COURTS IN INDIA
The Supreme Court is the highest court. Its duties include interpreting the constitution, handling disputes between the states, and judging appeals from lower courts. Below it are high courts, followed by a hierarchy of subordinate courts, and some states also have panchayat (village-level) courts that decide civil and criminal matters. Some high courts serve more than one state, and all are independent of state legislatures and executives. The judiciary is regarded as slow and cumbersome but is also widely respected and often takes an activist role in protecting citizens’ rights. [Source: Library of Congress, 2005]
India's state courts are unusual among those of other federal systems in that they do not function as separate units. The system is integrated. At the lower levels, the judiciary is largely self-selecting, with senior judges appointing their colleagues from within the judiciary to positions. [Source: Robert S. Robins, Governments of the World: A Global Guide to Citizens' Rights and Responsibilities, Thomson Gale, 2006]
Paul Hockings wrote: The huge legal profession helps push cases slowly through the complex apparatus of magistrates' and higher-level courts, sometimes creating the impression that litigation is a national sport. While fines and imprisonment are the most common punishments, the Supreme Court has upheld the legality of the death penalty. [Source:Paul Hockings, Countries and Their Cultures, Gale Group Inc., 2001]
Each state’s judicial system is headed by a high court, often called the Supreme Court of a given state. There are 25 such courts. Judgments from these courts may be appealed to the supreme court. Islamic law (Shariah) governs many non-criminal matters involving Muslims, including family law, inheritance, and divorce. In mid-2011 India’s Cabinet approved the program, National Mission for Justice Delivery and Legal Reform, to eliminate judicial corruption and reduce the backlog of cases. India has a Labour Court.
Functioning of the Legal System in India
Robin Pagnamenta wrote in The Times; Beneath its gothic spires and in its vaulted stone corridors little appears to have changed at the Bombay High Court since 1879, when it was completed under the direction of the British colonial engineer Colonel James Fuller. Barristers in flowing black gowns and flap collars mingle with judges and clerks wearing elaborate red hats and clutching piles of documents tied up with ribbons in a scene more reminiscent of Charles Dickens than contemporary South Asia. In few other areas of public life have the traditions and practises of the Raj era survived so intact.[Source: Robin Pagnamenta, The Times, January 3 2013]
“India’s use of common law inherited from the British and its legal system’s close resemblance to other Anglo-Saxon countries, such as the United States and Canada, are cited sometimes as an advantage for foreign investors. But for anyone with real-life experience of India’s courts, that would seem an eccentric point of view. For all its familiarity and pageantry, the country’s legal system is an antiquated mess. Gummed up with more than 32 million pending cases, one study estimated that it would take India’s overloaded courts 320 years simply to clear the backlog. The sentencing in 2010 of seven former Union Carbide executives to prison terms for their role in the Bhopal gas leak — 25 years after the disaster that killed more than 22,000 people — is an extreme example of delayed justice. Thousands of less high-profile cases drag on for 20 years or more.
“Plagued with corruption and an acute shortage of judges, the situation has spawned a legal culture where lawyers, adept at seeking long adjournments, use the nation’s overburdened courts as a tool. Clients know that they can easily tie up commercial disputes for years, until they are forgotten or can be settled out of court.
“For companies operating in India, all of this is bad news. Far from embracing India’s courts, a growing number are actively avoiding them. When Telenor, the Norwegian telecoms group, fell into a dispute with Unitech, its Indian partner, they agreed to hold formal arbitration talks in Singapore rather than India. Even Indian companies are opting to include clauses in their contracts that allow for the use of courts outside India to settle disputes.
“Delhi claims to be trying to tackle the situation. Veerappa Moily, the Law Minister, unveiled a package of reforms recently designed to improve legal education and to cut the average duration of court cases from fifteen years to three, but many experts are sceptical that this is possible any time soon. In the meantime, the Bombay High Court will muddle on through, offering a valuable glimpse into India’s past but doing little to secure its future prosperity.
Long Delays in the Indian Legal System
The old adage that justice delayed is justice denied seems especially apt in India. Delays are one of the biggest problems with the Indian legal system. Civil cases are routinely drown out for more than 10 years. It is not unusual for a case first judged in the 1980s to still be in court.
As of 2000, there were around 25 mullion cases pending and according to one estimate it would take 324 years to clear them all form the docket. This is especially disturbing when you consider that the 90 percent of the cases end in acquittal. One man had to an endure an 18 year trial for improperly changing his voter registration when he moved to a new address.
