Goa Case Study: Regulatory Collapse and its Consequences
Background
Goa is far better known for the two million
vacationers who throng its beaches every year than
for its iron mines. But starting just a few
kilometers inland from its coastal resorts, the
state has about 90 working mines that yielded some
45 million tons of iron ore in 2010 -- 20 percent of
India's total.
Goan iron was worth well over Rs 21.5 crore (US$5 billion)
in 2011 and production has skyrocketed in recent years in
response to rising global prices.
State government officials estimate that the mining industry
directly employs some 20,000 people and indirectly supports
the livelihoods of tens of thousands more.
Goa is a tiny state and many of its mines are clustered
closely together and directly adjacent to nearby communities.
The local industry is dominated by three large firms that all
have their roots in the state: Fomento, Salgaocar and Sesa
Goa; the last of which was acquired by mining giant Vedanta
in 2007.
"A Total Lack of Governance"
The mining industry in Goa stands as a stark example of the
broader patterns of regulatory collapse described later in
this report. Goan anti-mining activists complain that mine
operators flout the law while government institutions plagued
by incompetence, incapacity or corruption stand by and do
nothing.
Surprisingly, when Human Rights Watch put these allegations
to key state government and industry officials, many
acknowledged that they were true. A senior official with one
of Goa's top three mining companies, speaking on condition of
anonymity, put it this way:
"There is a total lack of governance in the mining
sector. The government has no idea what is going
on.... Absent a real change in governance, there
will just be more corruption and more chaos from
year to year."
An official in Goa's own mines department complained to Human
Rights Watch that the state and central governments' approach
to oversight of the mining sector was "lethargic to an
extreme."
Even mining industry spokesman S. Sridhar estimated to Human
Rights Watch that 40 percent of all mining operations in Goa
fail to comply with at least some laws and regulations and
that perhaps another 5 percent is entirely illegal, taking
place on land miners have no right to work on. "The
remaining mining is done legally," he said.
Then Goa Environment Minister Alexio Sequeira told Human
Rights Watch he thought the true figures were less alarming
but added, "He [Sridhar] should know better than me."
P.S. Banerjee, general manager for Fomento, one of Goa's "big
three" mining companies, told Human Rights Watch that his
company's own operations were meticulous in adhering to the
letter of the law. But speaking of the industry more
broadly, he said that "Mining in Goa works in shades of gray.
The problem is not just legal versus illegal mining, but
there is a huge gray area in between and that is the most
important issue." Banerjee described this approach to the law
euphemistically as "creative compliance."
But in practical terms, "creative compliance" simply means
non-compliance that government regulators fail to detect or
respond to.
Failure to Track Basic Indicators of Compliance
Consent to Operate
On paper, Goa's Pollution Control Board has the
responsibility to verify whether mining companies (and other
industries) are complying with India's air and water acts.
Those laws are important tools to help ensure that
mines do not cause serious harm to human health and
the environment. But in practice, the board is
ineffectual and carries out little meaningful
oversight activity of mining or any other industry.
As of late 2011, the board had only 16 technical
staff to oversee the environmental and
pollution-related practices of the entire mining
industry as well as of every other business in the
state -- including even visiting cruise ships.
Then, Goa Environment Minister Alex Sequeira was dismissive
of the board's oversight role, calling it a "mere post
office" that did little more than ferry paperwork between the
central government and operations based in Goa.
But in principle, the board is one of Goa's key oversight
institutions. It has the power to conduct surprise
inspections, including of mine sites, and to shut down
operations that do not maintain consents to operate issued by
its staff -- but it does not have the manpower to do either
of these things. Board Chairman Simon DeSousa told Human
Rights Watch that with his office's small staff, "We are
handicapped. It is impossible to oversee all these
industries."
Perhaps worse, Dr. DeSousa admitted to Human Rights Watch
that he had no idea whether mining firms and other companies
were bothering to maintain the "consent to operate" from his
own office they are legally required to possess. These
consents are normally given and renewed almost automatically
if miners can prove that they have obtained all other
required government clearances -- in practical terms they
serve as a way for the state government to verify that miners
are in compliance with other baseline legal obligations. "It
is quite possible that 40 percent of mines are operating
without clearances," DeSousa told Human Rights Watch. "Some
mines may not have obtained consent to operate from the board
-- we cannot police that. We cannot see who is operating
illegally unless someone complains." He blamed the problem on
his office's lack of a coherent filing system.
