When you deprive people of their right to live in dignity, to hope for a
better future, to have control over their lives, when you deprive them of
that choice, then you expect them to fight for these rights. – Queen Rania
Al Abdullah of Jordan
Human rights are essential for the overall development of individuals. The
Constitution of India makes provisions for basic rights also known as
Fundamental Rights for its citizens as well as for aliens. A distinction is
made between Specific Fundamental Rights and Unspecified Fundamental Rights.
The rights enshrined in the Constitution also at times are at par with the
International Covenant on Civil and Political Right (ICPPR) which is an
international treaty. The ICCPR is applicable to States rather than to
Therefore, rights enshrined therein become the obligation of a
state only when they have been incorporated in the State’s internal law.
After the Universal Declaration of Human Rights by the UN General Assembly
on December 10, 1948, the concept of Human Rights assumed a significance of
its own though earlier than this, International Labour Organisation in 1920
also initiated the Conventions on the rights of workers to form unions and
organisations, abolition of forced labour and right to collective
The UN Charter in 1945 affirmed faith in the fundamental human rights and
appointed a Commission on Human Rights under Mrs. E. Roosevelt. This
declaration was the outcome of the latter’s deliberations A.A. Said aptly
remarked The concept of Human Rights may be difficult to define but
impossible to ignore. The Human Rights are concerned with the dignity of
the individual—the level of self esteem that secures personal identity and
promotes human community.
As defined by OHCHR:
Human rights are rights inherent to all human beings, whatever our
nationality, place of residence, sex, national or ethnic origin, colour,
religion, language, or any other status. We are all equally entitled to our
human rights without discrimination. These rights are all interrelated,
interdependent and indivisible.
Universal human rights are often expressed and guaranteed by law, in the
forms of treaties, customary international law , general principles and
other sources of international law. International human rights law lays down
obligations of Governments to act in certain ways or to refrain from certain
acts, in order to promote and protect human rights and fundamental freedoms
of individuals or groups.
Origin and Development of Human Rights in India
doctrine of non-violence in deed and thought says Nagendra Singh, is a
humanitarian doctrine par excellence, dating back to the third century B.c.
- Jainism too contained similar doctrines.
According to the Gita, he who has no ill will to any being, who is friendly and
compassionate, who is free from egoism and self sense and who is even-minded
in pain and pleasure and patient is dear to God. It also says that divinity
in humans is represented by the virtues of non-violence, truth, freedom
from anger, renunciation, aversion to fault-finding, compassion to living
being, freedom from covetousness, gentleness, modesty and steadiness- the
qualities that a good human being ought to have.
The historical account of
ancient Bharat proves beyond doubt that human rights were as muck manifest
in the ancient Hindu and Islamic civilizations as in the European Christian
civilizations. Ashoka, the prophet Mohammed and Akbar cannot be excluded
from the genealogy of human rights.
Human Rights in British India
The modern version of human rights jurisprudence may be said to have taken
birth in India at tile time of the British rule. When the British ruled
India, resistance to foreign rule manifested itself in the form of demand
for fundamental freedoms and the civil and political rights of the people,
Indians were humiliated and discriminated against by the Britishers. The
freedom movement and the harsh repressive measures of the British rulers
encouraged the fight for civil liberties and fundamental freedoms. Under the
British rule, human rights and democracy were suspect and socialism was an
anathema. In the Indian cultural history, the British colonial period
remains the Indian equivalent of the Dark Ages.
Lord Macaulay rejected the
ancient Indian legal political system as dotages of Brahmanical
, and condemned ancient legal heritage and its inner core as an
immense apparatus of cruel absurdities.
Lord Wellesley condemned the
Indians as vulgar, ignorant, rude and stupid and Lord Cornwallis described
as an axiom that every native of Hindustan is corrupt. The English East
India Company debarred Indians from high offices an3 deprived them of their
political, social and economic rights.
The impression created in the Indian
minds was that their sacred inalienable human rights and vital interests had
been ignored, denied, and trampled upon for the sake of England and the
English rulers. Mahatma Gandhi organised the people of India under his
leadership and launched his non-violent struggle to achieve self-government
and fundamental rights for themselves. Lokmanya Tilak advocated that
freedom was the birth right of Indians for which they will have to
It was because of the stiff opposition from the people of India
that the Charter Act of 1813 was enacted to promote the interest and
happiness of the native inhabitants of India. Similarly, the Government of
India Act, 1833 was passed to allow the Indians to enjoy some political
rights. The proclamation of Queen Victoria on 1 November 1858 contained
:some principles of state policy, which were similar to fundamental rights
in nature. The concrete demand for fundamental rights came logically in the
wake of the nationalist movement , which coincided with the birth of the
Indian National Congress in 1885.
