The rumour of Maoism


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IN his classic Elementary Aspects of Peasant Insurgency in Colonial India, Ranajit Guha outlined certain methodological imperatives for the historian who wanted to ‘get in touch with the consciousness of [peasant] insurgency’ when access to it is barred by the discourse of counter-insurgency that structures official records. How does one look beyond this discourse of the state that frames the archives in order to gain access to the voice of the rebels? Guha’s solution was relatively simple: Counter-insurgency, he argued, derives directly from insurgency and is so determined by the latter that ‘it can hardly afford a discourse that is not fully and compulsively involved with the rebel and his activities.’1 

Unlike British Marxist historian E.J. Hobsbawm who had tried to track the story of ‘social bandits’ through a somewhat problematic reading of folklore,2 Guha warned that ‘folklore relating to peasant militancy can be elitist too’, for many singers and balladeers belonged to upper-caste families who had fallen on hard times and were, therefore, often suspicious of the revolt of the lower castes or tribals. Guha underlined that though the records of the colonial state and its police officials registered the voice of those hostile to the insurgents – including landlords and usurers – they could not avoid being shaped by the will of the insurgents. His conclusion therefore was that the presence of rebel consciousness could be read in the body of evidence produced by the discourse of counter-insurgency itself.

The burden of Guha’s argument was that in order to decode the language of counter-insurgency, it was often enough to simply reverse the values in the terms used by the official discourse: thus ‘badmashes’ simply meant peasant militants and not ‘bad characters’; ‘dacoit village’ would indicate an entire village involved in the resistance and ‘contagion’ would most likely refer to the solidarity generated by the uprising.


Those were happier days from the historian’s point of view. For the peasant and tribal insurgencies that Guha was discussing were organic struggles which drew their leadership from amidst the peasants or tribal communities themselves. Whether it was Sidhu-Kanoo, Birsa Munda or Titu Mir – the leadership of the movements and their ‘ideologies’ derived directly from the world of the tribals. The context of colonial India was also, in a significant sense, quite clearly polarized and the possibility of written records being produced from a multiplicity of sources was simply out of the question. It may, therefore, be possible to follow Guha’s suggestion and merely reverse the values in order to get a sense of that other discourse.

In contrast, the methodological challenge for a scholar of contemporary India seems insurmountable. And if any future historian were to explore the Maoist movement of our times, say a hundred years later, she is likely to be completely misled if she decided to follow in Guha’s footsteps. For not only would she or he be confronted with the official discourse of counter-insurgency, there would also be a ‘Maoist discourse’ to contend with – which is almost certainly not the voice of the ‘insurgent peasant’ (or the adivasi).

What this future historian will find in the archives, apart from the standard genre of documents produced by the state and its officials, will be a whole range of writings that claim to speak in the voice of the peasant/adivasi, produced by the state-in-waiting: the Maoist vanguard and their intellectual spokespersons. Among these will be actual party journals, pamphlets and statements, but they will also include a large body of writings produced by academics, journalists, human rights activists and other supporters of the movement.

For our historian-scholar, it will be relatively easy to deal with the documents and reports produced by the state and its officials. The real challenge lies in finding ways of decoding the mass of materials that are produced by the partisans of the movement. For one of the myths being endlessly reiterated in this genre of writings is that of virtually complete identity between the poor adivasi or peasant and the insurgents – a sub-sumption of the adivasi voice into the voice of the Maoist vanguard.


Unlike early colonial India, twenty-first century India is a world saturated by the media – it is indeed a world of media explosion; a world where the media is no longer captive to either the state or corporate elites. We live in an era where public discourse is framed by a multiplicity of voices. And yet, it might well be impossible for our future historian to find even one unfiltered voice of the adivasi – unfiltered, that is, through elite discourse.

The adivasis cannot represent themselves; they must be represented, it would seem. They must be represented either by the agents of the state – the Salwa Judum and Mahendra Karma for example – or by the revolutionaries. Unlike Karma who at least is himself an adivasi, the voice of the revolutionary is almost always that of a Brahman/upper caste Ganapathy or Koteswara Rao or their intellectual spokespersons.