Under mounting public pressure due to a scandal around
allegations of mining-related illegalities and corruption in
the state, the board stated in 2011 that 41 of Goa's 90 mines
were not in compliance with the law. Outside parties
apparently informed board officials that it had not issued
those mines with up-to-date consents to operate, and
questioned whether they possessed the other government
clearances needed to obtain them. Thirtyfour of the
forty-one leaseholders reportedly failed to comply with an
initial deadline and were told to cease operations until
necessary permissions could be obtained.
While the board's action was an important step to bring the
state's mines into compliance with the law, the board still
lacks any independent means to track compliance.
Production Figures
Goa's Mines Department tracks production figures based
entirely on figures submitted by mine operators themselves.
The department had only 12 technical staff as of September
2011 and Dr. Hector Fernandez, the department's senior
geologist, conceded to Human Rights Watch that the government
had no way of verifying whether company figures were
accurate. "With this staff we cannot," he said, "It's
impossible."
This means that the state does not actually know if mines are
producing ore in excess of what they claim, thereby cheating
the government out of tax revenue and royalties. Critics
allege that this is precisely what has taken place.
A September 2011 report by the Goa legislature's
Public Accounts Committee detailed what it called
unexplained discrepancies between production and
export figures. Those could translate into steep
revenue losses for the state government, since no
royalties or other taxes would be paid on
unreported production.
Industry officials questioned the figures, arguing that there
could be benign explanations for many of the apparent
discrepancies. Alarmingly, the state government could
neither confirm nor deny the allegations because it did not
have any data of its own.
Central Government Failures
The Indian central government imposed a moratorium on new
mining leases in Goa in February 2010, apparently at the
request of the state government.
However, this did not result in remedying deficiencies with
the clearances underpinning the state's existing mines. Many
of Goa's mines appear to have been established on the basis
of Environmental Impact Assessments that contained erroneous
or fabricated data -- a nationwide problem that is discussed
in detail below.
As detailed below, a government commissioned study of the EIA
reports underpinning all of Goa's currently operational mines
seems likely to confirm widespread fabrication of data in
those reports.
In theory, the environment ministry's regional office in
Bangalore monitors whether mines in Goa and neighboring
states are operating in compliance with the law and with the
terms of their environmental clearances—and can shut them
down if they are not. But in practice, regional office staff
rarely visits the state and have never halted the operations
of any mine in Goa.
This problem -- also a nationwide affliction -- is addressed
in detail below.
Conflicts of Interest and Allegations of Corruption
If it is illegal, why does the Government not act?
Because the government is involved, politicians are
involved. At every level, everywhere.
Bureaucrats, everyone. If I point it out, they
will stop my legal mining, so I have to keep my
mouth shut. --S. Sridhar, spokesperson, Goa
Mineral Ore Exporters Association, May 2011
Many Goan mine operators are increasingly reliant on
contractors to operate their mines or transport their
products to the port. Encouraged by the vast profits being
made in the mining sector, Goan politicians have gotten in on
the mining business by becoming contractors themselves. A
2011 investigation by the Goa Herald newspaper documented the
alleged involvement of six senior state government officials
in the mining business. Some denied any involvement while
others openly admitted it to the paper.
The trend towards using contractors is driven largely by
economic considerations -- labor costs are lower and
companies do not wish to invest heavily in new equipment that
may lose its value if commodity prices and iron production
decline.
But in some cases there is also a political calculation. Some
contractors are hired because their ties to politicians make
them better able to either navigate or evade the regulatory
framework, not because of their competence or reputation for
responsible operation.
Officials with two different Goan mining firms, speaking on
condition of anonymity, told Human Rights Watch that
companies often selected contractors with political ties for
the wrong reasons, and that contractors linked to politicians
often displayed little interest in working responsibly or
even obeying the law. "Sometimes you proactively go to a
politician and say, ‘Look, let's do this together,' so you
get it done faster," one company official said, adding that
he disapproved of the practice. "Politicians have entered
into this mining business and are spoiling the names of
established mining companies. Their actions tar the
reputation of the whole industry."
An official with another mining firm complained about
companies' use of contractors with "no competence or value
added except that they work well with politicians."
