On September 4, 2018, the Supreme Court of India is scheduled to hear an unprecedented petition by 356 officers of the Indian Army seeking total immunity from any legal action and freedom to shoot and kill at will civilians in ‘disturbed areas’ by just branding them insurgents, terrorists or anti-national elements. They say that Armed Forces (Special Powers) Act (AFSPA), empowers them to do so and that courts of law should not meddle in this. Therefore, they are asking the Supreme Court to strike down all First Information Reports (FIRs) and court-monitored investigations into fake encounters carried out under the protective umbrella of AFSPA.
This ‘show of strength’ has been triggered by two cases which have brought the army to the brink of prosecution. The first one is the nearly-decade long Manipur Murder case and the second is a new one on the deaths of three civilians in Shopian, Jammu and Kashmir, in January 2018. The State government had filed a FIR against Major Aditya Kumar of the 10 Garhwal Rifles in this case. His father Lt. Col. Karamveer Singh has approached the court seeking to quash the FIR. In March 2018, Supreme Court stayed the investigation into this case.
The Manipur case has been referred to repeatedly in the petition, with the petitioners asserting that the historic orders passed by the Supreme Court in 2016 and 2017 to investigate the cases of alleged fake encounters are against the Indian constitution. The petition is also an ex-parte application for stay, which means the victims who are seeking justice for their allegations of fake encounters may not be heard in court.
The army officers feel that the FIRs which are being filed against them by the Central Bureau of Investigation (CBI) and State governments are “motivated and indiscriminate”. They call the victims “anti-nationals”. In the petition, they ask the court to initiate an investigation into the victims and petitioners themselves. They even ask for armed forces personnel who are the accused in this case to be given “adequate compensation” by the court.
Army officers claim that the CBI cannot investigate them and say that even FIRs cannot be filed against them.
Their petition says that army officers need to be safeguarded from “persecution and prosecution”. They have asked the court to ensure that no legal proceeding should be instituted against them without the sanction of the Central government. Army officers claim that the CBI cannot investigate them. They go a step further and say that even FIRs cannot be filed against them. The filing of the plea by serving Army officers assumed significance as the CBI’s SIT has recently filed charge sheets in two separate encounter cases in Manipur in which murder charges have been slapped. The Supreme Court is scheduled to hear this petition on September 4, 2018.
Manipur Murder and dacoity—a reality check.
This challenge has been brewing since the Supreme Court directive of July 8, 2016 on 1,528 alleged cases of ‘extra judicial killings’ by Security Forces in Manipur in the last about a decade under the powers vested on them by AFSPA. The Court agreed to order an independent inquiry into the entire gamut of extra-judicial killings by the Army, Assam Rifles and Police in the insurgency-hit areas in the North-East. Accordingly, in July 2017 the Court directed CBI investigation into the matter and asked its Director to appoint a Special Investigating Team (SIT) to probe into the ‘fake-encounters’. This was a severe setback for a section of Army personnel who indulge in such acts and also for those who support it by concealing the truth
One such ‘killing’ in 2010 made big news. It was the alleged murder of three Manipuri boys by army personnel belonging to the Dimapur based 3 Corps Intelligence and Surveillance Unit (CISU) commanded by Colonel Govindan Shreekumar. It was stated that à la Agent 007 James Bond this Colonel thought he had the ‘ license to kill’ anyone under AFSPA.
The narrative in this case suggests that on March 10, 2010, Diphupar police station of Dimapur was informed about the abduction of Phijam Naobi, R.K. Roshan and Thounaojam Prem and police launched an extensive search. On March 17, 2010, Assam Police found three bullet riddled bodies in the Bokajan police station area of Karbi Anglong district and informed the Nagaland Police about it. On physical verification, these bodies turned out to be those abducted on March 10.
Unlike allegations of fake encounters raised by human rights groups, this case was reported by an officer.