The New York Times described a case in which a meatcutter sued his neighbor, a milk merchant, for building a brick wall on the edge of his property with a drain that emptied on the meatcutters property. The cases went on for over 40 years and involved several hundred court cases. [Source: Barry Bearak, June 2, 2000]
The initial decision was made relatively quickly in the meatcutter's favor in 1963 but the cases case got bogged down after the milk merchant appealed. The appeal of the case took 13 years to receive a hearing and then was sent back to lower courts, where the cases appeared on the docket once or twice a month but was adjourned or postponed for various reasons. The meatcutter and milk merchant died in the middle of case and the appeal was carried on by their sons.
See Separate Article: LONG DELAYS IN THE INDIAN LEGAL SYSTEM factsanddetails.com
Supreme Court of India
The Supreme Court of India is comprised of 28 judges, including the Chief Justice. Judges are appointed by the President of India. The Supreme Court has numerous legal powers, such as appellate jurisdiction over all civil and criminal proceedings, with the potential of influencing interpretation of the constitution. The parliament and Supreme Court have maintained a contentious relationship on issues related to judicial review and parliamentary sovereignty. Below the Supreme Court are high courts, followed by a hierarchy of subordinate courts. Supreme Court Judges retire upon attaining the age of 65 years.[Sources: Library of Congress, 2005; CIA World Factbook, 2023]
The supreme court's duties include interpreting the constitution and judging appeals from lower courts. The Supreme Court is the ultimate interpreter of the constitution and the laws of the land. It has appellate jurisdiction over all civil and criminal proceedings involving substantial issues concerning the interpretation of the constitution. The court has the original and exclusive jurisdiction to resolve disputes between the central government and one or more states and union territories as well as between different states and union territories. And the Supreme Court is also empowered to issue advisory rulings on issues referred to it by the president. The Supreme Court has wide discretionary powers to hear special appeals on any matter from any court except those of the armed services. It also functions as a court of record and supervises every high court. [Source: Library of Congress, 1995; Worldmark Encyclopedia of Nations, Thomson Gale, 2007]
Associate justices as well as judges are appointed by the president after consultation with the chief justice and, if the president deems necessary, with other associate justices of the Supreme Court and high court judges in the states. The appointments do not require Parliament's concurrence. Justices may not be removed from office until they reach mandatory retirement age. unless each house of Parliament passes, by a vote of two-thirds of the members in attendance and a majority of its total membership, a presidential order charging "proved misbehavior or incapacity."
The independence of the Supreme Court is protected by the fact that members can be removed only through a complex process involving the president and an overwhelming majority of both houses of parliament. The only grounds for removal are incapacity (e.g., serious illness) and misconduct (e.g., corruption).[Source: Robert S. Robins, Governments of the World: A Global Guide to Citizens' Rights and Responsibilities, Thomson Gale, 2006]
Issues Involving the Supreme Court of India
“The contradiction between the principles of parliamentary sovereignty and judicial review that is embedded in India's constitution has been a source of major controversy over the years. After the courts overturned state laws redistributing land from zamindar estates on the grounds that the laws violated the zamindars' Fundamental Rights, Parliament passed the first (1951), fourth (1955), and seventeenth amendments (1964) to protect its authority to implement land redistribution. The Supreme Court countered these amendments in 1967 when it ruled in the Golaknath v State of Punjab case that Parliament did not have the power to abrogate the Fundamental Rights, including the provisions on private property. On February 1, 1970, the Supreme Court invalidated the government-sponsored Bank Nationalization Bill that had been passed by Parliament in August 1969. The Supreme Court also rejected as unconstitutional a presidential order of September 7, 1970, that abolished the titles, privileges, and privy purses of the former rulers of India's old princely states.
“In reaction to Supreme Court decisions, in 1971 Parliament passed the Twenty-fourth Amendment empowering it to amend any provision of the constitution, including the Fundamental Rights; the Twenty-fifth Amendment, making legislative decisions concerning proper land compensation nonjusticiable; and the Twenty-sixth Amendment, which added a constitutional article abolishing princely privileges and privy purses. On April 24, 1973, the Supreme Court responded to the parliamentary offensive by ruling in the Keshavananda Bharati v the State of Kerala case that although these amendments were constitutional, the court still reserved for itself the discretion to reject any constitutional amendments passed by Parliament by declaring that the amendments cannot change the constitution's "basic structure."