Jaoquim Alemao, until March 2012 Goa's politically
influential Minister of Urban Development, started a company
called Rhissa Mining Services. The company is run by his
son. The former minister does not deny his involvement in
the mining business and says that Rhissa's only role is to
purchase heavy machinery and rent it out to established
mining firms, which is not illegal.
Some observers have raised concerns about the true nature
Rhissa's activities. Rama Velip, a farmer and anti-mining
activist in the south Goa village of Rivona, says he was
approached by a representative of Rhissa who attempted to
persuade him to abandon his opposition to nearby mining
developments—mines that Rhissa had little or no clear
economic stake in.
He told Human Rights Watch that he felt he was being
approached by the powerful minister behind the company,
rather than the company itself.
Goa's Mineral Ore Exporters Association was not clear about
Rhissa's role in the local industry. When asked, association
spokesman S. Sridhar shook his head slowly and replied: "I
don't know what he [Jaoquim Alemao] is doing. I really don't
know." But he later added that, "Naturally if a politician is
there I will give him the contract if it is economical to
me.... It happens everywhere."
These practices are worrying because they create conflicts of
interest that can lead public officials to push back against,
rather than support, action by already weak regulatory
officials. Then Goa Environment Minister Alex Sequeira said
that he had no financial stake in the mining industry but
defended the right of other government officials to enter the
business. While acknowledging that conflicts of interest
were possible, he asked Human Rights Watch, "You talk in
terms of wanting a clean government, but how am I supposed to
look after my family if you say I should not do business?"
Some in Goa's mining industry also allege that corruption
often plagues their attempts to comply with the law by
obtaining necessary clearances and permissions. Activists
allege that this problem also pushes weak regulatory
institutions even deeper into complacency and inaction.
Some company officials complain that it can be almost
impossible to obtain necessary government clearances in a
reasonable amount of time without bribing officials to move
necessary paperwork through the system. Industry spokesman
S. Sridhar told Human Rights Watch:
Unless you go and talk to them personally nothing
is happening. There is corruption everywhere in
getting these approvals. If I do not want to pay a
bribe I have to wait four or five years. So I'll
pay the bribe to get the approval or I'll just
start producing [illegally] while I wait.
Local activists also allege that police officers also profit
from the mining industry by purchasing trucks they contract
out to haul ore from mine sites—creating a conflict of
interest when local protests shut down a mine that helps
supply their income.
India's Prevention of Corruption Act outlaws such practices
but critics allege that some police officials circumvent the
law by putting trucks in the names of their wives or
relatives.
A police official at the station in Quepem whose officers
have been deployed to break up mining-related protests in the
area told Human Rights Watch that, "No police officer in
Quepem owns a [mining] truck. It's different if a wife or
children are doing business."
Human Rights Impacts
South Goa's cluster of iron mines is relatively new, with
most springing up within the last 10 years (modern,
mechanized mining has been taking place in north Goa for
several decades). Human Rights Watch visited mining-affected
communities in south Goa's Quepem taluk [district] and found
evidence that some communities are suffering precisely the
kind of harm that government regulation of the industry is
supposed to prevent.
The mostly agricultural communities in south Goa are
profoundly divided in their attitudes towards the industry.
Residents who allege that mining has destroyed vital
groundwater supplies, ruined crops and created serious health
risks have protested strenuously against local mine
operators. On the other side of the divide, villagers who
have derived direct economic benefits from mining
activity—often by purchasing trucks they hire out to haul ore
away from the mine sites—have emerged as ardent proponents of
the industry.
Health, Environmental and Livelihood Concerns
Health Concerns
Some residents of mining-affected communities told Human
Rights Watch they worried that dust emissions from passing
ore trucks could be linked to respiratory disease in their
communities.
"People are getting breathing problems," one farmer
complained. Hundreds of heavily laden ore trucks pass
through narrow roads leading through those communities every
day, spewing clouds iron-rich dust as they pass. According
to residents, the dust settles in thick coats on the crops
that stand in nearby fields, on homes, and even on a
schoolhouse that sits adjacent to the road.
Sufficient data does not exist to measure the extent of any
health damage caused by dust emissions in mining areas of
Goa—neither the state nor central governments have carried
out any studies to obtain that data. A 2001 study of mining
areas in Goa found that overloaded ore trucks were
responsible for "fugitive dust emissions…sharply exceeding
the ambient national air quality standards for residential
areas."