So we have a Maoist-aligned intelligentsia vicariously playing out their revolutionary fantasies through the lives of adivasis, while the people actually dying in battle are almost all adivasis. Take the following killed in West Bengal in recent months: Rajaram Mandi, Lakhinder Mandi and Gopinath Soren on the side of the Maoists and Sadhan Mahato, Tapan Mahato, Barendranath Mahato and Gurucharan Mahato on the CPI(M) side. It will be hard to find a single Bhattacharya, Banerjee, Mukherjee, Basu or such like among the dead.


On the face of it, the list of dead would seem to suggest that the Maoist story is correct and that the entire battle is being fought by and among the adivasis. But as a matter of fact, we do not even know whether the peasant or the adivasi in question is really the ‘insurgent’ we are looking for. I say this in a deliberately provocative vein because a point being repeatedly made by the Maoist-aligned intelligentsia is that to deny that the peasants or adivasis themselves are rising in arms, is to deny ‘them’ agency.

There is a definitional fiat at work here: you are by definition not an agent if you are not a Maoist. Claims like these abound in almost all writings of intellectuals sympathetic to the Maoists. And the only time we hear an actual adivasi voice (filtered, no doubt) is when an Arati Murmu, one of the endlessly harassed people of Lalgarh, assaulted by the police, says: ‘Whenever there is a Maoist attack the police raid our villages and torture our women and children. For how long will we suffer this oppression by the police? All of us are Maoists, let the police arrest us. Today we have come out.’3 


Statements like these have been endlessly retailed by the Maoist-aligned intellectuals in support of their argument that all adivasis are Maoists, as though the meaning of Arati Murmu’s statement is quite so transparent. It is possible that she is actively involved in the Maoist movement, but it is also possible that she is making this statement in exasperation. If Arati Murmu is who she says she is, an ordinary adivasi woman whose fellow-villagers have repeatedly been bearing the brunt of police repression and harassment, then the statement can be read more as an expression of defiance of the police and not necessarily as a true and valid claim that all villagers are now Maoists.

It is indeed true that many adivasis in Lalgarh, Chhattisgarh and many other parts of the country have become Maoists in the face of continued police harassment.4 However, to conclude from this that the only way adivasis become or can become agents is to completely misrepresent the situation.

A related question is that of the ‘organicity’ of the Maoists’ relationship to the adivasis. One of the ways in which Maoist-aligned intellectuals have been countering the charge of appropriating the voice of the adivasis is by claiming that the Maoists are the adivasis, that they are not an external factor in adivasi life – at least in areas of their influence.

Take for example, the following argument which takes historians Sumit Sarkar and Tanika Sarkar to task for criticizing the Maoists.5 According to the author, they argue that ‘the movement in Jangal Mahal had been going quite well until the Maoists entered the scene from outside and derailed the movement… [and] it is the violent activities of the Maoists that brought joint forces into the scene.’6 


The author counters this position by asserting that ‘(T)he reality… is that the Maoists did not fall from the sky; the Maoist Communist Centre and the CPI(ML) People’s War had been active there from the 1980s and 1990s and fought over day to day issues by the people’s side and suffered persecution, molestation and incarceration for years together.’

This apparently is ‘proof’ enough of the Maoists’ deep roots among the adivasis, for the author then proceeds:

‘Their social roots lie in the soil of Jangal Mahal, however disturbing this may sound to these historians and sections of "learned personalities". Thus the statement that the Maoists are external to the movement, that they have entered the scene all of a sudden and taken control of it, does not have any factual basis at all.’7 


I have emphasized the phrases, ‘thus the statement’ and ‘does not have any factual basis’, in order to underline the structure of the argument. The only ‘facts’ that Bhattacharyya refers to is that the MCC and PWG have been active in the area since the 1980s and 1990s and from this it is supposed to follow that they have ‘deep roots’ among the local populace. By that reckoning the RSS and Vishwa Hindu Parishad also must have ‘deep roots’ among the adivasis (often in the same areas!). Let us leave aside the minor possibility that different kinds of political forces can be active in an area without managing to get any significant support from the local population.

