1413430 (Refugee)

[2015] AATA 3245

1413430 (Refugee) [2015] AATA 3245 (4 August 2015)

DECISION RECORD

DIVISION:Migration & Refugee Division

CASE NUMBER:  1413430

COUNTRY OF REFERENCE:                  India

MEMBER:Glen Cranwell

DATE:4 August 2015

PLACE OF DECISION:  Brisbane

DECISION:The Tribunal affirms the decision not to grant the applicant a Protection visa.

Statement made on 04 August 2015 at 1:27pm

Any references appearing in square brackets indicate that information has been omitted from this decision pursuant to section 431 of the Migration Act 1958 and replaced with generic information which does not allow the identification of an applicant, or their relative or other dependant.

STATEMENT OF DECISION AND REASONS

APPLICATION FOR REVIEW

1. This is an application for review of a decision made by a delegate of the Minister for Immigration to refuse to grant the applicant a Protection visa under s.65 of the Migration Act 1958 (the Act).

2. The applicant who claims to be a citizen of India, applied for the visa [in] March 2013 and the delegate refused to grant the visa [in] July 2014.

3. The applicant appeared before the Tribunal on 4 August 2015 to give evidence and present arguments. The Tribunal hearing was conducted with the assistance of an interpreter in the Punjabi and English languages.

   RELEVANT LAW

4. The criteria for a protection visa are set out in s.36 of the Act and Schedule 2 to the Migration Regulations 1994 (the Regulations). An applicant for the visa must meet one of the alternative criteria in s.36(2)(a), (aa), (b), or (c). That is, the applicant is either a person in respect of whom Australia has protection obligations under the ‘refugee’ criterion, or on other ‘complementary protection’ grounds, or is a member of the same family unit as such a person and that person holds a protection visa of the same class.

   Refugee criterion

5. Section 36(2)(a) provides that a criterion for a protection visa is that the applicant for the visa is a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations under the 1951 Convention relating to the Status of Refugees as amended by the 1967 Protocol relating to the Status of Refugees (together, the Refugees Convention, or the Convention).

6. Australia is a party to the Refugees Convention and generally speaking, has protection obligations in respect of people who are refugees as defined in Article 1 of the Convention. Article 1A(2) relevantly defines a refugee as any person who:

   owing to well-founded fear of being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion, is outside the country of his nationality and is unable or, owing to such fear, is unwilling to avail himself of the protection of that country; or who, not having a nationality and being outside the country of his former habitual residence, is unable or, owing to such fear, is unwilling to return to it.

7. Sections 91R and 91S of the Act qualify some aspects of Article 1A(2) for the purposes of the application of the Act and the Regulations to a particular person.

8. There are four key elements to the Convention definition. First, an applicant must be outside his or her country.

9. Second, an applicant must fear persecution. Under s.91R(1) of the Act persecution must involve ‘serious harm’ to the applicant (s.91R(1)(b)), and systematic and discriminatory conduct (s.91R(1)(c)). Examples of ‘serious harm’ are set out in s.91R(2) of the Act. The High Court has explained that persecution may be directed against a person as an individual or as a member of a group. The persecution must have an official quality, in the sense that it is official, or officially tolerated or uncontrollable by the authorities of the country of nationality. However, the threat of harm need not be the product of government policy; it may be enough that the government has failed or is unable to protect the applicant from persecution.

10. Further, persecution implies an element of motivation on the part of those who persecute for the infliction of harm. People are persecuted for something perceived about them or attributed to them by their persecutors.

11. Third, the persecution which the applicant fears must be for one or more of the reasons enumerated in the Convention definition - race, religion, nationality, membership of a particular social group or political opinion. The phrase ‘for reasons of’ serves to identify the motivation for the infliction of the persecution. The persecution feared need not be solely attributable to a Convention reason. However, persecution for multiple motivations will not satisfy the relevant test unless a Convention reason or reasons constitute at least the essential and significant motivation for the persecution feared: s.91R(1)(a) of the Act.

12. Fourth, an applicant’s fear of persecution for a Convention reason must be a ‘well-founded’ fear. This adds an objective requirement to the requirement that an applicant must in fact hold such a fear. A person has a ‘well-founded fear’ of persecution under the Convention if they have genuine fear founded upon a ‘real chance’ of being persecuted for a Convention stipulated reason. A ‘real chance’ is one that is not remote or insubstantial or a far-fetched possibility. A person can have a well-founded fear of persecution even though the possibility of the persecution occurring is well below 50 per cent.