On March 13, 2010 Col. Shreekumar’s own Second-in-Command, Major Ravi Kiran, wrote to the Brigadier General Staff serving under Lt. Gen. Dalbir Singh Suhag, GOC 3 Corps bringing this gruesome crime to his notice. Despite the FIR and the evidence on record no action was taken. Major Ravi Kiran again wrote to 3 Corps giving lucid details of the cold-blooded triple-murder that took place in the unit's Officers' Mess. Unlike allegations of fake encounters raised by human rights groups, this case was reported by an officer of the very unit responsible for this gruesome murder. Yet, the Corps Commander ignored it and disposed it off with a one-man inquiry!
So, the crimes continued with dacoity committed by the same CISU in December 2011. An armed party of 15 soldiers dressed in battle fatigues under the command of Captain Rubina Kaur Keer had raided the house of one Poona Gogoi, an army contractor in Jorhat, who was away in Guwahati. All members of the family—his wife (Renu Gogoi) and three children—were manhandled and tied up. Raiding soldiers seized the keys of the locked cupboards and took into possession a licensed pistol with 13 cartridges, jewellery worth Rs. 6.5 lakhs and cash adding up to Rs. 1.5 lakhs. They also took away items like laptop and four mobile phones. On Poona Gogoi registering a FIR with the police station listing all the items that had been stolen, 3 Corps handed back the stolen pistol, most items and the cash except the jewellery and cartridges. After that Suhag told the police that the matter would be dealt with by Army authorities and that was the end of it!
What was worse, Col. Sreekumar recommended Capt. Rubina Kaur for the gallantry award.
“Captain Rubina Kaur Keer through her perseverance, initiative, unrelenting efforts and in total disregard to personal safety, penetrated into the terrorist network in a highly insurgent-infested area thereby establishing a dynamic Intelligence network to track and monitor insurgent movement and activities,” reads the citation for Sena Medal.
The Court of Inquiry (CoI) ordered by the then Eastern Army Commander, Lt. Gen. Bikram Singh into the dacoity episode had all the indications of an eyewash and deliberately meant to protect Suhag as would be evident from the fact that it was headed only by a Brigadier rank officer. The CoI was obviously orchestrated and despite clinching FIR and evidence the accused got away on some technical grounds. For this botch-up, Lt. Gen. Suhag was issued with a Show Cause Notice (SCN) and a Discipline and Vigilance (DV) Ban on May 19, 2012, by the then Army Chief, General V.K. Singh which would have automatically disqualified Suhag for any promotion.
But the Machiavellian Ministry of Defence appointed Lt. Gen. Suhag in the acting rank of Army Commander with effect from June 01, 2012, even before he replied to the SCN and its detailed processing on merit. What is worse, as soon as General Bikram Singh took over as Army Chief he got the DV Ban on Suhag lifted only to make him a regular Army Commander. The CoI into this ‘dacoity’ on its part led to Court Martial resulting in the dismissal of Havildar Sandeep Thapa. Col. Shreekumar was given a ‘severe displeasure’ while Capt. Rubina was given a ‘reprimand’ along with Havildar Bhupen Hatimuta and Havildar Jeevan Neog who got ‘severe reprimands’. This order, issued much after Gen. V.K. Singh demitted office, fully justified the DV Ban imposed on Suhag.
Yet, General Suhag went on to become the Army Chief. But it was a different story for Brigadier L.I. Singh, Yudh Seva Medal recipient who in his capacity as Deputy Director General Discipline and Vigilance Directorate in the Army Headquarters had coordinated the disciplinary action for dereliction of duty against senior officers of 3 Corps including Gen Suhag. As soon as Gen Bikram Singh took over as Army Chief in 2012 this Brigadier was booted out and ‘dumped’ as they say in Army parlance. He is still in limbo!
Killings continue to haunt
Even after several years the Manipur killing refuses to die down within the Army as could be seen from the action of Lt. Col. Dharamvir Singh who had worked with the same CISU from 3 Corps. He created a stir in September last year when he wrote to his superiors alleging that CISU had been systematically executing Manipuri militants in “fake encounters” since 2010. Though nothing had come off it back then, on the morning of 1 July, 2018, he was taken into custody by his own unit from his official quarters in Imphal. He was accused of insubordination, not joining his new post on time, and bringing his family into a field posting.