The writer then goes on to charge intellectuals like the Sarkars with ‘portraying the masses in a way that these ‘ignorant people are devoid of any initiative of their own, that they are unthinking, unfeeling robots, which can only follow, but cannot lead".’8 

There are a number of issues here that are worthy of consideration. First, the author’s own rendering of the Sarkars’ position indicates that according to them, a movement was already on, and in pretty good health before the Maoists took it over. How is this a ‘denial of agency’ to the adivasis? It would not have been possible for them to hold that position if they had been inclined to ‘portray the masses’ as ‘ignorant’, ‘devoid of initiative’ and ‘robots’ as Bhattacharyya alleges. It is also worth mentioning that the Sarkars’ account is based on the evidence of an active sympathizer of the Lalgarh movement (an activist of the Lalgarh Andolan Sanhati Mancha) who was by no means hostile to the Maoists. My point is that for Maoist-aligned intellectuals, adivasi agency can be recognized only as long as they are the foot soldiers of the Maoists.

Second, the question of agency as it is routinely posed in a number of such writings assumes a simple and unproblematic relationship between the adivasi who becomes Maoist and the Maoist vanguard, i.e. the CPI (Maoist). The fact is that this is precisely where matters are considerably more complex and interesting. Those who pick up the gun and ally themselves with the Maoists are, indeed, not mere unthinking robots or ‘ignorant’ fools – they are agents in more complicated ways than simplistic Maoist-inspired accounts would allow us to see.


In the first place, to merely reassert a commonplace of much historical and political research of recent decades, most people (adivasis and peasants, as opposed to middle class intellectuals) who ‘become Maoists’ do not do so because they agree with their politics, their ‘ideology’ or their programme. They do so because ‘Maoism’ performs some function in a very immediate sense in their lives.

Take the story of Jagadish Mahato – one of the abiding legends of the rise of the Naxalite movement in the Bhojpur region in Bihar. A school teacher by profession, Jagadish Mahato was born into a poor peasant family in the now well-known village of Ekwari. He began his sojourn in politics in the context of the most vicious and unimaginable economic, social and sexual oppression of the local dalit people by upper caste landlords. Till 1968, he was an Ambedkarite of sorts and also published a short-lived newspaper by the name of ‘Harijanistan’. He and his friends also organized demonstrations to raise the demand for Harijanistan but to no avail.

Peaceful struggle against the armed might of the landlords turned out to be utterly ineffective. Then he heard about the ‘Naxalites’ and their activities in Kolkata, in Siliguri and Medinipur. He and Rameshwar Ahir sought them out and established contact with the CPI(ML).9 Thus began the drama of one of the most important segments of the Naxalite movement outside West Bengal. ‘Naxalism’ became the weapon in a battlefield of caste-class conflict. Jagadish Mahto died soon thereafter but the CPI(ML) Liberation struck roots in that region.


There are innumerable stories of similar kind in the history of social and political movements. The ‘movement’ first appears as a rumour in a situation of ongoing battle. To return to our earlier example, Jagadish Mahato could hardly have been an Amebedkarite in the sense we know Amebedkarism today, for the very name Harijanistan gives away the fact that his own self-identity was still being defined within an inherited Gandhian vocabulary.

Ambedkar too was little more than a rumour – the rumour of a leader of the ‘depressed classes’ about whom, possibly many legends were in circulation. And Jagadish Mahato did not have to wait for the ‘real’ Ambedkar or the Naxalites to materialize before he became an agent. He sought out the Naxalites and Charu Mazumdar. Both Ambedkar and Naxalism played the role that he assigned them in his life. The partnership can then carry on or not, depending upon a variety of factors. Mahato died too soon and we do not know what would have happened to his relationship with the CPI(ML). It is possible that he might have refashioned himself completely in order to become a party leader, but that is another story.


It is also well worth bearing in mind that agency is not always about noble struggle. If vanguards are instrumental in ‘using’ people for their purposes, ordinary people who choose to join them can be no less instrumental. Thus for instance, Bela Bhatia’s field work revealed how, ‘There have been instances where individuals have misused such power [as comes from wielding a gun] for private gain.’ ‘Attraction for armed power,’ she found, ‘may lead unprincipled individuals to join the movement.’ Some of them, she went on to observe, ‘formed gangs after running away with the party arms and turned against the party itself (e.g. Jagnandan Yadav group in Bihar).10

It has been argued that exclusive focus on ‘armed struggle’ for ‘capture of state power’ ‘involves intense paranoid secrecy and a normalization of a wartime mentality.’11 It is worth considering what happens when such a situation combines with the ways in which wielding of technologically sophisticated arms shapes subjectivity as suggested by Bhatia’s account. It is also worth considering how it can radically alter the dynamic of ongoing caste/class struggles. Take, for instance, the following report, once again from Jharkhand:

