Writ[e] & Talk | Ep 9 | Socio-spatial Consequences of Disturbed Areas Act 1991 on Urbanizing Spaces in Gujarat

Transcript 

Ms. Sinchan Chatterjee

At our podcast here, we tend to look for articles that help in our holistic understanding of the legal fallacies in our society and how through academic discourse we can further discussion on the same. Due to this, This piece of yours becomes a very crucial read, not just through time, but specifically this year. At a time when religious conflicts have become painfully rampant, it is our imperative to look into the varied intricacies that supplant and further such discrimination. Housing and residence thus become a very foundational form of such biases. And your paper provides a very pertinent intersection to sociological understandings. of not just legal but also individual and communal failure.With that, I would like to start the discussion on the same. Should I go ahead with the first question?

Mr. Devansh Srivastava

Yes, please.

Ms. Sinchan Chatterjee

Okay, so in discussing the methodology of your research, you suggest the adoption of a socio-legal approach for the understanding of property, which also serves as a critique of positive law. Can you elaborate on how this approach offers a more nuanced understanding of policy implications?

Mr. Devansh Srivastava

First of all, thank you so much for inviting me to the podcastand let me begin by quoting a philosopher of science, Sir Karl Popper and like let's assume we are not students of a particular discipline for a while. So he says that we are not students of some subject matter, but students of problems and problems may cut across the borders of. any subject or discipline. He says this in his book on conjectures and reputations. So that is when interdisciplinary and interdisciplinary approaches become very important and there is a limitation to which one can approach a problem through the lens of a particular discipline say law or political science or any other discipline

So I have, consistently face this problem of cutting through disciplines because I am not from any particular discipline myself. I have an interdisciplinary background and it is also ironical that even those belonging to say sociology, economics, law, political science, they hesitate to incorporate methods that originate from other disciplines and cut through their own. Now in public policy, paupers ideas. they're very pertinent. So the question before researcher is that of what is the research problem at hand and what does one make of it? What is the position through which one approaches it? And as I said, I'm from an interdisciplinary background which is in peace and conflict studies, planning and development and now it is public policy. And the area of research is urban housing segregation. So I too was faced with this kind of challenge that what kind of methodology should I look at. So coming to your question, I have strived for trying to basically understand how does the legal speak to the social. And In context, it implies the operation of speciality, which is at the interface of law and policy. So if you see the working of law in the paper in terms of disputes that have reached with the Gujarat High Court, it is not merely a question of property or identity that is in dispute. It is also the built environment that plays out in the given scheme of spatial segregation in the state of Gujarat, and the existing literature on socio spatial segregation tells us that only. 

And as the paper also elaborates borrowing from Benjamin Davy, land is a relational space and is a result of social construction and it involves a range of social actors other than the parties involved in dispute with the state. So I feel that the social legal approach in this way can serve as a critique of positive law and can speak to this interface. that is also present in the disputes, but in formal legal approaches, they are not really looked at. So I do believe that it provides a very nuanced understanding of policy implications

Ms. Sinchan Chatterjee

Okay, so just to follow up to that, so would you suggest using this approach for the analysis of all policy decisions with wide social impact as a better alternative and if not, what other methodology would you suggest for this?

Mr. Devansh Srivastava

If I would prioritize social legal method for all policies, I will not actually because it goes back to how I began talking about the research problem and how I have defined it in the paper. Though in the recent decade, if you see there are scholars working on different things, they have begun in cooperation of legal processes, jurisprudence, historical archives, ethnography.

So there is an emphasis on combination of different methods. And again, it is contingent on the context at hand and the problem that one is grappling with.And these scholars come from different backgrounds of say, geography, law, sociology, urban history, etc.And here at National Law School, my fellow scholars are using they have employed qualitative comparative analysis to understand parliamentary deliberation process or critical discourse analysis to understand the construction of backwardness in past-pages reservations. So there is no particular methodology that I privilege over the others, but it is my conviction that discipline should start talking to each other first and it is the job of scholars to initiate so and at the same time the universities should be accommodative to that kind of innovative approaches how they can be operationalized to understand these kinds of problems. 