Broader studies of the health impacts of dust emissions by
iron mines have generally focused on occupational health
issues, not impacts on surrounding communities. But such
studies indicate that inhalation of iron oxide can cause
respiratory ailments. Studies also indicate that exposure to
silica, which is often a constituent part of iron ore dust,
may be linked to serious ailments including silicosis and
other lung diseases such as lung cancer.
Some communities in Goa resort to making use of surface water
for at least part of the year because their groundwater
supplies have been damaged or destroyed by nearby mining
operations. In some cases that surface water is itself
contaminated by runoff from the same mines.
In 2010, India's Ministry of Environment and Forests declared
its intention to commission a study on the environmental
impacts of all existing mines in Goa, but at the time of
writing the study had yet to be carried out.
So far, however, the state and central governments have not
treated the potential health impacts of irresponsible mining
with the seriousness they deserve. In an interview with
Human Rights Watch, then-Goa Environment Minister Alex
Sequeira professed the government has not been able to act
because people in mining-affected communities are
uninterested in their own health:
The local in many areas believes that money is God.
You and I may believe he is sacrificing his health
but he does not care. Locals own trucks and are
provided things by mining companies—money, air
conditioners. So even if this activity is taking a
toll on their health, they will not allow us to
act.
Water and Agriculture
People living in and around two south Goa villages visited by
Human Rights Watch—Rivona and Caurem—complained that adjacent
mines have polluted nearby rivers and streams through
irresponsible waste disposal and that natural springs used to
irrigate fields have been destroyed as mines puncture the
water table and damage aquifers. "Because of water
pollution, there is no water for agriculture," said farmer
and anti-mining activist Rama Velip. "Some wells are dry.
Some spring water is destroyed."
Other residents of the two communities echoed his complaint.
"I have had no sugar cane for three years," said one farmer
who alleges that dust and groundwater pollution have
destroyed his crops. Another local resident said that since
mid-2010, "murky water is suddenly coming from the springs,"
and attributed this to nearby mining activity.
Other farmers alleged that their crop yields had decreased
dramatically due to clouds of iron-rich dust from passing
trucks that settle on and kill their crops.
Most mines in Goa operate below the water table, and many are
forced to continually pump out vast quantities of water in
order to keep mine pits dry. Often, mine operators simply
discard the water rather than reinject it into the ground to
help regenerate the resource.
One woman living near Caurem told Human Rights
Watch that in 2011, one nearby mine broke through
the water table and unleashed a torrent of water
that flowed from the mine site down a hill and
across a nearby road for more than a week; by the
time it stopped flowing, nearby springs had
completely dried up.
Many of these claims are impossible to verify because
sufficient data does not exist -- and that is part of the
problem. Public officials have done nothing to study alleged
harms caused by the cumulative impact of mining operations in
south Goa, and do not know how many mine operators are
engaged in irresponsible and illegal practices that could
bring about such harm. The data that does exist, however, is
troubling.
Goa mining industry spokesperson S. Sridhar told Human Rights
Watch that mining did not cause any loss of drinking or
irrigation water anywhere in Goa. "Water is available
everywhere," he said.
But a study published by his own association in 2010
acknowledged that mining in Goa has "quantitative and
qualitative impacts on the water regime in and around the
mines," including through pollution and through damage to
aquifers.
And one mine near Caurem was shut down in March 2011 for
damaging local springs, dumping its waste on the banks of a
nearby river and causing other harm.
Its closure followed extended protests by local residents.
One villager told Human Rights Watch that before the mine
shut down, company officials met with villagers to ask,
"‘What do you want? Money? Something to implement in the
village?' We said we don't want anything, just our land and
our water."
A 2009 study by the National Environmental Engineering and
Research Institute (NEERI) found that mining around Sirigaon
village in north Goa had created "water scarcity" by
puncturing the water table and reducing the area available
for groundwater recharge by rain.
The study also found that silt carried as runoff from mine
waste dumps had "degraded the soil fertility in the
agricultural fields" around the village.
Such mine runoff problems are common in Goa and are
exacerbated when mine operators locate waste dumps close to
riverbanks—generally in violation of the terms of their
environmental clearances. Goa receives more than 3000 mm of
rainfall annually and monsoon rains often cause these dumps
to collapse, causing pollution and heavy siltation of
agricultural fields, irrigation canals, rivers and creeks.
