FOREST RIGHTS ACT, 2006
(As a part of internal assessment in Political Science - General Elective)
Submitted by:
SILVY-142
KHUSHI SINGH- 145
ADITI PRAKASH- 251
JIGYASA YADAV- 342
SHUBHI RATHORE- 447
SHINE MAHAJAN- 561
CONTENTS
TOPIC
PAGE
NUMBER
INTRODUCTION
2-3
HISTORICAL BACKGROUND
4-5
FEATURES OF FRA, 2006
6-7
ARGUMENTS IN FAVOUR OF THE FRA, 2006
8-9
ARGUMENTS AGAINST THE FRA, 2006
10-11
INJUSTICES AND CHALLENGES FACED BY
THE FOREST DWELLER COMMUNITIES
12-13
CHALLENGES
AND
ISSUES
IMPLEMENTATION OF THE FRA, 2006
14-15
IN
WAY FORWARD
16-17
BIBLIOGRAPHY
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1
INTRODUCTION
The intersection of human rights and environmental conservation has garnered increasing
attention in academic discourse and policy arenas worldwide. In this context, the Forest Rights
Act (FRA) of India, enacted in 2006, stands as a pivotal legislative framework that not only
addresses historical injustices against forest-dwelling communities but also emphasizes the
crucial link between indigenous land rights and sustainable environmental stewardship.
The Forest Rights Act (FRA) of India, enacted in 2006, is a landmark legislation aimed at
addressing historical injustices faced by forest-dwelling communities, particularly Scheduled
Tribes and other traditional forest dwellers. It recognizes and vests forest rights and occupation
in these communities, granting legal recognition to their customary rights over ancestral lands
and forest resources. By empowering local communities with control and management
responsibilities, the FRA promotes community-based approaches to environmental governance,
highlighting the crucial link between indigenous land rights and sustainable environmental
stewardship. The Act signifies a departure from colonial-era forest policies that marginalized and
dispossessed indigenous peoples, emphasizing principles of equity, justice, and sustainability.
Despite its transformative potential, the implementation of the FRA has been marred by
challenges such as bureaucratic hurdles, lack of awareness, and resistance from vested interests.
Nevertheless, the Forest Rights Act remains a significant step towards ensuring the rights and
livelihoods of forest-dependent communities while advancing the goals of environmental
conservation and social justice in India.
Forest dwellers and Scheduled Tribes (STs) in India comprise diverse indigenous communities
with deep cultural and historical connections to forest ecosystems. These communities have
traditionally relied on forests for their livelihoods, sustenance, and cultural practices. Scheduled
Tribes, recognized under the Indian Constitution, are marginalized groups often residing in
remote and forested regions. Forest dwellers encompass a broader category of people living in or
near forests, including Scheduled Tribes and other traditional forest-dependent communities.
Both groups face socio-economic challenges, including land dispossession, lack of access to
basic services, and limited representation in decision-making processes, necessitating protective
legislation like the Forest Rights Act.
At its core, the Forest Rights Act embodies principles of equity, justice, and sustainability. By
granting legal recognition to the customary rights of forest-dependent communities over their
ancestral lands, the legislation not only upholds fundamental human rights but also
acknowledges indigenous knowledge and practices integral to biodiversity conservation.
Moreover, by empowering local communities with control and management responsibilities over
forest resources, the FRA promotes community-based approaches to environmental governance,
which are often more effective and equitable than top-down conservation strategies.
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Understanding the Forest Rights Act of India is crucial within the context of a course addressing
human rights and the environment. Firstly, it illustrates the intricate connection between the
protection of human rights and the preservation of natural ecosystems, emphasizing that
environmental conservation cannot be achieved at the expense of indigenous rights and
well-being. Secondly, the FRA serves as a case study for analyzing the complexities of policy
implementation, the role of grassroots movements, and the challenges of balancing conservation
objectives with social justice imperatives.
In this paper, we will delve into the historical background, key provisions, and implementation
challenges of the Forest Rights Act of India, examining its implications for both human rights
discourse and environmental conservation efforts. Through this exploration, we aim to
underscore the significance of integrating indigenous perspectives and rights-based approaches
into environmental policy frameworks, fostering more inclusive and sustainable models of
conservation and development.