The Constitution of India Bill 1895 known
as the Home Rule Document prepared by the Indian National Congress paved
the way for a constitution guaranteeing everyone of the citizens the basic
human rights like freedom of expression, inviolability of ones own house,
right to property and equality before law. The Government of India Act,
1915, in pursuance of the demands for fundamental rights, guaranteed
equality of opportunity in public services. A series of resolutions adopted
by the National Congress between 1917 and 1919 repeated the demand for civil
rights and equality of status with the English.
Human Rights and The Indian Constitution
The Constitution of the
Republic of India which came into force on 26th January 1950 with 395 Articles
and 8 Schedules, is one of the most elaborate fundamental laws ever adopted. The
Preamble to the Constitution declares India to be a Sovereign, Socialist,
Secular and Democratic Republic. The term democratic
denotes that the Government gets its authority from the
will of the people. It gives a feeling that they all are equal
irrespective of the race, religion, language, sex and culture.
The Preamble to the
Constitution pledges justice, social, economic and political, liberty of
thought, expression, belief, faith and worship, equality of status and of
opportunity and fraternity assuring the dignity of the individual and the
unity and integrity of the nation to aid its citizens.
India was a signatory to the Universal Declaration of Human Rights. A number
of fundamental rights guaranteed ta the individuals in Part III of the
Indian Constitution are similar to the provisions of the Universal
Declaration of Human Rights.
The following chart makes it very clear:
Civil and Political Rights in the Universal Declaration of Human Rights and
in the Indian Constitution
|Equality before law
|Prohibition of discrimination
|Equality of opportunity
|Freedom of speech and expression
|Freedom of peaceful assembly
|Freedom to form associations or unions
|Freedom of movement within border
|Protection ion respect of conviction for
|Protection of life and personal liberty
|Protection of slavery and forced labour
|Freedom of conscience and religion
|Remedy for enforcement of rights
|Right against arbitrary arrest and detention
The table below shows that most of the economic, social and cultural rights
proclaimed in the Universal Declaration of Human Rights have been
incorporated in part IV of the Indian Constitution
Economic, Social and Cultural Rights in the Universal Declaration of Human
Rights and in the Indian Constitution
|Right to work, to just and favourable
condition of work
|Right to equal pay for equal work
|Right to education
|Right to just and favourable remuneration
|Right to rest and leisure
|Right of everyone to a standard of living
adequate for him and family
||Article 39(a), 47
|Right to proper social order
In Keshavnanda Bharati v. State of Kerala, the Supreme Court observed, The
Universal Declaration of Human Rights may not be a legally binding
instrument but it shows how India understood the nature of human rights at
the time the Constitution was adopted.
In the case of Jolly George Varghese v. Bank of Cochin the point involved
was whether a right incorporated in the Covenant on Civil and Political
Rights, which is not recognised in tie Indian Constitution, shall be
available to the individuals in lndia. Justice Krishna Iyer reiterated
dualism and asserted that the positive commitment of the State Parties
ignites legislative action at home but does not automatically make the
Covenant an enforceable part of the Corpus Juris in India. Thus, although
the Supreme Court has stated that the Universal Declaration cannot create a
binding set of rules and that even international treaties may at best inform
judicial institutions and inspire legislative action.
In the judgement given in the Chairman, Railway Board and others v. Mrs. Chandrima Das, the Supreme Court observed that the Declaration has the
international recognition as the Moral Code of Conduct having been adopted
by the General Assembly of the United Nations. The applicability of the
Universal Declaration of Human Rights and principles thereof may have to be
read, if need be, into the domestic jurisprudence.
Fundamental Rights and Human Rights
The judicially enforceable fundamental rights which encompass all seminal
civil and political rights and some of the rights of minorities are
enshrined in part Ill of the Constitution (Articles 12 to 35). These include
the right to equality, the right to freedom, the right against exploitation,
the right to freedom of religion, cultural and educational rights and the
right to Constitutional remedies.