‘The Maoists have not been immune to that fundamental and all-pervasive characteristic of Indian society – caste. Tussles over sharing money, as well as inter-caste clashes between Yadavs and Ganjus, a dalit community, have led to the formation of splinter groups like Tritiya Sammelan Prastuti Committee (TPC) and the Jharkhand Prastuti Committee (JPC). This has come as delightful news to the local administration which often supports one group against the other, and seeks to extract information by providing protection.’12 


Thus to make the argument that whoever joins the Maoists becomes an agent is certainly true if we bear in mind that it is not the agency of a Maoist revolution that is in question here but rather, agency in its precise social-theoretic sense – as belonging to a person who thinks and takes decisions and acts according to them in whatever way possible. S/he is, in that sense, always-already an agent – even if decisions are always implicated in a web of power relations.

It is also clear from many independent accounts that from the late 1980s, resentment has been brewing against the Maoists in Chhattisgarh.13 There is independent corroboration from different quarters that the rise of the Salwa Judum as a state-sponsored counter-insurgency was preceded by a rising discontent against Maoist activities in May-June 2005.

Versions differ as to the reasons for the resentment: In one version, villagers decided to resist the Maoists who had come to take a young girl away from her family as a recruit – this forcible taking of one member from every tribal family being a standard practice of the Maoists. (What this does to the question of agency is best left to the reader to ponder.) Another version points to the Maoist-enforced boycott of trade in tendu leaves against the backdrop of a drought, as the main precipitating factor behind the resentment.14 

These are complicated questions but it is possible to sift through various contending accounts to get a sense of what is actually going on as far as the relationship between the adivasis/ peasants and the Maoists is concerned. In this one sense, our historian is much better placed than Ranajit Guha. And here in these accounts of resentment against the Maoists, we get a glimpse of yet another dimension of adivasi agency, especially in Chhattisgarh but also in some other parts of the Maoist area of influence.


The most recent instance of the complex dynamic that the adivasi-Maoist relations embodies comes from the Jangal Mahal area – precisely the area about which Bhattacharyya (cited earlier) makes his claims against Sumit Sarkar and Tanika Sarkar. This is the story of Gurucharan Kisku alias Marshal, from all accounts an important tribal leader of the Maoists. Kisku reportedly joined the MCC as far back as in 1988 and had arms training in handling all manner of sophisticated arms, including laying and detonating mines.15 It is clear from Kisku’s statements that his main grouse centres on the ‘tribal question’:

‘I decided to quit the party when I realized that it does nothing for the adivasis. In fact, the party is using them as instruments... Kishenji is an outsider who does not know anything about tribals here... Tribals are a social entity with distinct customs, religion and language. The party is destroying this tribal system and way of life in Jangal Mahal and other areas.’16

It is possible that Kisku is particularly bitter at this moment of his break-up with a party and movement he has been involved with for two decades, and this articulation of his complaints could be an exaggerated overstatement. What is undeniable, however, is that in order to express his angst, he draws on an existing discourse among the adivasis populace where certain adivasi cultural practices are seen to be under threat from the Maoists.


Of course, this does not mean that ‘Maoism’ has no social support among the adivasis and peasants and is simply a fantasy of the revolutionary intelligentsia. Maoism exists and indeed, its area of influence has been expanding. It is impossible to reduce the growth of this ‘Maoism’, which arises out of an unstable compact between the political party – the CPI (Maoist) – and the ordinary peasants or adivasis, to any single factor. There are a number of different factors and indeed, different histories, that lie behind the phenomenon. At a superficial level, this difference can be located in the very different histories of the different components that went into the making of the party in its present form, namely the CPI(ML) People’s War (better known as the PWG), the CPI(ML) Party Unity and the Maoist Communist Centre – all of whom had different styles and different kinds of social base.


The history of the PWG goes back to the post-Emergency mass upsurge of the poor peasantry of Karimnagar district and other parts of Telengana in Andhra Pradesh. The primary issues were those of land, wages and vicious forms of caste oppression. ‘The organizational centre’ of this struggle, writes K. Balagopal, ‘was the agricultural labourers union or Raythu Coolie Sangham (generally known as the Sangham), and not the underground armed squads, known as dalams.’17 The struggle was mainly of the unarmed poor, though the Naxalites did kill a few particularly vicious landlords.