On 11 July, Singh reappeared and stepped up his actions against his unit, this time filing an affidavit in the Manipur High Court, repeating the accusations of “fake encounters” that he had listed in his September letter. After he went missing again, his wife filed a habeas corpus petition in the same High Court on 20 July. A week later, the Lt. Col was produced in court. The Army has so far remained tight-lipped on the entire controversy. But the High Court has directed it to file its official reply. There is also no clarity on Singh’s current whereabouts. His affidavit, however, has rattled the force. In it, he has detailed how three suspected militants were allegedly killed and at least two others taken hostage and allegedly murdered by his unit, the 3 CISU.
The 3 Corps Command which is the epicenter of these allegations covers three international boundaries.
The 3 Corps Command which is the epicenter of these allegations of murder and dacoity is the biggest terrain for an Indian Army formation—covering three international boundaries besides counter-insurgency work. These borders have a bad reputation of being porous to drug smuggling.
Ironically, there is a mysterious link between 3 Corps, Eastern Army Command and Army Headquarters. The present Army Chief General Bipin Rawat had commanded 3 Corps! His predecessor General Dalbir Singh Suhag (Retd) had commanded 3 Corps, Eastern Army and was Army Chief. His predecessor General Bikram Singh (Retd) had also commanded the Eastern Army. The present Eastern Army Commander Lt. General Abhay Krishna was Brigadier General Staff (Operations), HQ 3 Corps and had dealt with these serious allegations!
These connections appear bizarre in the context of the Army sabotaging and stonewalling all kind of enquiries and investigations in to the matter whether by the military, police or CBI. Strangely enough Phijam Manikumar Singh, brother of Phijam Naobi, one of those killed in the Manipur Murder has filed an affidavit in the Manipur High Court accusing the two Generals (Suhag and Krishna) of these very charges. The unprecedented ‘show of strength’ by 356 Army offices directly challenging the Supreme Court itself may be part of this perfidy!
It is clear that for several years Army top brass has been protecting ‘killer/smuggler squads’ by giving them immunity from even disciplinary action, let alone criminal trial. Like in ‘banana republics’ they have been thriving. The only exception was General V.K .Singh who had to pay a heavy price for ‘floating against the wind’.
The Supreme Court insists that every death caused by the armed forces in a disturbed area should be thoroughly enquired into.
The Supreme Court had ruled that large-scale killings in Manipur in the guise of self-defence, while dealing with insurgency or militants, are unacceptable. As per the court if members of the armed forces are deployed and employed to kill citizens of the country on the mere allegation or suspicion that they are the ‘enemy’, not only the rule of law but also democracy would be in grave danger. The Supreme Court insists that every death caused by the armed forces in a disturbed area should be thoroughly enquired into. This is to address any allegation of use of excessive or retaliatory force beyond the call of duty and even planting weapons on the victims to justify such excess.
What Supreme Court said is significant:
“It does not matter whether the victim was a common person or a militant or a terrorist, nor does it matter whether the aggressor was a common person or the state. The law is the same for both and is equally applicable to both...This is the requirement of a democracy and the requirement of preservation of the rule of law and the preservation of individual liberties.”
Delving into AFSPA
Put in simple terms, the AFSPA gives armed forces the power to maintain public order in “disturbed areas”. They have the authority to prohibit a gathering of five or more persons in an area, can use force or even open fire after giving due warning if they feel a person is in contravention of the law. If reasonable suspicion exists, the army can also arrest a person without a warrant; enter or search premises without a warrant; and ban the possession of firearms. Any person arrested or taken into custody may be handed over to the officer in charge of the nearest police station along with a report detailing the circumstances that led to the arrest.