13. In addition, an applicant must be unable, or unwilling because of his or her fear, to avail himself or herself of the protection of his or her country or countries of nationality or, if stateless, unable, or unwilling because of his or her fear, to return to his or her country of former habitual residence. The expression ‘the protection of that country’ in the second limb of Article 1A(2) is concerned with external or diplomatic protection extended to citizens abroad. Internal protection is nevertheless relevant to the first limb of the definition, in particular to whether a fear is well-founded and whether the conduct giving rise to the fear is persecution.

14. Whether an applicant is a person in respect of whom Australia has protection obligations is to be assessed upon the facts as they exist when the decision is made and requires a consideration of the matter in relation to the reasonably foreseeable future.

    Relocation

15. The focus of the Convention definition is not upon the protection that the country of nationality might be able to provide in some particular region, but upon a more general notion of protection by that country: Randhawa v MILGEA (1994) 52 FCR 437 per Black CJ at 440-41. Depending upon the circumstances of the particular case, it may be reasonable for a person to relocate in the country of nationality or former habitual residence to a region where, objectively, there is no appreciable risk of the occurrence of the feared persecution. Thus, a person will be excluded from refugee status if under all the circumstances it would be reasonable, in the sense of ‘practicable’, to expect him or her to seek refuge in another part of the same country. What is ‘reasonable’ in this sense must depend upon the particular circumstances of the applicant and the impact upon that person of relocation within his or her country. However, whether relocation is reasonable is not to be judged by considering whether the quality of life in the place of relocation meets the basic norms of civil, political and socio-economic rights. The Convention is concerned with persecution in the defined sense, and not with living conditions in a broader sense: SZATV v MIAC (2007) 233 CLR 18 and SZFDV v MIAC (2007) 233 CLR 51, per Gummow, Hayne & Crennan JJ, Callinan J agreeing.

    State protection

16. Harm from non-state agents may amount to persecution for a Convention reason if the motivation of the non-State actors is Convention-related, and the State is unable to provide adequate protection against the harm. Where the State is complicit in the sense that it encourages, condones or tolerates the harm, the attitude of the State is consistent with the possibility that there is persecution: MIMA v Respondents S152/2003 (2004) 222 CLR 1, per Gleeson CJ, Hayne and Heydon JJ, at [23]. Where the State is willing but not able to provide protection, the fact that the authorities, including the police, and the courts, may not be able to provide an assurance of safety, so as to remove any reasonable basis for fear, does not justify an unwillingness to seek their protection: MIMA v Respondents S152/2003 (2004) 222 CLR 1, per Gleeson CJ, Hayne and Heydon JJ, at [28]. In such cases, a person will not be a victim of persecution, unless it is concluded that the government would not or could not provide citizens in the position of the person with the level of protection which they were entitled to expect according to international standards: MIMA v Respondents S152/2003 (2004) 222 CLR 1, per Gleeson CJ, Hayne and Heydon JJ, at [29]. Harm from non-State actors which is not motivated by a Convention reason may also amount to persecution for a Convention reason if the protection of the State is withheld or denied for a Convention reason.

    Complementary protection criterion

17. If a person is found not to meet the refugee criterion in s.36(2)(a), he or she may nevertheless meet the criteria for the grant of a protection visa if he or she is a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations because the Minister has substantial grounds for believing that, as a necessary and foreseeable consequence of the applicant being removed from Australia to a receiving country, there is a real risk that he or she will suffer significant harm: s.36(2)(aa) (‘the complementary protection criterion’).

18. ‘Significant harm’ for these purposes is exhaustively defined in s.36(2A): s.5(1). A person will suffer significant harm if he or she will be arbitrarily deprived of their life; or the death penalty will be carried out on the person; or the person will be subjected to torture; or to cruel or inhuman treatment or punishment; or to degrading treatment or punishment. ‘Cruel or inhuman treatment or punishment’, ‘degrading treatment or punishment’, and ‘torture’, are further defined in s.5(1) of the Act.