Fundamental rights differ from ordinary rights in the sense that the former
are inviolable. No law, ordinance, custom, usage, or administrative order
can abridge or take them away. Any law, which is violative of any of the
fundamental right, is void.
In ADM Jabalpur v. Shukla
, Justice Beg observed
the object of making certain general aspects of rights fundamental is to
guarantee them against illegal invasion of these rights by executive,
legislative, or judicial organ of the State. Earlier, Chief Justice Subba
Rao in Golak Nath v. State of Punjab
had rightly observed,
Fundamental rights are the modern name for what have been traditionally known as
The Supreme Court of India recognises these fundamental rights as Natural
or Human Rights
. While referring to the fundamental
rights contained in Part Ill of the Constitution, Sikri the then Chief Justice
of the Supreme Court, in Keshavananda Bharati v. State of Kerala
observed, I am unable to hold these provisions to show that rights are not
natural or inalienable rights. As a matter of fact India was a party to the
Universal Declaration of Rights and that Declaration describes some fundamental
rights as inalienable.
The Chief Justice Patanjali
Shastri in State of West Bengal v. Subodh Gopal Bose
fundamental rights as those great and basic rights, which are recognised
and guaranteed as the natu-a1 rights inherent in the status of a citizen of
a free country.
Article 14 of the Indian Constitution proclaims the general right of all
persons to equality before the law, while Article 15 prohibits the State
from discriminating against any citizen on grounds of religion, race, caste,
sex or place of birth, and prohibits any restriction on any citizen’s access
to any public place, including wells and tanks. Equality of opportunity for
all citizens in matters of pubic employment is guaranteed under Article 16.
Article 17 abolishes untouchability and makes its practice an offense
punishable under law.
Both Articles 15 and 16 enable the State to make
special provisions for the advancement of socially and educationally
backward classes, for such castes and tribes as recognized in the
Constitution (known as the Scheduled Castes and Scheduled Tribes) require
very special treatment for their advancement. Article 18 abolishes all
non-military or non-academic titles.
The right to freedom guaranteed to all
citizens under Article 19 encompasses the right to freedom of speech and
expression, the right to assemble peaceably without arms, the right to form
associations or unions, the right to move freely throughout the territory of
India, the right of residence, and the right to practice any profession, or
to carry on any occupation, trade or business.
The protection of a person in
respect of conviction of offense under Article 20 includes protection
against ex post facto criminal laws, the principle of autre fois convict and
the right against self-incrimination. Article 21, the core of all
fundamental rights provisions in the Indian Constitution, ordains: No
person shall be deprived of his life or personal liberty except according to
procedure established by law.
Article 21A was added to the Constitution by
the Eighty Sixth Constitutional Amendment Act 2002. Article 21A proclaims
the State shall provide free and compulsory education to all children of
the age of six to fourteen years in such manner as the State may, by law,
determine. The rights of a person, arrested and detained by the State
authorities, are provided in Article 22. These include the, right to be
informed of the grounds of arrest, the right to legal advice and the right
to be produced before a magistrate within 24 hours of arrest (except where
one is arrested under a preventive detention law).
The right against
exploitation includes prohibition of trafficking in human beings and forced labour (Article 23), and prohibition of employment of children below 14
years of age to work in any factory or mine or in any other hazardous
employment. Subject to public order and morality, all persons are equally
entitled to freedom of conscience and the right to profess, practice and
propagate religion (Article 25). Every religious denomination or section
also has the right to establish and maintain religious institutions and
manage their religious affairs (Article 26). No one may be compelled to pay
any religious taxes (Article 27).
The wholly State-funded educational
institutions are barred from imparting religious instructions (Article
28).10 The rights of any section of citizens or a minority to promote its
distinct language, script or culture, to have access to Statefunded
educational institutions (Article 29), and to establish and maintain
educational institutions of its choice (Article 30) are also guaranteed.10
The right to Constitutional remedies is essentially the right to move the
Supreme Court of India for 2nforcement of the above rights (Article 32). The
Supreme Court is vested with wide Constitutional powers in this regard. They
include the power to issue directions, orders or writs for the enforcement
of the fundamental rights (Article 32(2)). State (i.e. provincial) High
Courts too have identical powers (Article 226).