Studies have found that this phenomenon can have serious
negative impacts on agricultural yields, groundwater quality
and fish populations that mining-affected communities depend
on.
Human Rights Watch observed that some mine operators
distribute water in metal drums to communities whose own
water supplies have been destroyed or damaged. This practice
implies the creation of localized water scarcity problems
that did not exist prior to the onset of mining activity. It
also begs the question of how the impacted communities will
obtain drinking and irrigation water after mining operations
have been completed -- the damage to their aquifers will not
vanish when local iron deposits are exhausted. Simon DeSousa
of Goa's Pollution Control Board acknowledged to Human Rights
Watch that depletion of water resources by mining was a
problem in south Goa. Asked why miners were allowed to dig
below the water table if that was the case, he said he did
not know.
Protest and Response
In 2011, growing local discontent around the impact of iron
mining operations in south Goa led to peaceful protests and
also to violent confrontations between local residents and
mine employees.
Residents of Caurem told Human Rights Watch that in a
separate incident in April 2011, fights between angry
villagers and private security guards at one mine site left
individuals on both sides injured.
Residents in Rivona and Caurem have staged prolonged sit-in
protests, blocking the roads providing access to local mine
sites. Protesters told Human Rights Watch that in May 2011
they were confronted by a group of truck drivers who
threatened violence if they did not clear the road;
ultimately the police dispersed the protesters and arrested
at least 94 people.
Quepem police official S.S. Narvekar told Human Rights Watch
that the arrests were a "preventative" measure to avert
violence between anti-mining activists and truck drivers,
that they were carried out with "minimum force" and that all
those detained were released at the end of the same day.
Many of the villagers arrested see things differently, and
allege that police carried out a lathi (baton) charge against
them without being provoked.
Narvekar acknowledged the seriousness of the protesters'
complaints, but said the police were powerless to address
those issues. "If the [state government] confirmed that what
these mines are doing is illegal, it would be different," he
said. "But without that, on what basis can we ask them to
stop?"
Threats and Violence
There have been occasional reports of violence and direct
threats against anti-mining activists in Goa. Nilesh Gaukar,
a resident of Caurem village who helped organize local
anti-mining protests in 2011, told Human Rights Watch that he
received an anonymous phone call in early May warning him
that "mine owners and contractors" were planning to attack
him. On May 12, as he alighted from a public bus at the
nearby industrial estate where he worked, a man wielding an
iron bar attacked him:
I got off the bus and as I was going to the gate someone hit
me with an iron rod. Ten or 15 people were around [but] he
got away on a motorcycle -- one person was waiting there on
the bike. I saw him get on the bike and flee. He tried to
get me on the head but only got me on the shoulder and elbow.
Gaukar spent four days in the hospital and when he returned
home, police officials in Quepem provided him with a 24-hour
police guard. No one was arrested.
Another prominent local voice against mining, Cheryl DeSousa,
told Human Rights Watch that she has suffered a long string
of phone calls threatening violence against her and her
daughter in extremely graphic terms. DeSouza owns more than
200 acres of farmland in the heart of south Goa's iron mining
belt and has participated in anti-mining protests by nearby
villagers.
DeSousa says that she has been approached with highly
lucrative offers to buy her land but has consistently
refused, partly because her late husband is buried there.
She told Human Rights Watch that because of her refusal to
sell, she has received numerous threatening phone calls from
anonymous callers. She said that some have threatened to
gang rape her teenage daughter and throw acid on her face.
"They also told me that my problem is that I haven't had a
man in so long, and they will fix that." She did not file a
complaint with the police, describing that as a "waste of
time."
An Inevitable Scandal
When Human Rights Watch first visited Goa in May 2011,
industry and state government officials appeared complacent
about the state's mining troubles. Many of those who openly
acknowledged the worst problems described above expressed no
urgency to correct them.
By September 2011, the situation had changed dramatically.
This was due largely to the arrival of a Commission of
Inquiry convened by the central government and headed by
retired Supreme Court Justice M.B. Shah. The Shah
Commission was tasked with investigating illegal mining of
iron ore and manganese nationwide.
Goa -- to the apparent surprise of Goan politicians and
industry leaders—was the commission's first stop. Within
days, Shah began talking to the press, making statements that
seemed highly critical of the mining industry and the state
government.