19. There are certain circumstances in which there is taken not to be a real risk that an applicant will suffer significant harm in a country. These arise where it would be reasonable for the applicant to relocate to an area of the country where there would not be a real risk that the applicant will suffer significant harm; where the applicant could obtain, from an authority of the country, protection such that there would not be a real risk that the applicant will suffer significant harm; or where the real risk is one faced by the population of the country generally and is not faced by the applicant personally: s.36(2B) of the Act.

    Relocation

20. Under s.36(2B)(a) of the Act, there is taken not to be a real risk that an applicant will suffer significant harm in a country if the Tribunal is satisfied that it would be reasonable for the applicant to relocate to an area of the country where there would not be a real risk that the applicant will suffer significant harm. That relocation must be ‘reasonable’ is also a requirement when considering the definition of ‘refugee’ and the Tribunal draws guidance from the judgments of the High Court in SZATV v MIAC and SZFDV v MIAC which held that whether relocation is reasonable, in the sense of ‘practicable’, must depend upon the particular circumstances of the applicant and the impact upon that person of relocation within his or her country: SZATV v MIAC (2007) 233 CLR 18 and SZFDV v MIAC (2007) 233 CLR 51, per Gummow, Hayne & Crennan JJ, Callinan J agreeing.

    State protection

21. Under s.36(2B)(b) of the Act there is taken not to be a real risk that an applicant will suffer significant harm in a country if the Tribunal is satisfied that the applicant could obtain, from an authority of the country, protection such that there would not be a real risk that the applicant will suffer significant harm. That is, the level of protection must be such to reduce the risk of the applicant being significantly harmed to something less than a ‘real risk’: MIAC v MZYYL [2012] FCAFC 147.

    Section 499 Ministerial Direction

22. In accordance with Ministerial Direction No.56, made under s.499 of the Act, the Tribunal is required to take account of policy guidelines prepared by the Department of Immigration –PAM3 Refugee and humanitarian - Complementary Protection Guidelines and PAM3 Refugee and humanitarian - Refugee Law Guidelines – and any country information assessment prepared by the Department of Foreign Affairs and Trade expressly for protection status determination purposes, to the extent that they are relevant to the decision under consideration.

    CONSIDERATION OF CLAIMS AND EVIDENCE

23. The Tribunal has before it the Department’s file relating to the applicant.  The Tribunal has had regard to the material referred to in the delegate’s decision, and other material available to it from a range of sources.  This material includes:

    ·application for protection visa;

    ·copies of the applicant’s passport;

    ·interview with delegate dated [in] January 2014;

    ·medical report dated [in] January 2009 and photograph of burns.

24. The applicant’s claims, as set out in Part C of his protection visa application form, can be summarised as follows:

    ·The applicant claims he will be killed by his brother-in-law, [Mr A] (his sister's husband),

    ·He claims this will happen because he did not support his sister marrying her husband.

    ·The applicant claims that his brother in law set him on fire and tried to kill him. As a result of this attack 30% of his body suffered 3rd degree burns.

    ·The applicant also claims that he and his parents have been threatened by his brother-in-law as they do not support his sister's marriage.

    ·The applicant claims that his brother-in-law is a criminal and a drug dealer who is well connected to the police and politicians.

    ·Because of his brother-in-law's connections (both criminal and political) he claims he cannot move to other parts of India or Nepal.

    ·The applicant also claims that his family have taken this matter to the police, but no action was taken.

25. At the hearing, the Tribunal asked the applicant what he feared if he returned to India. 

26. The applicant stated that he was burnt with oil [in] December 2008.  Two or three days before this, he came to know that his sister was in a relationship with [Mr A].  [Mr A] has been to prison 2-3 times, and sells drugs.  The applicant met [Mr A] at a sweets shop, and told him not to do this.  [Mr A] had 4 or 5 friends with him, and one of them held him while burning oil was poured over him.

27. The applicant stated that his sister married [Mr A] in 2012.  He is unsure of the date.  His sister had stopped seeing [Mr A] for a few months, and their parents had arranged for her to marry [another] boy.  However, [Mr A] took her forcibly while she was on a shopping trip and they had a court marriage.

28. The applicant stated that [Mr A] has been telephoning the applicant’s parents and saying that the applicant would be killed if he returned to India.  When the applicant’s father went to report the forcible taking of his daughter, the police manhandled the father and beat him up.  The father was told by the police that the applicant would be killed if he returned to India.

29. The Tribunal expressed doubts that the police would assist a convicted drug dealer.  The applicant stated that [Mr A] went to jail under a previous government.  He has political connections with the current government.