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HISTORICAL BACKGROUND
Forests in India have historically been home to various tribal communities, who relied on them
for their livelihoods and saw them as integral to their way of life. Before colonial intervention,
these tribes coexisted with forests sustainably, engaging in practices like Jhum cultivation,
hunting-gathering, and animal herding. However, British colonial interests in commercializing
forest resources led to the imposition of laws that transformed forests from common property
resources to state-owned property. This disrupted the autonomy of tribal communities over their
land, deeming them outsiders on their own territories, and perpetuating a cycle of exploitation
and marginalization.
The Indian Forest Act of 1865 marked the beginning of colonial control over forests and pastures
in India. It was later replaced by a more authoritative legislation in 1878, which categorized
forests into reserve, protected, and village forests, granting colonial authorities power to identify
and demarcate valuable forest land, particularly for railway development. This act was succeeded
by the Indian Forest Act of 1927, which retained the forest categorization and allowed the Forest
Department to declare reserved, protected, and village forests, prohibiting people's access
without approval. It facilitated deforestation for commercial crops, disregarding the rights of
forest dwellers, leading to protests by Scheduled Tribe groups that were ignored by British
rulers.
The colonial forest laws were adopted in post-Independence India’s forest legislation.
Unsurveyed community lands under the Princely States, zamindars and private owners were
transferred to the Forest Department, declaring them as reserved forests, while no concrete
attempt was made to secure forest rights of tribal communities. In the late 1960s, there was a
push for setting up national parks for tigers and other large animals by two social groups - first, a
class of ex-hunters turned conservationists and second, representatives of international agencies,
such as the World Wildlife Fund (WWF) and the International Union for the Conservation of
Nature and Natural Resources (IUCN), seeking to transplant the American system of national
parks on Indian soil. This led to the enactment of The Wildlife (Protection) Act, 1972, under
which national parks and wildlife sanctuaries were established. It has been noted that in this
Western approach to conservation, the needs of the local population have not been taken into
account.
In the 1990s, BD Sharma, the Commissioner for Scheduled Tribes and Scheduled Castes,
highlighted the issue of tribal land dispossession, attributing tribal unrest to the non-recognition
of their land and forest rights. His recommendations prompted the Ministry of Environment and
Forests to issue guidelines for regularizing forest land rights, but these were not effectively
implemented by states. Additionally, a 1996 public interest litigation led the Supreme Court(TN
Godavarman v. Union of India) to order stricter enforcement of forest laws nationwide, resulting
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in the Forest Conservation Act, 1980, being applied to all lands recorded as forests in
government records. This decision brought previously categorized common lands under Forest
Department control, leading to the criminalization of tribal communities who were now
considered encroachers on their own lands.
Consequently, in 1996, the Environment Ministry issued orders to remove ‘encroachers’ from
forest land, leading to large scale evictions of tribal people. The uproar against these evictions
gave a fresh impetus to the tribal rights movement in India, and led to the formation of the
‘Campaign for Survival and Dignity’ in 2002 which spearheaded the demand for the recognition
of forest rights.The CSD employed multi pronged strategies, ranging from campaigns to dialogue
with political parties to litigation, to address the eviction of forest dwellers.
With the change in government in May 2004, the United Progressive Alliance (UPA-1) formed,
supported by Left parties, made significant policy shifts regarding forest dwellers' rights. The
UPA-1 government halted forest evictions and pledged to recognize and restore Scheduled
Tribes' rights, as outlined in the Common Minimum Programme. They conveyed to the Supreme
Court that historically, forest dwellers had been alienated from their lands without viable
livelihood alternatives or compensation. Forest rights groups, led by the Campaign for Survival
and Dignity (CSD), argued against the Ministry of Environment and Forests (MoEF) handling
forest dwellers' rights, advocating instead for the Ministry of Tribal Affairs (MoTA) to draft
legislation. This move, supported by the National Advisory Council under UPA-1, marked a
significant victory for forest rights groups over bureaucratic and conservation opposition.
The draft Bill was initially titled “The Scheduled Tribes (Recognition of Forest Rights) Bill
2005,” and was introduced by the MoTA during the winter session of Parliament on December
13, 2005. After much discussion and a series of deliberations, both within and outside
Parliament, on the nature and process of recognition of forest rights, the Bill was finally passed
in Parliament on December 15, 2006 as the Scheduled Tribes and Other Traditional Forest
Dwellers (Recognition of Forest Rights) Act, 2006 and received the approval of the President on
December 29, 2006. The rules of its implementation were finalised in December 2007, and the
Act came into force on January 1, 2008
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FEATURES OF THE FRA, 2006
The act recognizes and vests the forest rights and occupation in Forest land in forest Dwelling
Scheduled Tribes (FDST) and Other Traditional Forest Dwellers (OTFD)who have been residing
in such forests for generations.