“During the 1975-77 Emergency, Parliament passed the Forty-second Amendment in January 1977, which essentially abrogated the Keshavananda ruling by preventing the Supreme Court from reviewing any constitutional amendment with the exception of procedural issues concerning ratification. The Forty-second Amendment's fifty-nine clauses stripped the Supreme Court of many of its powers and moved the political system toward parliamentary sovereignty. However, the Forty-third and Forty-fourth amendments, passed by the Janata government after the defeat of Indira Gandhi in March 1977, reversed these changes. In the Minerva Mills case of 1980, the Supreme Court reaffirmed its authority to protect the basic structure of the constitution. However, in the Judges Transfer case on December 31, 1981, the Supreme Court upheld the government's authority to dismiss temporary judges and transfer high court justices without the consent of the chief justice.
“The Supreme Court continued to be embroiled in controversy in 1989, when its US$470 million judgment against Union Carbide for the Bhopal catastrophe resulted in public demonstrations protesting the inadequacy of the settlement. In 1991 the first-ever impeachment motion against a Supreme Court justice was signed by 108 members of Parliament. A year later, a high-profile inquiry found Associate Justice V. Ramaswamy "guilty of willful and gross misuses of office . . . and moral turpitude by using public funds for private purposes and reckless disregard of statutory rules" while serving as chief justice of Punjab and Haryana. Despite this strong indictment, Ramaswamy survived parliamentary impeachment proceedings and remained on the Supreme Court after only 196 members of Parliament, less than the required two-thirds, voted for his ouster.
“During 1993 and 1994, the Supreme Court took measures to bolster the integrity of the courts and protect civil liberties in the face of state coercion. In an effort to avoid the appearance of conflict of interest in the judiciary, Chief Justice Manepalli Narayanrao Venkatachaliah initiated a controversial model code of conduct for judges that required the transfer of high court judges having children practicing as attorneys in their courts. Since 1993, the Supreme Court has implemented a policy to compensate the victims of violence while in police custody. On April 27, 1994, the Supreme Court issued a ruling that enhanced the rights of individuals placed under arrest by stipulating elaborate guidelines for arrest, detention, and interrogation.
High Courts in India
India is divided into 28 states and 8 union territories,, There are 25 High Courts in India, with six having control over more than one state/ or union territory. Delhi has a High Court of its own among the Union Territories. Some high courts serve more than one state or union territory. For example, the high court of the union territory of Chandigarh also serves Punjab and Haryana, and the high court in Gauhati (in Meghalaya) serves Assam, Nagaland, Meghalaya, Mizoram, Manipur, Tripura, and Arunachal Pradesh. [Source: Library of Congress, 1995 *]
The Superior Courts are subordinate to, but not under the control of, the Supreme Court. Each state's judicial system is headed by a supreme court, whose judges are appointed by the president and over whom state legislatures have no control. Supreme Court justices can serve until the age of 62. Each state is divided into districts; within each district, a hierarchy of civil courts is responsible to the main civil courts, which are presided over by a district judge. The Criminal Procedure Code of 1973, which came into force on April 1, 1974, provides for the appointment of separate sets of magistrates to perform executive and judicial functions within the criminal court system. Executive magistrates are responsible to the state government; judicial magistrates are under the control of the Supreme Court in each state.[Source: Worldmark Encyclopedia of Nations, Thomson Gale, 2007]
As part of the judicial system, the high courts are institutionally independent of state legislatures and executives. The president appoints state high court chief justices after consulting with the chief justice of the Supreme Court and the governor of the state. The president also consults with the chief justice of the state high court before he appoints other high court justices. Furthermore, the president may also exercise the right to transfer high court justices without consultation. These personnel matters are becoming more politicized as chief ministers of states endeavor to exert their influence with New Delhi and the prime minister exerts influence over the president to secure politically advantageous appointments. *
Each high court is a court of record exercising original and appellate jurisdiction within its respective state or territory. It also has the power to issue appropriate writs in cases involving constitutionally guaranteed Fundamental Rights. The high court supervises all courts within its jurisdiction, except for those dealing with the armed forces, and may transfer constitutional cases to itself from subordinate courts. The high courts have original jurisdiction on revenue matters. They try original criminal cases by a jury, but not civil cases.