A disturbed area is one which is declared by notification under Section 3 of the AFSPA. An area can be disturbed due to differences or disputes between members of different religious, racial, language or regional groups or castes or communities. The Union Government, or State Government or administrator of the Union Territory can declare the whole or part of the State or Union Territory as a disturbed area. A suitable notification would have to be made in the Official Gazette. As per Section 3, it can be invoked in places where “the use of armed forces in aid of the civil power is necessary”.
The Armed Forces (Special Powers) Bill was passed by both the Houses of Parliament and it was approved by the President on September 11, 1958, and came to be known as the Armed Forces Special Powers Act, 1958. In a few days the Act will be celebrating sashtipoorthi . [Its 60 birth anniversary.]
It is effective in the whole of Nagaland, Assam, Manipur (excluding seven Assembly Constituencies of Imphal) and parts of Arunachal Pradesh. The Centre revoked it in Meghalaya on April 1, 2018. Earlier, the AFSPA was effective in a 20 km area along the Assam-Meghalaya border. In Arunachal Pradesh, the impact of AFSPA was reduced to 8 police stations instead of 16 in Tirap, Longding and Changlang districts bordering Assam. Tripura withdrew the AFSPA in 2015. It was promulgated in Punjab in 1983 and withdrawn in 1997. Jammu and Kashmir also have a similar Act since 1990.
Under AFSPA the Army is vested with draconian powers that has many chances of being misused when it comes to civil population. In a July 2016 verdict, the Supreme Court ripped open the cloak of immunity and secrecy provided by AFSPA to security forces for deaths caused during encounters in disturbed areas. Earlier, Commissions headed by former Supreme Court judges have found serious human rights violations by the security forces and have recommended scrapping of AFSPA or making drastic changes in the Act. But successive governments and army top brass have been defending AFPSA with all their might.
The Act, for whatever reason, has become a symbol of oppression, an object of hate, and an instrument of discrimination.
To be more specific in 2005 a high-level official Committee headed by Justice B.P. Jeevan Reddy of the Supreme Court tasked with reviewing the AFSPA unambiguously recommended its repeal. This is what the Committee said in its 147-page Report: "The Act is too sketchy, too bald and quite inadequate in several particulars… the Act, for whatever reason, has become a symbol of oppression, an object of hate, and an instrument of discrimination and high-handedness."
Acknowledging that the Supreme Court had upheld the constitutional validity of the Act, the Committee said that the judgment "is not an endorsement of the desirability or advisability of the Act." The Supreme Court may have endorsed the competence of the legislature to enact the law. But "the Court does not and is not supposed to pronounce upon the wisdom or the necessity of such an enactment." On this point, the Committee had recorded that it is highly desirable and advisable to repeal the Act altogether in accordance with the “overwhelming desire of an overwhelming majority of the [North-East] region.”
Besides Justice Reddy other members of the Committee included a former Director General of Military Operations Lt. Gen. V.R. Raghavan, a former special secretary in the Union Home Ministry P.P. Shrivastava, a former Vice-Chancellor of the Marathwada University Dr. S.B. Nakade, and senior journalist, Sanjoy Hazarika.
Rejecting the principal submission made by the armed forces in favour of continuation of the AFSPA, the Committee pointed out that protection from legal proceedings against soldiers acting in good faith already exists in Section 49 of the Unlawful Activities (Prevention) Act, 1967 (ULP Act).
It also noted that "while providing protection against civil or criminal proceedings in respect of the acts and deeds done by [the armed] forces while carrying out the duties entrusted to them, it is equally necessary to ensure that where they knowingly abuse or misuse their powers, they must be held accountable therefore and must be dealt with according to the law applicable to them."
Accordingly, the Committee recommended amending the ULP Act to incorporate measures that would regulate the already permissible conduct of armed forces personnel in areas where they are deployed to fight terrorist activities and provide protection to ordinary citizens against possible abuse.
AFSPA and the Army Doctrine
Stating that "The Indian Army is the land component of the Indian Armed Forces which exists to uphold the ideals of the Constitution of India,” Army Doctrine-2004 clearly lays down its roles:
• Primary: Preserve national interests and safeguard sovereignty, territorial integrity and unity of India against any external threats by deterrence or by waging war.