The act also establishes the responsibilities and authority for sustainable use, conservation of
biodiversity and maintenance of ecological balance of FDST and OTFD.It strengthens the
conservation regime of the forests while ensuring livelihood and food security of the FDST and
OTFD. It seeks to rectify colonial injustice to the FDST and OTFD who are integral to the very
survival and sustainability of the forest ecosystem.
The act identifies four types of rights:
Title rights
● It gives FDST and OTFD the right to ownership to land farmed by tribals or forest
dwellers subject to a maximum of 4 hectares.
● Ownership is only for land that is actually being cultivated by the concerned family and
no new lands will be granted.
Use rights
The rights of the dwellers extend to extracting Minor Forest Produce, grazing areas, to pastoralist
routes, etc.
Relief and development rights
To rehabilitation in case of illegal eviction or forced displacement and to basic amenities, subject
to restrictions for forest protection.
Forest management rights
It includes the right to protect, regenerate or conserve or manage any community forest resource
which they have been traditionally protecting and conserving for sustainable use.
Members or community of the Scheduled Tribes who primarily reside in and who depend on the
forests or forest lands for bona fide livelihood needs. It can also be claimed by any member or
community who has for at least three generations (75 years) prior to the 13th day of December,
2005 primarily resided in forest land for bona fide livelihood needs. The Gram Sabha is the
authority to initiate the process for determining the nature and extent of Individual Forest Rights
(IFR) or Community Forest Rights (CFR) or both that may be given to FDST and OTFD. First,
the gram sabha (full village assembly, NOT the gram panchayat) makes a recommendation – i.e
who has been cultivating land for how long, which minor forest produce is collected, etc. The
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gram sabha plays this role because it is a public body where all people participate, and hence is
fully democratic and transparent. The gram sabha’s recommendation goes through two stages of
screening committees at the taluka and district levels. The district level committee makes the
final decision ( section 6(6)). The Committees have six members – three government officers and
three elected persons. At both the taluka and the district levels, any person who believes a claim
is false can appeal to the Committees, and if they prove their case the right is denied (sections
6(2) and 6(4)). Finally, land recognised under this Act cannot be sold or transferred.
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ARGUMENTS IN FAVOUR OF THE FRA, 2006
The Forest Rights Act (FRA) of 2006 is a crucial piece of legislation in India aimed at
recognizing and vesting forest rights and occupation in forest land to forest-dwelling
communities. Here are several arguments in favor of the Forest Rights Act:
Recognition of Rights;
The Forest Rights Act (FRA), 2006 recognizes the rights of the forest dwelling tribal
communities and other traditional forest dwellers to forest resources, on which these
communities were dependent for a variety of needs, including livelihood, habitation and other
socio-cultural needs. The forest management policies, including the Acts, Rules and Forest
Policies of Participatory Forest Management policies in both colonial and post-colonial India,
did not, till the enactment of this Act, recognize the symbiotic relationship of the STs with the
forests, reflected in their dependence on the forest as well as in their traditional wisdom
regarding conservation of the forests. This recognition is crucial for ensuring the livelihood and
well-being of these communities, many of whom have been living in and dependent on forests
for
Social Justice:
The FRA is seen as a measure of social justice, as it seeks to rectify historical injustices faced by
forest-dwelling communities. These communities have often been marginalized and dispossessed
of their traditional lands and resources.
Conservation of Forests:
Contrary to the belief that recognizing community rights over forest land might lead to increased
deforestation, studies have shown that communities with secure rights are often more effective
stewards of their forests. Recognizing community rights can lead to better forest management
and conservation outcomes.
Livelihood Security:
For many forest-dwelling communities, forests are a crucial source of livelihood, providing them
with food, fuel, and other resources. The FRA helps secure these livelihoods by recognizing their
rights over forest land and resources.
Empowerment of Communities:
By recognizing their rights, the FRA empowers forest-dwelling communities to participate in
decision-making processes related to forest management. This can lead to more sustainable and
equitable outcomes for both communities and forests.
