything regarding religion to grant citizenship. Hence the question arises whether granting citizenship on the basis of religion to particular communities and leaving the few behind is constitutional or not. Isn’t it the violation of Article 14 of the Constitution.
(2) Many others questioned the government regarding the fact that why did it only considered religiously persecuted minorities from Pakistan, Afghanistan and Bangladesh? It is not clear why migrants from these countries are differentiated from migrants from other neighbouring countries such as Sri Lanka (Buddhist state religion) and Myanmar (primacy to Buddhism). Similarly, the Rohingya Muslims in Myanmar had a history of religious persecution. Over the years, there have been reports of both Tamil Eelams and Rohingya Muslims fleeing persecution from their respective countries and seeking refuge in India.[25] Given that the objective of the Bill is to provide citizenship to migrants escaping from religious persecution, it is not clear why illegal migrants belonging to religious minorities from these countries have been excluded from the Bill.[26]
(3) It is also unclear why there is a differential treatment of migrants based on their date of entry into India, i.e., whether they entered India before or after December 31, 2014.[27]
(4) The Bill also excludes illegal migrants residing in areas covered by the Sixth Schedule, that is, notified tribal areas in Assam, Meghalaya, Mizoram and Tripura. The purpose behind the enactment of the Sixth Schedule of the Constitution was to aid in the development of tribal areas through autonomous councils while protecting the indigenous population in these areas from exploitation and preserving their distinct social customs. The Bill also excludes the Inner Line Permit areas. Inner Line regulates the entry of persons, including Indian citizens, into Arunachal Pradesh, Mizoram and Nagaland. Once an illegal migrant residing in these areas acquires citizenship, he would be subject to the same restrictions in these areas, as are applicable to other Indian citizens. Therefore, it is unclear why the Bill excludes illegal migrants residing in these areas.[28]
(5) With respect to classification based on religious persecution of certain minorities in Pakistan, Afghanistan and Bangladesh, it may be argued that there are other religious minorities in these countries, who face religious persecution and may have illegally migrated to India. For example, over the years, there have been reports of persecution of Ahmadiyya Muslims in Pakistan (who are considered non-Muslims in that country), and the murder of atheists in Bangladesh. It is unclear why illegal migrants from only six specified religious minorities have been included in the Bill.
Protests
Since the implementation of the act, the central government has faced a huge number of objections and protests throughout the country especially Assam. Eventually, the protests became extremely violent and aggressive to the extent that many people were killed. Even the educational institutions weren’t safe and students were brutally beaten up. The protests started in Assam on 4 December 2019, after the bill was introduced in parliament. Later on, protests erupted in Northeast India, and subsequently spread to the major cities of India. On 15 December, major protests took place near Jamia Millia Islamia in New Delhi and Aligarh Muslim University. As the protests broke out, mobs burnt and destroyed public as well as private properties and several railway stations were vandalised. Police forcibly entered the campus of Jamia, used batons and tear gas on the students, and more than 200 students were injured while around 100 were detained overnight in the police station. The police action was widely criticized and resulted in students across the country protesting in solidarity.[29]
Protesters agitated not only against the citizenship issues of the CAA, National Register of Citizens (NRC) and National Population Register (NPR), but also against police brutality, unemployment, poverty and for women’s safety. Mainly consisting of Muslim women, the protesters at Shaheen Bagh, since 14 December 2019, blocked a road in New Delhi using non-violent resistance for 101 days as of 24 March 2020.[30]
Several other protestors were arrested including Shargil Imam[31] and 3 months pregnant activists Safoora Zargar[32] who was even accused of Delhi Riots. Many others were accused of spreading hate speeches and giving death threats including BJP leader Kapil Mishra[33].
Conclusion
The beauty of our constitution is that it promotes secularism. Countries like Pakistan, Afghanistan etc. are Islamic republic and specifically point towards a particular religion hence, does not have a very renown status internationally. But we, I believe, as a secular country should implement laws in such a way that they must not violate the privacy of a particular community in order to benefit the other. NRC can be a major step in removing the illegal migrants if implemented appropriately.
One of the most active intellectuals of his time, an American historian Henry Steele Commager said: “If the democracy is to flourish, it must have criticism; if the government is to function it must have dissent”. We are the largest democracy in the world. It is the right of the people to express their dissent and protest against the laws which they find inappropriate. (However, protests should be as peaceful as they can be). Calling them “anti-nationals” point towards a poor governance. Hence, government should take adequate steps to handle protestors and even if it is not the intention of the government, laws must be implemented in such a way that they don’t hurt the religious feeling of the people.