• Secondary: Assist Government agencies to cope with ‘proxy war’ and other internal threats and provide aid to civil authority when requisitioned for the purpose.
The Doctrine is clear. The secondary role of coping with ‘proxy war’ and other internal threats and providing ‘aid to civil authority’ comes only when requisitioned by that authority and not otherwise. This role comes in different forms—short intervention during severe riots and breakdown of law and order and medium-term role in counter-insurgency operations against terrorists or secessionist. By its very definition it cannot be long term or permanent. But this is what it has become in Jammu & Kashmir and the northeast, given the pathetic state of civil governance, corruption and inefficiency of police forces.
The AFSPA is one of the more draconian legislations that the Indian Parliament has passed in its seven decades of Parliamentary history. Under this Act, all security forces are given unrestricted and unaccounted power to carry out their operations, once an area is declared disturbed. Even a non-commissioned officer is granted the right to shoot to kill based on mere suspicion! All this in the name of ‘aiding civil authority’ to maintain law and order!
The AFSPA was first applied to the the northeastern States of Assam and Manipur and was amended in 1972 to extend to the other States of Nagaland, Tripura, Meghalaya, Arunachal Pradesh and Mizoram. The enforcement of the AFSPA has resulted in innumerable incidents of arbitrary detention, torture, rape, and looting by security personnel. This legislation was justified by the Government of India, on the plea that it was required to stop the norhteastern States from seceding from the Indian Union.
During my brief stint in the Indian Army (Infantry) in the 1960s I had two opportunities to involve in operations to provide ‘aid to civil authority’—one in Tamil Nadu to quell the violent anti-Hindi imposition agitation and the other in Nagaland against insurgency. While the former was short and quick—just about a week, the latter went on dragging for years though I was part of it only for about a year before leaving the Army to join the Indian Administrative Service (IAS). During the counter-insurgency operations we came face to face with heavily armed ‘underground hostiles’ moving to and from China and lost several men. We had no protection of AFSPA and our orders were to capture hostiles and weapons and not to kill. And we did conduct several operations successfully doing exactly this and did not feel any necessity for the draconian AFSPA.
The Act was extended to J&K in 1990 and has now become a subject of intense controversy. Uncharacteristically, the Army brass has gone overboard desperately clinging on to this law as if it is a matter of survival. Lt. Gen. Syed Ata Hasnain, who commanded the Srinagar-based XV Corps, had gone to the extreme of suggesting that the country could be compelled to grant the State independence by 2016 if government lifts AFSPA from some areas. He also reported to have asserted that ‘while the State people were seeking bijli, sadak, paani (electricity, roads, water), calls for lifting the AFSPA were coming from four categories: Pakistan, the Inter-Services Intelligence Directorate, terrorists and secessionists.’ How naïve could a military commander be?
It is ironic that while Chief Ministers favour the withdrawal of AFSPA, the Army has been steadfast in rejecting this.
It is three decades since the bombing that signalled the beginning of the murderous insurgency in J&K and 28 years since AFSPA was clamped down in the State. Does the refusal to withdraw AFSPA mean that in these long years India's strategic establishment as well as the Army has failed to contain insurgency and restore peace? It is ironic that while Chief Ministers, the civilian head of the State government, have acknowledged the return of peace and raised their voice in favour of the withdrawal of AFSPA from parts of the State, the Army has been steadfast in rejecting this. It looks as if under the cover of AFSPA Army Doctrine-2004 is being turned on its head- ‘aid to civil authority’ assuming primary role pushing external threats to secondary position!
Army and Democracy
Over the years, the effort of ruling politicians has been to make Army as instrument of an increasingly autocratic state and the Army brass and hawk’s mind-set seem to suit this agenda. So, the big question arises: What is the role of India’s professional Army that had remained resolutely non-political since Independence-to defend democracy or oppress the people at the whim of an autocratic state?