Sympathetic critics have noted that this mode of operation continued till well into the 1980s – in the struggles in Adilabad against food shortages where common villagers would loot granaries and shops and redistribute food.18 By 1985, however, as the state’s retaliation, mostly on behalf of the rural rich, began, PWG strategy itself underwent a transformation. Gradually, mass struggles receded to the background and increasingly, their place was taken over by the dalams. However, it is not correct to say that this shift was entirely in response to state retaliation. It was increasingly becoming a short cut, for as the Naxalite legend spread, it struck fear among sections of the landlords – another form in which Naxalism then, as Maoism now, existed as rumour. Often then, mere putting up of the posters demanding a rise in wages, for example, could lead to a rise in wages. The rumour did its work.

The armed intervention of the Naxalites on behalf of the poor provided a counter, a backdrop against which the mass struggles were fought as the movement spread in other parts of Telengana. The arms of the Naxalites fulfilled a social function here that must be clearly recognized: they were a foil to the armed might of the upper/dominant caste landlords and local arms of the state that functioned, always in the interests of the former.


As distinct from the land and wage struggles of this period, the more recent growth of the Maoists, in say Northern Karnataka, was among tribals who were at the point of displacement with the formation of the Kudremukh National Park. Though many other organizations and movements have also been agitating in the area, holding road blockades, ‘storming the forests’, organizing human chains and satyagrahas, the attraction for the Maoists at least among a section of the poorest seems to have been quite evident.19 

Here the conflict was not with the immediate oppressor, namely the landlord. Rather, the perceived threat was from a distant and impersonal force – the state and its officials – and the impending displacement that stared the adivasis in the face. Violence at least had the potential to make news and attract attention to their situation, where satyagrahas, nonviolent actions and human chains have been made completely ineffective and delegitimized by the state and the media.

In places like Lalgarh or in some other parts of Jharkhand too, the prospects of Maoist violence have often seemed liberating in the face of the most vicious nexus of forest contractors, local police and business interests. Elsewhere, I have written about how the state’s repression of all legitimate democratic struggles has made the Maoist option look so attractive that it has ended up eliminating all intermediate spaces of mass politics.20


In the Dandakaranya region, which includes Gadchiroli and the districts of Dantewada, Bastar and Kanker – the current ‘war zones’– there is yet another kind of state and state-sponsored violence that is destroying adivasi life.21 Little surprise that the influence of the Maoists has phenomenally increased over the years. Here the most recent conflicts have been around the renewed drive by the state to industrialize and throw open the mineral rich forest areas to corporations. This clearly involves large-scale displacement of the tribal population from their traditional habitats. Important steel companies like Essar Steel and Tata Steel have been in the process of acquiring prime agricultural land in the area.

Independent reports have testified to the fact that the entire process of land acquisition was being conducted at gun point. Gram sabha meetings, ostensibly meant to discuss and give or withhold consent to land acquisition, were a farce: instead of meetings, individuals were being called in to a room and made to sign their consent – or so the villagers felt.22 Held under heavy armed guard, these meetings were a farce in another sense. Legally, no outsiders are allowed to attend gram sabha meetings but the interested parties, namely Essar Steel officials – in the case of the report cited above – were inside, overseeing the process. As a reporter put it, the same procedure was being followed in other places: Gram sabha ‘meetings’ were held under the shadow of Section 144, while all outspoken critics of the acquisition would be under arrest.


Such stories have been filtering in from researchers in the field for some years now and it was clear that in this new phase of neo-liberal industrialization, a new kind of violence was being unleashed on people who were to be dispossessed in order to make room for mining and industry. In many such cases (for example, Kashipur, Kalinganagar, Singur, Nandigram, Goa, Pen tehsil in Maharashtra), mass struggles have been ongoing for some time.

Even apart from these well-known, emblematic names, there have been innumerable mass struggles throughout the country which have resisted the frenetic drive towards industrialization and mining through displacement, often successfully.

However, it is equally true that often, in the face of the darkest state violence, the prospect of a counter-violence holds great attraction for many people. Maoism seemed to provide precisely such a possibility.

It is important to understand this attraction that sustains the movement. It has become something of a liberal platitude to say that it is lack of ‘development’ that breeds Maoism and that if the adivasis have enough to eat and some basic facilities of education and health, there would be no Maoism. On the other hand, if the above instances are any indication, it would appear that it is rather the frenzied drive towards development that is breeding Maoist politics.