As laws inconsistent with or
in derogation of the rights conferred by part III of the Constitution are
void (Article 13), the Courts have the power to adjudge the Constitutional
validity of all laws. Furthermore, by virtue of Article 141,the law declared
by the Supreme Court shall be binding on all courts in India. Fundamental
rights guaranteed under the Indian Constitution may be divided, for the sake
of convenience, into two categories viz., specified fundamental rights and
other fundamental rights (rights not specifically enumerated).
In National Legal Services Authority versus U.O.I
(AIR 2014 SC 1863), the
Supreme Court has held that Article 14 does not restrict word ‘person’ and
its application to only males and females and hijras/transgender who are
neither male or female falls within the expression ‘person’. They are
entitled to legal protection of laws in all spheres of state activity
including health care, employment , education as well as equal civil
citizenship rights, as enjoyed by every other citizen of this country.
Naz Foundation v. Govt of NCT of Delhi:-
The Delhi High Court declared
Section 377 of IPC, which criminalizes Homosexuality in India, as
unconstitutional and violative of fundamental rights guaranteed under
Article 14, 15 and 21 of the Constitution. Later on in Suresh Kumar Kaushal
& Anr. V. NAZ Foundation & Others, the Supreme Court of India struck down
the decision of Delhi High Court and held the Section 377 of IPC does not
suffer from any constitutional infirmity and has left on the legislature to
deal with the legality of the Section.
In Romesh Thapar v/s State of Madras
, Patanjali Shastri,CJ, observed that
Freedom of speech & of the press lay at the foundation of all democratic
organization, for without free political discussion no public education, so
essential for the proper functioning of the process of popular government,
is possible. In this case, entry and circulation of the English journal Cross Road, printed and published in Bombay, was banned by the Government
of Madras. The same was held to be violative of the freedom of speech and
expression, as without liberty of circulation, publication would be of
The Hon’ble Supreme Court observed in Union of India v/s Association for
, One-sided information, disinformation, misinformation
and non information, all equally create an uninformed citizenry which makes
democracy a farce. Freedom of speech and expression includes right to impart
and receive information which includes freedom to hold opinions.
Express Newspapers v/s Union of India
, it has been held that the press plays
a very significant role in the democratic machinery. The courts have duty to
uphold the freedom of press and invalidate all laws and administrative
actions that abridge that freedom. Freedom of press has three essential
elements. They are:
- Freedom of access to all sources of information,
- Freedom of publication, and
- Freedom of circulation.
In Sakal Papers v/s Union of India, the Daily Newspapers (Price and Page)
Order, 1960, which fixed the number of pages and size which a newspaper
could publish at a price was held to be violative of freedom of press and
not a reasonable restriction under the Article 19(2). Similarly, in Bennett
Coleman and Co. v/s Union of India, the validity of the Newsprint Control
Order, which fixed the maximum number of pages, was struck down by the Court
holding it to be violative of provision of Article 19(1)(a) and not to be
reasonable restriction under Article 19(2). The Court also rejected the plea
of the Government that it would help small newspapers to grow.
Maneka Gandhi v. Union of India
, the Supreme Court gave a new
dimension to Art. 21 and held that the right to live the right to live is
not merely a physical right but includes within its ambit the right to live
with human dignity. Elaborating the same view, the Court in Francis Coralie
v. Union Territory of Delhi[, observed that:
The right to live includes the right to live with human dignity and all that
goes along with it, viz., the bare necessities of life such as adequate
nutrition, clothing and shelter over the head and facilities for reading
writing and expressing oneself in diverse forms, freely moving about and
mixing and mingling with fellow human beings and must include the right to
basic necessities the basic necessities of life and also the right to carry
on functions and activities as constitute the bare minimum expression of
The Supreme Court in Peoples Union for Democratic Rights v. Union of
, held that non-payment of minimum wages to the workers employed in
various Asiad Projects in Delhi was a denial to them of their right to live
with basic human dignity and violative of Article 21 of the Constitution.
Bhagwati J. held that, rights and benefits conferred on workmen employed by
a contractor under various labour laws are clearly intended to ensure basic
human dignity to workmen. He held that the non-implementation by the private
contractors engaged for constructing building for holding Asian Games in
Delhi, and non-enforcement of these laws by the State Authorities of the
provisions of these laws was held to be violative of fundamental right of
workers to live with human dignity contained in Art. 21.