This poser came up in a big way when Prime Minister Indira Gandhi imposed Emergency in June 1975 turning a vibrant democracy into enslaved autocracy. Response to the poser came from the international media in a lengthy article titled “Ruler of 600 million and alone–Indira Gandhi is unmaking a democracy ‘to save it” in the TIME magazine of August 11, 1975 written by Claire Sterling, regular columnist for Atlantic Monthly , Washington Post , and International Herald Tribune after extensively visiting India.
After analysing the situation on the ground and presenting the alternatives before Mrs. Gandhi-becoming a real dictator or sending the country into the Soviet orbit, Claire opines that neither development is likely to leave the Indian Army unmoved:
“India’s standing Army of nearly a million men has been resolutely non-political since Independence. But it is also sensitive to the smallest slight to its honour, dignity and military independence, not to mention the nation’s sovereignty; and it is steeped in loyalty to constitutional principles. It was altogether her Army when she enjoyed unquestioned legitimacy of constitutional rule. It may not be should its ranking officers conclude that she has become something else. More than ever now her fate hangs on the Army’s loyalty.”
Claire concludes the article with touching poignancy:
“One thing worse than governing India by democratic persuasion would be trying to govern it by force. Yet that is how Indira is trying to do it now. Depending on how fast and how far she goes in changing from a traditional Prime Minister to the one-woman ruler of a police state, the Indian Army–the one group with the power to stop the process–could intervene. If it were to do so, it would almost certainly be not to replace her with a military dictator, but to restore the institutions of democracy it has been drilled into defending since birth.”
The Army did not intervene but remained a bulwark of India’s democracy and its institutions. I was a witness.
The Indian Army lived up to this faith during Emergency. The Army did not intervene but remained a bulwark of India’s democracy and its institutions. I was a witness. They had heeded the call of Jayaprakash Narayan (JP), the mass leader of the people: “You have not sold your conscience and honour for the sake of your bread.” Fortuitously, Emergency ended within a short period and democracy was restored with Indira Gandhi’s defeat in the 1977 elections. Should our Army be any different now?
The genie needs to be bottled
As a law facilitating one-time/short engagement of Army in Internal Security (IS) duties to quell insurgency, AFSPA cannot be faulted. But the problem is the prolonged and endless deployment of Army in IS duties of all kinds, which is the job of the police and at best para-military forces. As per Army Doctrine-2004, the Indian Army's primary role is to preserve national interests and safeguard the sovereignty, territorial integrity and unity of India against any external threats by deterrence or by waging war. To perform this role, Army keeps aloof from the civilian crowd, concentrating on their training and battle readiness.
Familiarity breeds contempt. This is precisely what is happening in Kashmir and several places in the northeast.
Relegating the Army to its secondary/tertiary role by decades-long deployment on counter-insurgency and IS duties dilutes its authority, corrupts ranks and compromises efficiency through lack of training. Besides, over time Army is looked upon merely as another state force with its soldiers losing the respect and mystique they traditionally enjoyed. Familiarity breeds contempt and military men find themselves at the receiving end.
This is precisely what is happening in Kashmir and several places in the northeast. Since the civilian population is directly involved, politics and politicians come in, power-games begin, and wittingly or unwittingly Army becomes a pawn. The narrow aim of power-mongers has always been to create a situation of intense hostility inextricably miring the military into it forcing it to resort to excessive force. The words ‘national security’ comes easy on their lips!
As we have seen Army has primary—defending India by war or deterrence, and secondary/tertiary-counter insurgency and aid to civil power—roles to play. In their primary role where enemies are involved armed forces personnel certainly enjoy immunity without question. They don’t even need AFSPA for this. But giving them such immunity in their secondary/tertiary role where Indian citizens are involved, will amount to turning the Constitution on its head, abandoning democracy and rejecting the Rule of Law.
Voltaire had famously said: “It is forbidden to kill; therefore, all murderers are punished unless they kill in large numbers and to the sound of trumpets.” For the Indian Army, this could be true in times of war against enemies. But they cannot do this during peace against own citizens.