But to see the entire issue merely in terms of ‘development’ or its lack is entirely misleading. For, in the last instance, what is at stake here is neither ‘development’ nor ‘industrialization’; it is justice and democracy. What is at stake here is precisely the fact that in the name of development and industrialization, the common resources of the country are being handed over to private corporations by displacing those who have inhabited that land for centuries. It is also worth remembering that even in the mass rebellions of the early colonial period that Guha studied, violence emerged as a last resort – when everything from petitioning to meetings failed.


It is important to understand that, at one level, it is not Maoism that is really at issue here, as both the state and the Maoist-aligned intellectuals would have us believe. It is really Indian democracy that is at issue. I have argued elsewhere that a deep split structures the Indian polity – a split between ‘sovereignty’ and the rule of the extraordinary and the impulse of democracy.23 

The rule of the extraordinary, as evidenced in the rule through laws like AFSPA or UAPA/POTA/TADA on the one hand, and the indiscriminate manner in which violence becomes the primary mode of dealing with social struggles and dissent on the other, now structures our politics. Thus, even while Indian democracy can become the vehicle for the political rise of the dalits and lower castes, the seduction of violence at its peripheries always remains powerful for that is precisely where democracy gives way to a complete lawlessness of the Law.



1. Ranajit Guha, Elementary Aspects of Peasant Insurgency in Colonial India, Oxford University Press, New Delhi, 1983, p. 15.

2. See Eric J. Hobsbawm, Bandits, Abacus, Great Britain, 2001.

3. Cited in Partho Sarathi Ray, ‘Background of the [Lalgarh] Movement. 13 November 2008’, Sanhati,, last accessed on 24 January 2010.

4. See Aditya Nigam, ‘A Million Mutinies Within’, Tehelka 6(26), 4 July 2009.

5. Sumit Sarkar and Tanika Sarkar, ‘Notes on a Dying People’, Economic and Political Weekly XLIV(26 & 27), 27 June 2009, pp. 10-14.

6. Amit Bhattacharyya, ‘Is Lalgarh Showing the Way?’ Economic and Political Weekly XLV(2), 9-15 January 2010, pp. 17-21. For a similar claim, also see, Saroj Giri, ‘The Dangers Are Great, the Possibilities Immense: The Ongoing Political Movement in India’, Monthly Review, 8 November 2009,, downloaded on 27 January 2010.

7. Ibid., p. 20, emphasis added.

8. Ibid., p. 20.

9. Abhay Kumar Dubey, Kranti ka Atma Sangharsh, Vinay Prakashan, Delhi, 1994, pp. 179-81.

10. Bela Bhatia, ‘On Armed Resistance’, Economic and Political Weekly XLI(29), 22 July 2006, p. 3181.

11. Nivedita Menon, ‘Radical Resistance and Political Violence Today’, Economic and Political Weekly XLIV(50), 12 December 2009, p. 17.

12. Prashant Jha (2009), ‘Complicating the "Naxalite" Debate’, Kafila, debate/, last accessed on 24 January 2010.

13. Human Rights Forum, Death, Displacement and Deprivation. The War in Dantewada: A Report, Human Rights Forum Publication, Hyderabad, 2006.

14. Maureen Nandini Mitra, ‘Red Alert’, Down to Earth, 31 October 2006, p. 23.

15. Ravik Bhattacharya, ‘Kishenji aide quits, says Maoists anti-tribal’, The Indian Express, 8 February 2010, p. 5.

16. Ibid.

17. K. Balagopal, ‘The Limits of Violence’, Himal 20(12), December 2007, p. 44.

18. Ibid., p. 44.

19. See Muzaffar Assadi, ‘Forest Encroachments, Left Adventurism and Hindutva’, Economic and Political Weekly XXXIX(9), 2004, pp. 882-885.

20. Aditya Nigam, ‘Democracy, State and Capital: The "Unthought" of 20th Century Marxism’, Economic and Political Weekly XLIV(51), 19 December 2009.

21. Nandini Sundar, ‘Bastar, Maoism and Salwa Judum’, Economic and Political Weekly XLI(29), 22 July 2006, pp. 3187-3191.

22. See Mitra, op cit., fn. 14, p. 27, .

23. See Aditya Nigam, op cit., fn. 20, 2009.