30. The Tribunal spent some time providing the applicant with a summary of the independent country information relating to relocation set out below. 

31. The Tribunal put to the applicant that if the police would have great difficulty finding the applicant, it might doubt whether [Mr A] would be able to find him either.  The applicant stated that [Mr A] has a big circle of friends.  He also has political connections.

32. The Tribunal put to the applicant that it appeared he would have no difficulty relocating because he was a Sikh.  The applicant stated that Sikhs are not treated as well outside of Punjab.  Even the taxi driver who took him to Delhi airport was not very nice to him.

33. The Tribunal put to the applicant that he indicated on his protection visa application that he could speak, read and write English, Punjabi and Hindi.  He was fit and able bodied, and unemployment in India was low.  This suggested that he would have no difficulty supporting himself if he was to relocate.  The applicant stated that he does not speak much English.  He fears [Mr A], otherwise he would go home and work on his farm.

34. The Tribunal asked the applicant whether there were any other matters he wished to raise.  The applicant stated that [Mr A] had put 2 bullets in another man in his home village, and that man was still not able to walk.  [Mr A] was roaming free and not in jail.  There was also a terrorist attack recently in Punjab which the police were not able to stop.  How could the police protect him?

    Independent country information

    State protection

35. Police inaction, either as a result of delays in conducting inquiries or refusals by police to accept FIRs, effectively prevents investigations into often serious crimes.  The practice is widespread, and can appear at times to be politically related. While some reports indicate that persistence on the part of the complainant can result in FIRs being acknowledged, this is not always the case.[1]

    [1] See the following reports as examples:

36. In 2012, the US Department of State (USDOS) noted that “[w]idespread impunity at all levels of government remained a serious problem. Investigations into individual cases and legal punishment for perpetrators occurred, but in many cases a lack of accountability due to weak law enforcement, a lack of trained police, and an overburdened court system created an atmosphere of impunity”.

37. Corruption remained pervasive, and bribes were reportedly paid to “speed up procedures, such as police protection”.[2][3]

    Relocation

    [2] US Department of State 2012, Country Reports on Human Rights Practices 2011 – India, 24 May, Executive Summary, Section 4.

38. USDOS states that Indian law provides for freedom of movement within the country, and the government generally respects this in practice.[4]  The UK Home Office reported that background checks by the Indian police are not conducted where Indian nationals relocate within India, as the authorities have neither the resources nor the language abilities to monitor internal relocation.  While there is not currently a national registration system for Indian citizens, several proposals and versions of identity cards are being used in various states for various purposes.[5]

    [4] US Department of State 2013, Country Reports on Human Rights Practices for 2012 – India, 19 April, Section II

    [5] UK Home Office 2010, Country of Origin Information Report – India, 21 September, p. 95.

39. The IRBC corresponded with an official at the Canadian High Commission in India, who “said that police share information about ‘law enforcement’ but indicated that ‘there is limited sharing of information between police forces’ and police are not required to ‘report the movements of persons of interest to other offices’”.[6]  In relation to tracing a person through registration, India reportedly does not have central registries for housing, rentals, schools, etc.  If a person wishes to transfer voter registration to another location, however, the elections committee requires proof of address.[7]

    [6] Immigration and Refugee Board of Canada 2012, India: Communication between police offices across the country; whether police across India can locate an individual, particularly as a result of registration requirements for employment, housing and education, security checks, and technological surveillance, IND104065.E, 14 May < Accessed 29 May 2012.

    [7] Immigration and Refugee Board of Canada 2012, India: Communication between police offices across the country; whether police across India can locate an individual, particularly as a result of registration requirements for employment, housing and education, security checks, and technological surveillance, IND104065.E, 14 May < Accessed 29 May 2012.

1. The previously mentioned official from the Canadian High Commission in India indicated to the IRBC that as there is no central police database and records are kept in local police stations in India, “this makes it ‘extremely difficult, if not impossible’ to locate an individual as a result of a security check, unless there is a match between a local police station and the subject of a security check”.[8]  It was reported in April 2011 that an applicant was not required to go to a police station to obtain identity documents such as driver’s licences, voter cards, or ration cards.[9]

   [8] Immigration and Refugee Board of Canada 2012, India: Communication between police offices across the country; whether police across India can locate an individual, particularly as a result of registration requirements for employment, housing and education, security checks, and technological surveillance, IND104065.E, 14 May < Accessed 29 May 2012.