References:
[1] Foreigners Act, 1864, available at:http://www.asianlii.org/mm/legis/code/fa1864127/ (Last visited on August 07, 2020)
[2] 3 Passport (Entry into India) Act, 1920, available at: https://www.mha.gov.in/sites/default/files/PptEntryAct1920.pdf (Last visited on August 07, 2020)
[3] Immigrants (Expulsion from Assam) Act, 1950, available at: https://indiankanoon.org/doc/1523917/ (Last visited on August 07, 2020)
[4] “Birth, Descent, Origin and Now Religion: Becoming an Indian Under the Citizenship Act and Its Amendments”, News 18, December 9, 2019, available at: https://www.news18.com/news/india/birth-descent-origin-and-now-religion-becoming-an-indian-under-the-citizenship-act-and-its-amendments-2418015.html (Last visited on August 07, 2020)
[5] Citizenship Act, 1955, available at: http://legislative.gov.in/sites/default/files/A1955-57.pdf (Last visited on August 08, 2020)
[6] Citizenship Amendment Act, 1986, s. 3, available at: http://www.parliament.gov.sb/files/legislation/Acts/1986/THE%20CITIZENSHIP%20(AMENDMENT)%20ACT%201986.pdf(Last visited on August 08, 2020)
[7] Citizenship Amendment Act, 2003 s. 3(c), available at: http://egazette.nic.in/WriteReadData/2004/E_7_2011_119.pdf (Last visited on August 08, 2020)
[8] Citizenship Act, 1955, s. 4, available at: http://legislative.gov.in/sites/default/files/A1955-57.pdf (Last visited on August 08, 2020)
[9] Citizenship Amendment Act, 1992, s. 4, (Act 39 of 1992)
[10] Indian Nationality Law, available at: https://en.wikipedia.org/wiki/Indian_nationality_law (Last Modified on July 21, 2020)
[11] Indian Nationality Law, available at: https://en.wikipedia.org/wiki/Indian_nationality_law (Last Modified on July 21, 2020)
[12] Citizenship Act, 1955, s. 6, available at: http://legislative.gov.in/sites/default/files/A1955-57.pdf (Last visited on August 08, 2020)
[13] Citizenship Act, 1955, s. 7, available at: http://legislative.gov.in/sites/default/files/A1955-57.pdf (Last visited on August 08, 2020)
[14] Prabhash K Dutta, “What is Assam Accord of 1985 and how amended citizenship law challenges it?”, India Today, December 13, 2019, available at: https://www.news18.com/news/india/birth-descent-origin-and-now-religion-becoming-an-indian-under-the-citizenship-act-and-its-amendments-2418015.html (Last visited on August 08, 2020)
[15] Krishna Murari Yadav, “BRIEF POLITICAL AND LEGAL HISTORY OF NRC IN INDIA” (2019) (Unpublished Assistant Professor, LC-I, Faculty of Law, University of Delhi)
[16] “What is NRC: All you need to know about National Register of Citizens”, India Today, December 18, 2019, available at: https://www.indiatoday.in/india/story/what-is-nrc-all-you-need-to-know-about-national-register-of-citizens-1629195-2019-12-18 (Last visited on August 09, 2020)
[17] Sarbananda Sonowal v. Union of India & Anr. AIR 2005 SC 2920 available at: https://indiankanoon.org/doc/907725/ (Last visited on August 09, 2020)
[18] Sarbananda Sonowal v. Union of India (July 05, 2006), available at: https://indiankanoon.org/doc/1436100/#:~:text=119%20of%202006.,1964%20Order%20from%20the%20scene (Last visited on August 09, 2020)
[19] Krishna Murari Yadav, “BRIEF POLITICAL AND LEGAL HISTORY OF NRC IN INDIA” (2019) (Unpublished Assistant Professor, LC-I, Faculty of Law, University of Delhi)
[20] “Assam Sanmilita Mahasangha & Ors. v. Union of India & Ors”, December 17, 2014, available at: https://indiankanoon.org/doc/50798357/ (Last visited on August 09, 2020)
[21] Assam Public Works v. Union of India & Ors., August 13, 2019, available at: https://www.indianemployees.com/judgments/details/assam-public-works-versus-union-of-india-ors (Last visited on August 09, 2020)
[22] Citizenship (Amendment) Bill, 2016, available at: https://www.prsindia.org/billtrack/the-citizenship-amendment-bill-2016-4348 (Last visited on August 09, 2020)
[23] Citizenship (Amendment) Act, 2019, available at: https://en.wikipedia.org/wiki/Citizenship_(Amendment)_Act,_2019 (Last modified on July 22, 2020)
[24] Citizenship (Amendment) Bill, 2019, available at : https://www.prsindia.org/billtrack/citizenship-amendment-bill-2019 (Last visited on August 09, 2020)
[25] Citizenship (Amendment) Bill, 2019, available at: https://www.prsindia.org/billtrack/citizenship-amendment-bill-2019 (Last visited on August 09, 2020)
[26] Citizenship (Amendment) Bill, 2019, available at: https://www.prsindia.org/billtrack/citizenship-amendment-bill-2019 (Last visited on August 09, 2020)
[27] Citizenship (Amendment) Bill, 2019, available at: https://www.prsindia.org/billtrack/citizenship-amendment-bill-2019 (Last visited on August 09, 2020)
[28] Citizenship (Amendment) Bill, 2019, available at : https://www.prsindia.org/billtrack/citizenship-amendment-bill-2019 (Last visited on August 09, 2020)
[29] Citizenship Amendment Act protests, available at: https://en.wikipedia.org/wiki/Shaheen_Bagh_Protests (Last modified on July 19, 2020)
[30] Shaheen Bagh Protests, available at: https://en.wikipedia.org/wiki/Shaheen_Bagh_Protests (Last modified on July 19, 2020)
[31] “Sharjeel Imam charged with sedition in anti-CAA riots case”, The Print, July 25, 2020, available at: https://theprint.in/india/sharjeel-imam-charged-with-sedition-in-anti-caa-riots-case/468342/ (Last visited on August 10, 2020)
[32] “Safoora Zargar: Bail for pregnant India student blamed for Delhi riots”, BBC News, June 23, 2020, available at: https://www.bbc.com/news/world-asia-india-53149967 (Last visited on August 10, 2020)
[33] “Defiant BJP Leader Kapil Mishra Says Did Not Commit Crime by Supporting CAA”, News 18, February 25, 2020, available at : https://www.news18.com/news/politics/defiant-bjp-leader-kapil-mishra-says-did-not-commit-crime-by-supporting-caa-2515711.html (Last visited on August 10, 2020)
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