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Legal recoginiton:
Prior to the FRA, many forest-dwelling communities lacked legal recognition of their rights,
leading to their marginalization and vulnerability to eviction. The FRA provides a legal
framework for recognizing and protecting these rights.
Democratization:
It has the potential to democratize forest governance by recognising community forest resource
rights over an estimated 85.6 million acres, thereby empowering over 200 million forest
dwellers in over 1,70,000 villages. It will ensure that people get to manage their forest on their
own which will regulate exploitation of forest resources by officials, forest governance and
management as well as tribal rights etc.
Compliance with International Obligations:
The FRA is in line with international agreements and conventions, such as the United Nations
Declaration on the Rights of Indigenous Peoples (UNDRIP), which recognizes the rights of
indigenous peoples to their lands, territories, and resources.
Thus, the Act empowers the forest dwellers to access and use the forest resources in the manner
that they were traditionally accustomed, to protect, conserve and manage forests, protect forest
dwellers from unlawful evictions and provides for basic development facilities for the
community of forest dwellers to access facilities of education, health, nutrition, infrastructure
etc.
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ARGUMENTS AGAINST THE FRA, 2006
The Forest Rights Act (2006), while aimed at addressing historical injustices and recognizing the
rights of forest-dwelling communities in India, has been subject to criticism and scrutiny from
various quarters. Despite its noble intentions, several concerns have been raised regarding its
implementation and impact. The Act has led to adverse consequences for conservation efforts,
hindered development initiatives, and exacerbated conflicts over forest resources. Moreover, the
Act has failed to adequately balance the rights of indigenous communities with the imperative of
environmental protection, leading to a host of socio-economic and ecological challenges. In
examining the Forest Rights Act (2006), it becomes apparent that while it seeks to rectify past
injustices, its implementation has been fraught with complexities and unintended consequences,
raising questions about its efficacy and suitability. Some of the critics of FRA are as follows:
Legislative Competence:
The Act falls outside the legislative competence of the Parliament as it pertains more closely to
land rights than forest-related matters. Critics argue that the Act, by regulating land tenure and
rights in forest areas, infringes upon the domain of state governments, which typically have
jurisdiction over land-related matters. This encroachment on state powers raises concerns about
the centralization of authority and undermines the principles of federalism enshrined in the
Indian Constitution.
Right of Women:
The slow implementation and lack of gender responsiveness have threatened Indigenous people's
survival, particularly indigenous women who are often at the forefront of the fight for their
community's forest rights. Gender-specific provisions in forest policies are limited, leading to
marginalization and vulnerability, especially for widowed or separated women.
Furthermore, patriarchal norms and power dynamics within forest-dwelling communities often
restrict women's participation in community meetings, forest management committees, and other
decision-making forums. This lack of representation undermines women's ability to voice their
concerns, advocate for their interests, and influence decisions related to forest management and
resource allocation. Despite challenges, some Indigenous women, like the Van Raji (a small
forest-dwelling tribal group that inhabit remote, isolated, and ecologically fragile areas of
Uttarakhand) have engaged in decision-making bodies to protect their rights, albeit at personal
costs. Policymakers need to prioritize gender-inclusive forest policies and support Indigenous
women's participation in decision-making processes to achieve socioeconomic progress and
ecological sustainability.
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Impact on sustainable livelihood:
The Forest Rights Act has negatively impacted sustainable livelihoods by leading to conflicts
over resource use, undermining traditional livelihood practices, and exacerbating poverty among
forest-dependent communities. In some cases, the recognition of forest rights has resulted in
unsustainable exploitation of forest resources, leading to ecological degradation and loss of
income opportunities. Additionally, bureaucratic hurdles and delays in implementing the FRA
have hindered communities' access to resources and livelihood opportunities, perpetuating
socio-economic disparities and marginalization. Overall, the FRA's shortcomings have
undermined rather than enhanced sustainable livelihoods for forest-dependent communities.
Encouragement of deforestation:
The FRA has led to an increase in deforestation in certain regions. By granting forest rights to
communities without adequate safeguards for sustainable forest management, there is a risk of
overexploitation of forest resources for short-term gains, leading to long-term ecological
damage.