   [9] Immigration and Refugee Board of Canada 2011, India: Identity documents required to obtain employment and housing in Delhi, Mumbai and Chandigarh; whether individuals must present themselves at police stations to obtain identity documents; issuance procedures for ration cards, birth certificates, driver's licenses, and voter cards, IND103725.E, 27 April < Accessed 31 May 2012.

2. India has some 1.2 billion people in some 27 million towns, cities and settlements, and the largest 8 cities have between 4 and 12 million people each[10][11][12].

   [10] – accessed 22 January 2013.

3. Hindi is the majority language in the following northern states: Himachal Pradesh, Haryana, Delhi, Uttaranchal, Uttar Pradesh, Rajasthan, Madhya Pradesh, Bihar, Jharkhand and Chhattisgarh. Hindi is the official language of eight of the nine states listed above.[13] Hindi is also spoken in Punjab, and is understood by approximately 40 per cent of the Indian population.[14] According to the Encyclopaedia Britannica Online, Hindi is spoken as a first language by approximately 425 million people across India, and as a second language by an additional 120 million.[15] English is recognised as an “associate” official language to Hindi, and is used predominantly by educated and professional groups, the media, and in administrative contexts.[16]

   [13] University of Illinois at Urbana-Champaign – Linguistics Department (n.d.), A Brief Profile of the Hindi Language < 4 October 2011

   [14] Online Computer Library Center (n.d.), Languages of India < Accessed 7 February 2008

   [15] Encyclopedia Britannica Online (n.d.), Hindi language < Accessed 4 October 2011

   [16] Online Computer Library Center (n.d.), Languages of India < Accessed 7 February 2008.

4. The 2001 census also recorded significant Sikh populations in Haryana, Rajasthan, Uttar Pradesh, Delhi, Chandigarh, Jammu and Kashmir, and Himachal Pradesh.[17]  A UK Home Office operational guidance note indicates that “Punjabi Sikhs are able to relocate to another part of India and there are Sikh communities all over India.  Citizens are not required to register their faith in India and Sikhs are able to practise their religion without restriction in every state of India.”[18] Information in a 2006 Immigration and Refugee Board of Canada report indicates that the majority of Sikhs in India reside in Punjab state, but there are Sikhs located in every state in India.[19]  In relation to employment, the 2006 IRBC report indicates that:

   Upon relocation to an area in India outside of Punjab state, several sources commented Sikhs would have indiscriminate access to employment[20]

   [17] Office of the Registrar General & Census 2001, Population by Religious Communities, Census India website < Accessed 23 February 2012; Singh Bajwa, S 2006, ‘Colossal Disparity in Population: Part I’, Sikh Review, January < Accessed 15 August 2012 .

   [18] UK Home Office 2012, Operational Guidance Note – India, June, p. 9 < Accessed 27 June 2012

   [19] Immigration and Refugee Board of Canada 2006, India: Ability of Sikhs to relocate within India; issues to be considered when relocating; safety concerns; treatment by authorities (March 2005 - December 2005), IND100771.EX, 18 January < Accessed 4 October 2006

   [20] Immigration and Refugee Board of Canada 2006, India: Ability of Sikhs to relocate within India; issues to be considered when relocating; safety concerns; treatment by authorities (March 2005 - December 2005), IND100771.EX, 18 January < Accessed 4 October 2006

5. The Times of India reported on 23 June 2013 that the overall Indian unemployment rate was 3%.[21]  In April 2013, the World Bank issued a report in which it expected economic growth in India to accelerate to 6.7% in 2015, and concluded that long-term prospects remain bright.[22]

   [21] - accessed 24 June 2013.

   [22] accessed 24 June 2013.

   Country of reference

6. The applicant claims to be an Indian national.  Based on the copy of his passport, the Tribunal finds that India is his country of nationality for the purposes of the Convention and also their receiving country for the purposes of s.5(1) and s.36(2)(aa) of the Act.

   Assessment of claims

7. While it has some doubts about the applicant’s credibility, the Tribunal is prepared to accept that [Mr A] has harmed the applicant in the past and has threatened to do so in the future should he return.