Ms. Sinchan Chatterjee

Right, I completely agree.So, my next question is, so in the case of Manubhai versus State of Gujarat, the court upheld the collector's decision to transfer property destroyed during communal riots to the government. How do you interpret the legal reasoning behind this decision and what precedents does it set for post-conflict property ownership and government discretion? Moreover, shouldn't there be a mechanism for either the retrieval of the property on behalf of its original owner or a transfer to their heirs? 

Mr. Devansh Srivastava

This is a very complex and complicated conflict that one finds in cities that have witnessed mass violence in any city in India, the question of post conflict property ownership. So in my paper, as it relates to the disturbed areas act, there is a particular provision section 17b where it is mentioned that where the landlord fails to erect a new building within a specified period at the original site irrespective of the weather the premises there on referred to and the other section shall rest in the state government. So the power has been given to the state government and the state government operates has further given this power to the collector. The legal reasoning behind this case. Just to give a brief context to the listeners that this is where in the paper I have discussed that a person who has lost his property, that person is trying to claim back the possession of the property, but because it was not in a particular time frame, the collector has decided to give it to the government and the court also sides with the collector's decision. 

I feel that this legal reasoning is not enough because the question one should be asking is whether it is fair or simply a matter of procedure under the law. See these are I do understand laws operate in a certain context and here we are trying to read them along with the built environment that comes along with that context. So that's why I say the legal reasoning is not enough and uprooted person wants to go back to their original circumstances, which is a very ideal case to begin with and the government's discretion here becomes very problematic. So in this whole metric of communal rioting and destruction of property, the courts need to go beyond a simplistic reasoning that gives primacy to the collective discretion and one has to look into sociological implications that arise in such cases.

How do we determine what constitutes an appropriate decision in an unjust situation of post-conflict property ownership? And with this reasoning, there can be two implications for precedents that form jurisprudence on the conflict. First is that it takes away state accountability in instilling a sense of justice in owners favour as a property, only translate to a particular structure only in which one resides the idea of home if we see it goes much beyond the simplistic materialistic conceptions and second self sorting is such a case I mean it would intensify and further segregate communities so the reason may be that those who have lost possession of their property were not able to claim possession in the stipulated time say because of the fear of claiming the property itself. In other words, I would say I don't really agree with the legal reason.To respond to your question on the mechanism for retrieval of the property and whether it should be given to the heirs. I do believe there should be a mechanism and it should incorporate the properties market value also before destruction and what are the present rates that should be taken into account. However, if the demographic composition of that particular place has changed in the post riot period, then maybe returning and residing is not a feasible option for the owner. And this is from the perspective of safety. What if the property has been reconstructed by someone else who is not actually the owner but has taken the position of the property. So in both cases, even with legal intervention, it may not be a safe option for the owner to return. But in a pragmatic sense, the state should be made accountable to pay the owner equivalent property price that matches say the property values of nearby areas. In case if return is a feasible option, then also the state should be obliged to reconstruct the damaged property. That's how I feel the mechanism should be. 

Ms. Sinchan Chatterjee

Yes. So you're saying that there should be a clear distinction between rehabilitation and retrieval of the property. Yes. Okay. So I also just wanted to ask, since property is no longer a fundamental right and merely a constitutional right, how accountable can we hold a state? Certainly it is a constitutional right. But the negative implications that a fundamental right has on the state, the state has removed itself from the same. So in this regard, how much accountability does the state still, can we still assert in on the state? 

Mr. Devansh Srivastava

I think the state is a mediating partner. I mean, not a partner as such, but entity, I would say and the state should be accountable in the sense that because the law actually mandates it is the composition of a certain place is changed the properties are damaged. So even though right to property is not a fundamental right anymore because this is again a law specified for a very complex situation and dealing with multiple consequences of riots, distress sales, bootlegging activities. consent between parties ghettoization damage of property redevelopment of property. So absolutely the onus lies on the state to facilitate all this transition that has happened and try to the maximum that whether the state that was there before which was the status quo of that time to what extent can one reach to that previous state and. I feel it is the state's responsibility in the first place because citizens are at the receiving end from any community.

Ms. Sinchan Chatterjee

Yeah. So, just like in extension of this, do you think like in light of the other Part 3 provisions of the Constitution, to what extent do you believe that the Act itself can be challenged on constitutional grounds? How far can we tread on the lines of right to equality, non-discrimination, enjoyment of life and dignified life? under Article 21 when viewed in the light of their impact on minorities. 