Impacts on ecological and wildlife conservation efforts:
The Act's provisions for recognizing individual and community forest rights have led to
increased pressure on forest ecosystems, resulting in overexploitation and unsustainable
harvesting practices, particularly for timber and non-timber forest products. This can lead to
habitat degradation, fragmentation, and loss, negatively impacting wildlife populations
dependent on these habitats.
The FRA's decentralized governance structure may hinder effective conservation efforts, as local
communities often lack coordination and oversight in implementing conservation measures. This
can result in fragmented conservation efforts and inconsistent enforcement of environmental
laws and regulations.
The FRA has also been criticized for weakening protected area networks and undermining
conservation efforts in critical biodiversity hotspots. As communities assert their rights over
traditional forest lands, there is a risk of encroachment and fragmentation of protected areas,
disrupting wildlife movement and compromising conservation landscapes. This is particularly
concerning in ecologically sensitive regions like the Western Ghats or the Eastern Himalayas,
where protected areas play a crucial role in preserving unique ecosystems and endangered
species. Balancing the rights of forest-dwelling communities with biodiversity conservation
remains a significant challenge, requiring integrated approaches that prioritize both conservation
and community welfare.
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INJUSTICES AND CHALLENGES FACED BY THE FOREST
DWELLER COMMUNITIES
Pre colonial era:
Before colonialism, indigenous communities typically held customary rights over forests within
their territories, with local communities enjoying various benefits from these forests. While
rulers like kings or chieftains might claim hunting rights in certain forests, other resources within
the forests remained accessible to the local communities.
Colonial era:
During the colonial period, the introduction of the Indian Forest Act in 1878 was grounded in the
concept of 'eminent domain,' asserting the ruler's absolute ownership of all property. This led to
the establishment of the Imperial Forest Department, which aimed to exploit forests for
maximum timber yield and revenue generation while also safeguarding state property from
perceived encroachment by local communities, now labeled as trespassers.
The injustices inherent in this colonial forest policy manifested in various ways. Firstly, forests
were predominantly viewed as a source of timber, resulting in the prohibition of shifting
cultivation. Additionally, the survey and settlement of agricultural lands were incomplete and
biased in favor of the state. 'Forest Villages' were established to ensure a labor force for forestry
operations, where forest land was leased for agricultural purposes to households, predominantly
comprising Adivasis, in exchange for compulsory labor, effectively creating a system akin to
bonded labor.
With forests now classified as state property, access to forest produce was restricted, temporary,
and subject to charges, all under the control of a forest bureaucracy armed with police powers.
Any concessions made to accommodate local livelihood needs were considered 'privileges' that
could be altered or revoked at any time. Even in cases where access was permitted, local
communities lacked the right to manage the forest, as valuable forests were logged by the state,
rendering heavily utilized forests effectively open-access areas.
Post independence era:
Following Independence, little changed in terms of forest governance. The integration of
princely states and zamindari estates into the Union saw forest areas declared as state property
without regard for existing inhabitants, leading to the sudden labeling of long-standing residents
as 'encroachers.'
Subsequently, forest lands were leased out under initiatives like the 'Grow More Food' campaign
to address the needs of a burgeoning population, yet these endeavors lacked proper regulation.
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Displaced individuals from dam projects found themselves without alternative lands and
consequently labeled as 'encroachers' on forest land elsewhere.
Legislation such as the Wildlife (Protection) Act of 1972 and the Forest (Conservation) Act of
1980 (FCA) continued to operate within the framework of eminent domain. Many communities
were forcibly relocated to establish sanctuaries and national parks. In the pursuit of development,
the perspectives of local communities were disregarded, and despite substantial fees, they
received inadequate compensation for the impact on their livelihoods.
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CHALLENGES AND ISSUES IN IMPLEMENTATION OF
THE FRA, 2006
Individual Rights vs. Community Rights:
The implementation of the FRA has been plagued by political opportunism, forester resistance
and bureaucratic apathy, and the discourse around it by deliberate canards and misconceptions In
certain states, politicians have primarily emphasized individual rights, effectively transforming
forest regulation into a scheme focused on regularizing encroachments. This narrow focus
neglects the crucial recognition and safeguarding of community rights, which are fundamental
for fostering sustainable forest management practices.