If left unchecked AFSPA can endanger India’s constitutional mandates of freedom, liberty and rule of law.
As rightly observed by the Supreme Court, if left unchecked and unfettered AFSPA can pose clear and present danger to India’s constitutional mandates of freedom, liberty and rule of law. Even worse, giving AFSPA a free run as demanded by a set of army officers who have petitioned the Supreme Court and some other hawks would be suicidal for the democratic republic of India. This cannot be countenanced. The genie of AFSPA must be put back into the bottle either by Parliament by repealing the law as recommended by Justice Jeevan Reddy Committee or by the Supreme Court by pronouncing it unconstitutional.
[ M.G. Devasahayam is a former Army and IAS officer. He had fought in the 1965 war and participated in counter-insurgency (Nagaland) and aid to civil power (Tamil Nadu) operations]
Sources: [All URLs are accessed on August 27, 2018]
Document:
Writ Petition (Crl) No. 18 of 2014 in the High Court of Asom at Gauhati by Phijam Manikumar Singh.
URL:
1. Devasahayam, M.G. 2014 . " The Haze Of Allegations ", Outlook, July 3. [https://www.outlookindia.com/website/story/the-haze-of-allegations/291305].
2. Devasahayam, M.G. 2014. " Indian Army - Politicised or Criminalised? ", Bharatkalyan97 , April 28. [http://bharatkalyan97.blogspot.com/2014/04/indian-army-politicised-or-criminalised.html].
3. Devasahayam, M.G. 2014. " Putting criminals in command? ", Bharatkalyan97 , April 20. [http://bharatkalyan97.blogspot.com/2014/04/putting-criminals-in-command.html].
4. Datta, S. 2016 . " Why one of the messiest chapters in Indian army history refuses to be closed ", Scroll.in , August 19. [https://scroll.in/article/814386/why-one-of-the-messiest-chapters-in-indian-army-history-refuses-to-be-closed].
5. The Tribune . 2016 . " Abandoning the ‘Army Doctrine’ in Kashmir? ", September 22. [https://www.tribuneindia.com/news/comment/abandoning-the-army-doctrine-in-kashmir/298777.html].
6. The Tribune . 2017 . " An Army for the people? ", April 26. [https://www.tribuneindia.com/news/comment/an-army-for-the-people/397454.html].
7. Chaoba, P. 2018 . " Custodial Killings by Army Alleged in Affidavit by Senior Officer ", The Wire , July 29. [https://thewire.in/rights/army-lt-col-dharamvir-exposes-armys-custodial-murders-in-affidavit/amp/].
8. Chaoba, P. 2018 . " Army’s systematic custodial murders exposed : Army abducted Lt. Col. Dharamvir reveals all in affidavit to HC ", Imphal Free Press , July 28. [https://www.ifp.co.in/page/items/50948/armys-systematic-custodial-murders-exposed-army-abducted-lt-col-dharamvir-reveals-all-in-affidavit-to-hc/#.W12EDV6tzKI.whatsapp].
9. Dutta, S. 2018 . " Indian Army officer fights a lonely battle with his comrades over ‘fake encounters’ ", The Print , August 14. [https://theprint.in/security/soldier-who-went-on-to-become-indian-army-officer-is-now-up-against-his-own-elite-unit/96688/amp/?__twitter_impression=true].
10. Krishnan, M. 2018 . "Plea by 355 Army personnel: A tacit intra-court appeal against the Manipur Encounters Case judgment?", Bar & Bench , August 18. [https://barandbench.com/plea-355-army-personnel-tacit-intra-court-appeal-manipur-encounters-cases-judgment/?_branch_match_id=523041415839417221].
11. Varadarajan, S. 2006 . " Repeal Armed Forces Act: official panel ", The Hindu, October 8 . [https://www.thehindu.com/todays-paper/repeal-armed-forces-act-official-panel/article18485943.ece].