8. The Tribunal accepts that the applicant faces a real chance of persecution at the hands of [Mr A] in the reasonably foreseeable future in his home area of Punjab.  The Tribunal also accepts that there are substantial grounds for believing that as a necessary and foreseeable consequence of the applicant being removed from Australia to India that there is a real risk that he will suffer significant harm in their home area of Punjab at the hands of [Mr A].

   State protection

9. The independent country information set out above indicates a high level of corruption, inaction and inefficiency in India’s criminal justice system.  Considering the country information, the Tribunal finds that the applicant would not be able to access a level of state protection in Punjab in accordance with the principles of MIMA v Respondents S152/2003.

10. Considering the country information, the Tribunal finds that the applicant could not obtain protection from the authorities in Punjab such that there would not be a real risk that he will suffer significant harm: MIAC v MZYYL [2012] FCAFC 147.

    Relocation

11. It was put to the applicant at the hearing that India is a vast and very populous nation, and that the independent country information does not support that [Mr A] or anyone else would be able to find him in the rest of India, especially given information about the lack of central registries and the difficulties that even the police have in tracking down individuals (as referred to in the country information set out above). 

12. It is 3 years since the applicant’s sister married [Mr A], and over 6 years since the applicant was attacked by [Mr A].  The Tribunal finds that it is very doubtful that [Mr A] would be motivated to seek out the applicant in other parts of India.  Even if [Mr A] was motivated to pursue the applicant across India, the country information indicates that India has a massive population and enormous cities.  There is no unified national registration system for Indians and very limited sharing of information between police forces.  The country information concerning the lack of central registries and difficulties police have in tracking down individuals across the nation indicates that the chance or risk that they would be able to locate the applicant is remote.  Given the totality of the independent country information and considering his individual circumstances, the Tribunal finds that the applicant could relocate to other Indian states where there is a remote risk of the occurrence of the feared persecution.

13. The applicant can read, speak and write Hindi which is understood by around 40% of the Indian population and a majority in eight northern states.  He is a young, able bodied male.  Independent country information indicates that unemployment is low in India and the country is experiencing substantial economic growth.  The Tribunal does not accept that the applicant could not move to another part of India and that he could not obtain employment which would be sufficient to support himself. 

14. The applicant is a Sikh and independent country information indicates that Sikhs are present throughout the country and are able to practise their religion without restriction and that they have indiscriminate access to employment.

15. Considering all of their individual circumstances and the country information, the Tribunal finds that it would be reasonable for the applicant to relocate to another state in India to avoid the localised threat of serious harm that the applicant faces in his home state of Punjab.  Accordingly, the Tribunal finds that the applicant does not in the reasonably foreseeable future face a real chance of persecution (Convention or non-Convention related) in India from [Mr A] or anyone else.  Their fear of persecution is not well-founded.

16. Considering the independent country information and his individual circumstances, the Tribunal finds that it would be reasonable for the applicant to relocate to an area of the country where there would not be a real risk that he will suffer significant harm and that 36(2B)(a) applies in their cases.  Accordingly, the Tribunal finds that that are not substantial grounds for believing that as a necessary and foreseeable consequence of the applicant being removed from Australia to India that there is a real risk that he will suffer significant harm.

    Conclusions

17. For the reasons given above the Tribunal is not satisfied that the applicant is a person in respect of whom Australia has protection obligations. Therefore the applicant does not satisfy the criterion set out in s.36(2)(a) or (aa) for a protection visa. There is no suggestion that the applicant satisfies s.36(2) on the basis of being a member of the same family unit as a person who satisfies s.36(2)(a) or (aa) and who holds a protection visa.  As he does not satisfy the criteria for a protection visa, he cannot be granted the visa.

    DECISION

18. The Tribunal affirms the decision not to grant the applicant a Protection visa.

    Glen Cranwell
    Member

    
    
    

‘Trader killed in his shop, police ‘inaction’ sparks protest’ 2012, The Indian Express, 22 July < Accessed 27 August 2012;
Deedwania, B 2012, ‘Firm traces stolen containers after police inaction’, Mumbai Mirror, 25 May < Accessed 27 August 2012
Ray, M 2012, ‘Court justice for rape victim after police inaction’, The Times of India, source: TNN, 23 June < Accessed 27 August 2012.

[3] Freedom House 2011, Freedom in the World 2011 – India, 5 July < Accessed 8 August 2012.

[11] - accessed 22 January 2013.

[12] - accessed 24 June 2013.