Vishakha v. State of Rajasthan
, the Supreme Court has declared sexual
harassment of a working woman at her work as amounting to violation of
rights of gender equality and rights to life and liberty which is clear
violation of Articles 14, 15 and 21 of the Constitution. In the landmark
judgment, Supreme Court in the absence of enacted law to provide for
effective enforcement of basic human rights of gender equality and guarantee
against sexual harassment laid down the following guidelines:
- All employers or persons in charge of work place whether in the
public or private sector should take appropriate steps to prevent sexual
harassment. Without prejudice to the generality of this obligation they
should take the following steps:
1. Express prohibition of sexual harassment as defined above at the work
place should be notified, published and circulated in appropriate ways.
2. The Rules/Regulations of Government and Public Sector bodies relating
to conduct and discipline should include rules/regulations prohibiting
sexual harassment and provide for appropriate penalties in such rules
against the offender.
3. As regards private employers steps should be taken to include the
aforesaid prohibitions in the standing orders under the Industrial
Employment (Standing Orders) Act, 1946.
4. Appropriate work conditions should be provided in respect of work,
leisure, health and hygiene to further ensure that there is no hostile
environment towards women at work places and no employee woman should have
reasonable grounds to believe that she is disadvantaged in connection with
- Where such conduct amounts to specific offences under I,P,C, or under
any other law, the employer shall initiate appropriate action in accordance
with law by making a complaint with appropriate authority.
- The victims of Sexual harassment should have the option to seek
transfer of perpetrator or their own transfer.
In Jeeja Ghosh V UOI , Supreme Court asked the SpiceJet Ltd to pay Rupees
Ten Lakhs to Jeeja Ghosh, an eminent activist involved in disability rights,
for forcibly de-boarding her by the flight crew, because of her disability.
Apex Court bench comprising of Justices A.K. Sikri and R.K. Agrawal also
issued the guidelines with regard to ‘carriage’ by persons with disabilities
and/or persons with reduced mobility and observed that People with
disabilities also have the Right to live with dignity
In Parmananda Katara v. Union of India, the Supreme Court has very
specifically clarified that preservation of life is of paramount importance.
The Apex Court stated that ‘once life is lost, status quo ante cannot be
restored.’ It was held that it is the professional obligation of all doctors
(government or private) to extent medical aid to the injured immediately to
preserve life without legal formalities to be complied with the police.
Article21 casts the obligation on the state to preserve life. It is the
obligation of those who are in charge of the health of the community to
preserve life so that the innocent may be protected and the guilty may be
In Jagmohan v. State of U.P, the Supreme Court had held that death penalty
was not violative of articles 14, 19 and 21.it was said that the judge was
to make the choice between death penalty and imprisonment for life on the
basis of circumstances, facts and nature of crime brought on record during
trail. Therefore, the choice of awarding death sentence was done in
accordance with the procedure established by law as required under article
In M.H. Hoskot v. State of Maharashtra, the Supreme Court said while
holding free legal aid as an integral part of fair procedure the Court
explained that the two important ingredients of the right of appeal are;
firstly, service of a copy of a judgement to the prisoner in time to enable
him to file an appeal and secondly, provision of free legal service to the
prisoner who is indigent or otherwise disabled from securing legal
assistance. This right to free legal aid is the duty of the government and
is an implicit aspect of Article 21 in ensuring fairness and reasonableness;
this cannot be termed as government charity.
The judgment by the Supreme Court of India in Justice K.S. Puttaswamy (Retd)
vs Union of India is a resounding victory for privacy. The ruling is the
outcome of a petition challenging the constitutional validity of the Indian
biometric identity scheme Aadhaar. The judgments ringing endorsement of the
right to privacy as a fundamental right marks a watershed moment in the
constitutional history of India.
The one-page order signed by all nine judges declares:
The right to privacy is protected as an intrinsic part of the right to life
and personal liberty under Article 21 and as a part of the freedoms
guaranteed by Part III of the Constitution.
Recent Events of Human Rights Violation
Limits on free speech and attacks on religious minorities, often led by
vigilante groups that claim to be supporters of the ruling Bharatiya Janata
Party (BJP), are an increasing concern in India. In 2016, students were
accused of sedition for expressing their views; people who raised concerns
over challenges to civil liberties were deemed anti-Indian; Dalits and
Muslims were attacked on suspicion they had killed, stolen, or sold cows for
beef; and nongovernmental organizations (NGOs) came under pressure due to
India’s restrictive foreign funding regulations.