The recognition of Individual Forest Rights (IFRs) has been inadequately executed, often
hampered by resistance from the Forest Department, indifference from other governmental
entities, and the misuse of technological tools. Claimants encounter significant challenges
throughout the filing process, facing issues such as flawed and opaque rejections and arbitrary
partial acknowledgments of their rights.
Digital Processes in Areas with Poor Connectivity:
The implementation of digital processes, exemplified by initiatives like the VanMitra software in
Madhya Pradesh, presents additional hurdles in regions with poor connectivity and low literacy
rates. This exacerbates existing injustices and impedes the efficient filing and processing of
claims, thereby further marginalizing vulnerable communities and hindering their access to
essential forest resources.
Incomplete Recognition of Community Forest Rights (CFRs):
The slow and incomplete recognition of Community Forest Rights (CFRs) represents a
significant gap in the implementation of the Forest Rights Act (FRA). This reluctance on the part
of the forest bureaucracy to acknowledge these rights has the potential to hinder the
empowerment of local communities in effectively managing their forests.
While some progress has been made in states like Maharashtra, Odisha, and Chhattisgarh
regarding the recognition of CFRs, most states have lagged behind in this regard. Maharashtra's
initiative to activate CFRs by de-nationalizing minor forest produce stands out as a positive step,
although challenges persist, particularly in areas where mining activities are proposed.
Convenient for Conservationists and Development Lobby:
The non-recognition of community rights conveniently aligns with the interests of both staunch
conservationists and the development lobby. Failure to acknowledge these rights leaves
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communities residing in protected areas susceptible to so-called 'voluntary rehabilitation'
schemes, while also opening up forests to exploitation for mining or dam projects without the
need for community consent.
Forest Villages Not Addressed:
Furthermore, the issue of 'forest villages' remains largely unaddressed across many states,
indicating a lack of comprehensive implementation of policies aimed at securing community
rights and ensuring sustainable forest management.
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WAY FORWARD
Reviewing Pending claims expeditiously:
There should be expeditious review of pending and rejected claims of Individual Forest rights
and Community Forest rights. This will ensure betterment and justice for the Tribal and Forest
dwellers.
Role of District level committee:
Regular meetings of district and sub-division level committees will facilitate approval of
Individual Forest rights (IFR) and Community Forest rights (CFR) claims in a time- bound
manner.
Management of community forest resource:
Effective and efficient management of forest resources will have lasting impact on ecology as
well as livelihood of forest dwellers.
Marketing and MSP support:
There is a need to provide marketing and MSP support to non-timber forest products and create
institutional mechanisms to support community forest enterprises for value addition.
Forest Bureaucracy:
The forest bureaucracy should also be reformed to serve as service providers to Gram Sabha.
Informing lower-level officials:
Intensive awareness and information dissemination campaigns are required at local level to
update both tribal and lower- level officials.
Capacity building for inclusive governance:
Strategy of training and capacity building through skill development, awareness drive for
Panchayats, Gram Sabha, village level Forest Rights committee etc, will facilitate good
governance and effective implementation of the FRA-2006.
Availability of required documents:
Digitisation of relevant maps and documents will improve accessibility of required documents to
the Forest rights committee and claimants. It will smoothen the task of the Gram Sabha in
identifying and filing claims for individual and community rights.
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Clarity on time frame:
The act fails to set a specific time limit for resolving claims. Providing clarity on the time limit
for settling claims will benefit beneficiaries and also bring transparency and accountability.
Active role of the Central government:
Centre should take a leading role in taking states on board to honour a law that could change the
lives of vulnerable sections.
Recognition of Community Forest rights (CFR):
The acknowledgement of CFR rights would shift forest governance in India towards a
community conservation regime which leads towards food security and livelihood.
Democratization of Minor Forest Produce (MFP):
Inclusion of more Minor Forest Produce for Minimum selling Price (MSP) will benefit a large
number of families dependent on minor forest produce.
Leveraging modern technology:
Using technology such as Lidar, drone technology, will reduce exclusion and inclusion errors.
Also, decrease time in settling a case.
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BIBLIOGRAPHY
● tribal.nic.in
● www.downtoearth.org.in
● cseindia.org
● Scheduled tribes and other Traditional Forest Dwellers (Recognition of
Forest Rights) Act.
● The Indian Forest Rights Act (2006): A Gender Perspective, Anjoo B.
Sharma
● Indigenous Women’s Struggle for Forest Rights in India, Dipika Adhikar
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