Many in the government considered this especially alarming,
coming on the heels of a scandal that had brought down the
government in neighboring Karnataka state earlier in the
year.
Prominent critics of the state's ruling Congress Party began
calling for the resignation of Goa's chief minister, Digambar
Kamat, who in addition to being chief minister since 2007,
had held the post of mines minister for more than a decade.
National media attention focused suddenly and intensely on
Goa. Some Goans expressed hope that the scandal could lead
to real accountability, and that the Shah Commission would
name names. Sujoy Gupta, editor of the Goa Herald, told
Human Rights Watch that he hoped that due to the Shah
Commission's work, "the ugly face of illegal mining will be
exposed because the individuals involved will be exposed.
That is what has been missing in the past."
The Shah Commission's report was submitted to the central
government in March 2012, but to date has not been made public.
By late 2011 the mining industry was focused on trying to
avoid a shutdown of iron exports similar to the one that
decimated the industry in Karnataka. Industry spokespeople
emphasized the potentially devastating impact an industry
shutdown could have on the state economy as well as mine
workers, their families, truck drivers and others who rely on
mining for their incomes.
"Any good doctor can find 10 things wrong with you even if
you are perfectly healthy," Goa mining industry spokesman S.
Sridhar told Human Rights Watch. "But why should he want to
put you in the hospital for that?"
Not all industry officials were convinced that a temporary
shutdown was such a bad idea.
An official with one of Goa's major mining firms, speaking on
condition of anonymity, told Human Rights Watch: "I would be
happy if they stopped all mining and said, 'OK, let's look at
everything fresh, make sure everything is clean and get rid
of the bad operators and then restart it.' My company might
not be happy and maybe some people would get hurt but
personally, I would be very happy."
A Test for Goa's New Government
In February 2012 the Congress Party lost control of Goa in
statewide elections. In part, the vote was seen to reflect
rising public anger over the state's increasingly public
mining scandals.
The opposition Bharatiya Janata Party (BJP), eager to turn
the tables on its Congress Party rivals after being tarnished
itself by the scandal in Karnataka, had sharply criticized
the state government's failure to curb abuses in the mining
sector.
In March 2012, Manohar Parrikar was sworn in as chief
minister of a new BJP-led government. As an opposition
legislator, Parrikar had publicly denounced the state
government's failure to tackle its mining problems in harsh
terms. A 2011 report Parrikar wrote as a member of the
legislature's Public Accounts Committee found that, "Mining
in the state is beset with substantial illegalities" and
concluded that there had been a "complete breakdown" of all
key regulatory institutions in the state. The report also
alleged that illegalities by miners had "resulted in strain
on the infrastructure, ecology, [and] agriculture and
threatens to destroy the water security of the state, if not
curbed immediately."
Parrikar's report found that "Environmental Impact
Assessment studies have been found to be
manipulated or... full of incorrect data"
regarding the presence on or near mining leases of
protected tribal populations; schools; agricultural
fields; and water bodies.
As an opposition politician, Parrikar's criticisms of the
Kamat government carried with them a strong implicit
commitment to reform. In an interview with Human Rights
Watch in September 2011—before the election that made him
chief minister—he said: "I am a supporter of regulated,
properly controlled mining" and accused the state and central
governments for failing to implement that kind of control.
"If you are just going to give permission for every single
mine, what is the point of needing permission? If
everyapplication is granted it means you are either careless
or corrupt." He also alleged that widespread corruption lay
behind many of the state government's worst oversights,
saying some illegalities by miners were so conspicuous that,
"this is only possible when a politician is there. It is not
just incapacity. They are looking the other way."
Even before the February 2012 election, public criticism
spurred some welcome action on the part of Goa's hitherto
lethargic state government. Goa's woefully understaffed
Pollution Control Board was allocated funds to hire dozens of
new staff in late 2011 -- a prerequisite to any kind of
credible monitoring by that office.
In addition, then Environment Minister Alex Sequeira
partnered with a Goan NGO to assess the credibility of the
Environmental Impact Assessment reports underlying every mine
in the state—an initiative described in more detail below.
In 2012, the state government announced that all of Goa's
460 licensed iron ore traders would have to reapply for
licenses to continue their business; only 186 elected to
re-apply.
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FULL TEXT OF REPORT:
http://www.hrw.org/sites/default/files/reports/india0612ForUpload_0.pdf