A crackdown on violent protests in Jammu and Kashmir beginning in July
killed over 90 people and injured hundreds, fueling further discontent
against government forces. Impunity for police and security forces largely
continued amid new allegations of torture and extrajudicial killings,
including reports of sexual assault and other abuses by security forces in
the central Indian state of Chhattisgarh.
There were also some positive developments in 2016. The Narendra Modi
government took steps toward ensuring greater access to financial services
such as banking, insurance, and pensions for economically marginalized
Indians and launched a campaign to make modern sanitation available to more
households. In July, the Supreme Court of India took a strong stand against
impunity for security forces, ruling that the Armed Forces (Special Powers)
Act (AFSPA) does not protect soldiers from prosecution for abuses committed
while deployed in internal armed conflicts. The court also gave new life to
a challenge to a discriminatory colonial-era law criminalizing
Treatment of Dalits, Tribal Groups, and Religious Minorities
Hindu vigilante groups attacked Muslims and Dalits over suspicions that they
had killed, stolen, or sold cows for beef. The violence took place amid an
aggressive push by several BJP leaders and militant Hindu groups to protect
cows and ban beef consumption.
In March 2016, a Muslim cattle trader, Mohammed Mazlum Ansari, 35, and a
12-year-old boy, Mohammed Imteyaz Khan, were found hanging from a tree in
Jharkhand state, their hands tied behind their backs and their bodies
bruised. In August, a man was killed in Karnataka state by members of a
nationalist Hindu group while transporting cows.
In July, four men in Gujarat were stripped, tied to a car, and publicly
beaten with sticks and belts over suspicions of cow slaughter.
The government’s continuing failure to rein in militant groups, combined
with inflammatory remarks made by some BJP leaders, has contributed to the
impression that leaders are indifferent to growing intolerance.
A 2016 report on caste-based discrimination by the UN special rapporteur on
minority issues noted that caste-affected groups continue to suffer
exclusion and dehumanization. In January, the suicide of Rohith Vemula, a
25-year-old Dalit student, drew renewed attention to entrenched caste-based
discrimination in Indian society, and sparked nationwide protests by
students and activists calling for reforms in higher education.
In June, a special court in Gujarat convicted 24 people for their
involvement in the mass killing of 69 people by a Hindu mob in Gulberg
Society, a Muslim neighborhood in Ahmedabad, during the 2002 Gujarat riots.
While pronouncing the verdict, the court called the killings the darkest
day in the history of civil society. But some victims’ families, lawyers,
and rights activists criticized the acquittals of senior BJP leaders and a
Freedom of Speech
The Indian authorities routinely use vaguely worded, overly broad laws as
political tools to silence and harass critics.
Authorities continue to use sedition and criminal defamation laws to
prosecute citizens who criticize government officials or oppose state
policies. In a blow to free speech, the government in 2016 argued before the
Supreme Court in favor of retaining criminal penalties for defamation. The
court upheld the law.
In February, authorities arrested three students at the Jawaharlal Nehru
University in Delhi under the sedition law for alleged anti-national speech,
acting on complaints by members of the Akhil Bharatiya Vidyarthi Parishad (ABVP),
the student wing of the ruling BJP. These arrests led to widespread protests
over the arbitrary use of the sedition law.
In August, police in southern Karnataka state filed a sedition case against
Amnesty International India based on a complaint by ABVP, alleging that
anti-Indian slogans were raised at a meeting organized by Amnesty on abuses
in Kashmir. Police later claimed, however, that they did not have sufficient
evidence to proceed with charges. The same month, an actor-turned-politician
in the state also faced sedition charges after she praised the friendship
and courtesy she received in Pakistan.
In August, the Karnataka High Court called the state government clearly
paranoid for pressing sedition charges against three people, including two
former policemen, for organizing a protest seeking better police wages and
In Chhattisgarh, journalists, lawyers, and civil society activists faced
harassment and arrest. In March 2016, the Editors Guild
of India reported that media in Chhattisgarh state were working under
tremendous pressure from authorities, Maoist rebels, and vigilante groups.
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