Describing a courtroom of a state Chief Justice, Simon Winchester wrote in Smithsonian, "two perspiring men in dark suits and white-tab collars, presiding over a courtroom filed with similarly dressed and similarly sweating lawyers, each waiting his turn to present a petition. The first lawyer stood, and with great rhetorical flourish began to 'Humbly submit' and utter phases like 'May it please the court' and 'Could I kindly approach, Your Lordship'...It was quite difficult to understand him fully, so flowery was the language."
Lower Courts in India
States are divided into districts (zillas ), and within each a judge presides as a district judge over civil cases. A sessions judge presides over criminal cases. The judges are appointed by the governor in consultation with the state's high court. District courts are subordinate to the authority of their high court. [Source: Library of Congress, 1995 *]
There is a hierarchy of judicial officials below the district level. Many officials are selected through competitive examination by the state's public service commission. Civil cases at the subdistrict level are filed in munsif (subdistrict) courts. Lesser criminal cases are entrusted to the courts of subordinate magistrates functioning under the supervisory authority of a district magistrate. All magistrates are under the supervision of the high court. At the village level, disputes are frequently resolved by panchayats or lok adalats (people's courts).
Describing a courtroom in a low-level civil court, Barry Bearak wrote in the New York Times, "The courtrooms are spare and shabby, with bare lightbulbs, broken furniture and overtaxed ceiling fans. Frayed wired dangle like old yarn from peeling yellow walls....Outside under trees, documents are produced by men hunched over manual typewriters; copies are made with carbon paper. Lawyers work out of open stalls, the more prominent ones laying claim to space with a roof, others with merely a sign amid the weeds. Cows and goats, much like the plaintiffs and defendants, wander around listlessly, trying to evade the sun. Water is drawn from a hand pump above a tube well...Each day, a list of 50 cases is posted in every courtroom, leaving a crowd of attorneys and clients waiting at the rear of the chambers like frustrated diners at an overbooked restaurant.”
Describing a courtroom in a middle-ranking civil court, Winchester wrote in Smithsonian, "The crowds were terrific. Under a row of thatched eaves a hundred men with battered typewriters were hammering out petition documents in English for supplicants who either could not read at or had little command of the tongue. Twenty rupees a page seemed the average copy charge."
Muslim Laws and Courts in India
Muslim follow their laws in civil matters. Mughal law and administration based on established schools of Muslim law served as the basis of British law and administration in India. Persian was the language of the law courts and the civil service early in the British period.
In many cases, Indian Muslims follow their own laws rather than Indian law. Muslims have separate civil laws that govern marriage, divorce and property rights. Muslim laws are sometimes spelled out in the Koran. Other times they are simply Muslim tradition. The Indian government permitted the arrangement so that Muslims would be less fearful of being persecuted by the Hindu majority.
Even though Indian law prohibits teenage marriage, Muslim girls often marry when they are 15 or under because according to Muslim tradition a girl is allowed to marry once she has begun to menstruate. In most cases parents simply lie about their child's age, something that is easy to do because birth certificates are uncommon, and have Muslim clerics sanctify the marriage. In 2002, a board that oversees the details of Muslim personal laws, argued that the 1929 Child Marriage Restraint Act does not apply to Muslims.
Muslims can also obtain an divorce quickly and don’t have to pay alimony while Hindu have to go through an exhausting and expensive legal process to settle these matters. Muslim tradition often affords near total discretion in matters of marriage, family and divorce. Wife beating, for example, is considered a private matter that authorities should keep out of.
Sentencing Guidelines in India
In India neither the legislature nor the judiciary has issued structured sentencing guidelines. Several governmental committees have pointed to the need to adopt such guidelines in order to minimize uncertainty in awarding sentences. The higher courts, recognizing the absence of such guidelines, have provided judicial guidance in the form of principles and factors that courts must take into account while exercising discretion in sentencing. [Source: Library of Congress Law Library Legal Reports, 2014 |*|]
In India neither the legislature nor the judiciary has issued structured sentencing guidelines. Several governmental committees have pointed to the need to adopt such guidelines in order to minimize uncertainty in awarding sentences. The higher courts, recognizing the absence of such guidelines, have provided judicial guidance in the form of principles and factors that courts must take into account while exercising discretion in sentencing. |*|
In 2013 the Supreme Court, in the case of Soman v. State of Kerala, observed that “the impossibility of laying down standards is at the very core of the Criminal law as administered in India, which invests the Judges with a very wide discretion in the matter of fixing the degree of punishment.”
Sentencing procedure is established under the Code of Criminal Procedure, which provides broad discretionary sentencing powers to judges. In a 2007 paper on the need for sentencing policy in India, author R. Niruphama asserted that, in the absence of an adequate sentencing policy or guidelines, it comes down to the judges to decide which factors to take into account and which to ignore. Moreover, he considered that broad discretion opens the sentencing process to abuse and allows personal prejudices of the judges to influence decisions. |*|
In regard to a murder case The Court in Sangeet concluded: In the sentencing process, both the crime and the criminal are equally important. We have, unfortunately, not taken the sentencing process as seriously as it should be with the result that in capital offences, it has become judge-centric sentencing rather than principled sentencing. |The Constitution Bench of this Court has not encouraged standardization and categorization of crimes and even otherwise it is not possible to standardize and categorize all crimes. |The grant of remissions is statutory. However, to prevent its arbitrary exercise, the legislature has built in some procedural and substantive checks in the statute. These need to be faithfully enforced. |*|
Absence of Structured Sentencing Guidelines in India
Currently India does not have structured sentencing guidelines that have been issued either by the legislature or the judiciary. In March 2003, the Committee on Reforms of Criminal Justice System (the Malimath Committee), a body established by the Ministry of Home Affairs, issued a report that emphasized the need to introduce sentencing guidelines in order to minimize uncertainty in awarding sentences, stating: The Indian Penal Code prescribed offences and punishments for the same. For many offences only the maximum punishment is prescribed and for some offences the minimum may be prescribed. The Judge has wide discretion in awarding the sentence within the statutory limits. There is now no guidance to the Judge in regard to selecting the most appropriate sentence given the circumstances of the case. Therefore each Judge exercises discretion accordingly to his own judgment. There is therefore no uniformity. Some Judges are lenient and some Judges are harsh. Exercise of unguided discretion is not good even if it is the Judge that exercises the discretion. In some countries guidance regarding sentencing option[s] is given in the penal code and sentencing guideline laws. There is need for such law in our country to minimise uncertainty to the matter of awarding sentence. There are several factors which are relevant in prescribing the alternative sentences. This requires a thorough examination by an expert statutory body. |[Source: Library of Congress Law Library,Legal Reports, 2014 |*|]
The Committee advised further that, in order to bring “predictability in the matter of sentencing, ” a statutory committee should be established “to lay guidelines on sentencing guidelines under the Chairmanship of a former Judge of Supreme Court or a former Chief Justice of a High Court experienced in criminal law with other members representing the prosecution, legal profession, police, social scientist and women representative.” In 2008, the Committee on Draft National Policy on Criminal Justice (the Madhava Menon Committee), reasserted the need for statutory sentencing guidelines. In an October 2010 news report, the Law Minister is quoted as having stated that the government is looking into establishing a “uniform sentencing policy” in line with the United States and the United Kingdom in order to ensure that judges do not issue varied sentences. |*|
In 2008, the Supreme Court of India, in State of Punjab v. Prem Sagar & Ors., also noted the absence of judiciary-driven guidelines in India’s criminal justice system, stating, “[i]n our judicial system, we have not been able to develop legal principles as regards sentencing. The superior courts[, ] except [for] making observations with regard to the purport and object for which punishment is imposed upon an offender, had not issued any guidelines.” The Court stated that the superior courts have come across a large number of cases that “show anomalies as regards the policy of sentencing, ” adding, “[w]hereas the quantum of punishment for commission of a similar type of offence varies from minimum to maximum, even where [the] same sentence is imposed, the principles applied are found to be different. Similar discrepancies have been noticed in regard to imposition of fine[s].” In 2013 the Supreme Court, in the case of Soman v. State of Kerala, also observed the absence of structured guidelines:
Giving punishment to the wrongdoer is at the heart of the criminal justice delivery, but in our country, it is the weakest part of the administration of criminal justice. There are no legislative or judicially laid down guidelines to assist the trial court in meting out the just punishment to the accused facing trial before it after he is held guilty of the charges. |*|
Criteria for Sentencing in India
In the Supreme Court’s judgment in Soman v. Kerala, the Court cited a number of principles that it has taken into account “while exercising discretion in sentencing, ” such as proportionality, deterrence, and rehabilitation. As part of the proportionality analysis, mitigating and aggravating factors should also be considered, the Court noted. [Source: Library of Congress Law Library Legal Reports, 2014 |*|]
In State of M.P. v. Bablu Natt, the Supreme Court stated that “[t]he principle governing imposition of punishment would depend upon the facts and circumstances of each case. An offence which affects the morale of the society should be severely dealt with.” Moreover, in Alister Anthony Pareira v. State of Maharashtra, the Court held that
[s]entencing is an important task in the matters of crime. One of the prime objectives of the criminal law is imposition of [an] appropriate, adequate, just and proportionate sentence commensurate with the nature and gravity of [the] crime and the manner in which the crime is done. There is no straitjacket formula for sentencing an accused on proof of crime. The courts have evolved certain principles: [the] twin objective of the sentencing policy is deterrence and correction. What sentence would meet the ends of justice depends on the facts and circumstances of each case and the court must keep in mind the gravity of the crime, motive for the crime, nature of the offence and all other attendant circumstances. |*|
Sentencing for Theft and Manslaughter in India
The punishment for theft is up to three years’ imprisonment, a fine, or both. No judicial guidance was found regarding sentencing for theft. [Source: Library of Congress Law Library Legal Reports, 2014 |*|]
In regard to manslaughter: Causing death by negligence is punishable by imprisonment of up to two years, a fine, or both. Other crimes similar to manslaughter include punishment for culpable homicide not amounting to murder, addressed in section 304 of the Penal Code: Whoever commits culpable homicide not amounting to murder shall be punished with [imprisonment for life], or imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine, if the act by which the death is caused is done with the intention of causing death, or of causing such bodily injury as is likely to cause death, or with imprisonment of either description for a term which may extend to ten years, or with [a] fine, or with both, if the act is done with the knowledge that it is likely to cause death, but without any intention to cause death, or to cause such bodily injury as is likely to cause death. |*|
The Supreme Court looked at the question of sentencing involving sections 304 and 304A in a drunken driving case and found that punishment must be commensurate with the crime and that deterrence was a primary consideration when deciding on the severity of the sentence where rash or negligent driving was involved. |*|
Sentencing for Murder in India
The punishment for murder under India’s Penal Code is life imprisonment or death and the person is also liable to a fine. Guidance on the application of the death sentence was provided by the Supreme Court of India in Jagmohan Singh v. State of Uttar Pradesh, where the Court enunciated an approach of balancing mitigating and aggravating factors of the crime when deciding on the imposition of capital punishment. However, this approach was called into question first in Bachan Singh v. State of Punjab where the Court emphasized that since an amendment was made to India’s Code of Criminal Procedure, the rule has changed so that “the offence of murder shall be punished with the sentence of life imprisonment. The court can depart from that rule and impose the sentence of death only if there are special reasons for doing so.” [Source: Library of Congress Law Library Legal Reports, 2014 |*|]
The Court also emphasized that due consideration should not only be given to the circumstances of the crime but to the criminal also. However, more recently the Court in Sangeet & Anr. v. State of Haryana, noted that the approach in Bachan has not been fully adopted subsequently, that “primacy still seems to be given to the nature of the crime, ” and that the “circumstances of the criminal, referred to in Bachan Singh appear to have taken a bit of a back seat in the sentencing process.”The Court in Sangeet concluded as follows:
This Court has not endorsed the approach of aggravating and mitigating circumstances in [the 1971 case of] Bachan Singh. However, this approach has been adopted in several decisions. This needs a fresh look. In any event, there is little or no uniformity in the application of this approach. Aggravating circumstances relate to the crime while mitigating circumstances relate to the criminal. A balance sheet cannot be drawn up for comparing the two. The considerations for both are distinct and unrelated. The use of the mantra of aggravating and mitigating circumstances needs a review. |*|
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Text Sources: Library of Congress, Ministry of Tourism, Government of India, Encyclopedia.com, New York Times, Washington Post, Los Angeles Times, Times of London, Lonely Planet Guides, Compton’s Encyclopedia, The Guardian, National Geographic, Smithsonian magazine, The New Yorker, Time, Reuters, Associated Press, AFP, Wall Street Journal, Wikipedia, BBC, CNN, and various books, websites and other publications.
Last updated December 2023