Mr. Devansh Srivastava

I'm not from a legal background, but I really like the reasoning that the Puttaswamy judgment the right to privacy judgment gives and it is a good vantage point to begin with.The state as a deciding authority between two consenting parties is also a violation of privacy of individuals. 

Moreover, the consent of neighbors if you see many of the case laws the consent of neighbors is also required as a procedural aspect that the inspector is bothered about so in selling of property whether it is so one has to see whether it is also a violation of one's privacy why should the neighbors around my Mauhalla they should be given any right to talk about or to protest sale that I am trying to do, which is my individually owned property and I'm selling it without any distress or under any duress. And if ownership is what determines one's right to possess a property as the legal understanding tells us, then the state should not be a party in determining whether transactions can or cannot take place between consenting individuals.And this is also what The disputes tell us that the court has relied on the original principles of the act. And also from the paper, we see that disputes occur in a built environment as I have been emphasizing and this built environment is plagued by spatial segregation. So privacy infringement and discrimination can be two grounds. I mean to begin with that come to my mind. 

Ms. Sinchan Chatterjee

Okay, all right. So moving on to my next question,what policy changes or interventions could be implemented to mitigate the self-sorting behavior that you were talking about in Ahmedabad's neighborhoods, particularly in context of religious and ethnic segregation? How can urban governance entities promote inclusive community integration and reduce the propensity for demographic clustering along communal lines, keeping in mind that the segregation is self-imposed. 

Mr. Devansh Srivastava

So I want to take a moment to talk about self sorting behavior of communities. First, we need to ask why such a behavior exists and I see through two perspectives. One is through restrictive covenants where cooperative societies have their own bylaws and there is exclusive membership. So religious minorities or now we have or a long time in Indian cities, we have caste based cooperative societies or sect based cooperative societies. So this leads to the conflict between individual liberty of regulating the control over one's property and societal membership. This has come up in the Zoroastrian case, which pertains to the Parsis and, but when we see membership, based on caste and the private bylaws mandating who can enter who cannot then it becomes a particular problem and conceptually this is where Sony Pelissery would argue that you know constitutional equality meets culture of exclusion so methodologically we come back to how the legal speaks to the social and there are many high court judgments on some of which if I remember them correctly sent Anthony's Cooperative Society case. There is a Zoroastrian Radhe Society case, which is different from this one and these cases indicate that the courts have advocated cosmopolitanism, open and secular membership right to housing. But when we have the contrasting Zoroastrian judgment of 2005, the Supreme Court judgment, It relies on the area of operation theory which actually goes against the ideas of open and secular membership. So this becomes slightly problematic when we think of a restrictive covenants and the disputes that arise from it. So this is one perspective. And the other one is that of a communally sensitive city. So if we think globally, we think of Belfast where ethnic divide runs deep between the Protestants and Catholics in Iraq. If we see in the post-war period, the mutual distrust between Sunnis and Shias we see in Beirut, Christians and Muslims in Sri Lanka, it is Tamils and Sinhalese in India, it is mostly between Hindus and Muslims. So is it a good policy idea to think of regulating spatial segregation in the given system. They whitewhat I mean to say is do populations want to live together in the present built environment and should policy makers push them to live together in the present environment though it would be a very ideal social mixing is a very integrating social cohesion is a very it's a good boost to the democratic ideas that we cherish in the constitution.Now, at the same time, I want to emphasize that the responsibility of the state in instilling a sense of trust between communities and make policies as policies that foster this interaction between communities is very important.So ghetto areas reduce this kind of a possibility. And also, if you see the paper, it also points to a similar direction. This policy at hand disturbed areas act is enacted to prevent out migration of minorities from their respective areas. But the question is, has it really happened? I am personally, I am an advocate of desegregation and policies should absolutely aim to encourage social mixing through legislations. The implementation should be better. Maybe one way to encourage this is through coming up with incentives in residential housing that instills a sense of security in people because that is also a primary factor because of which people reside to their own homogeneous coreligionist or co-cast identities, co-ethnic identities. So coming up with a social mixing policy, it's a very slow and incremental measure, but perhaps this is the best that we have as of now. 

Now, demographic clustering and self sorting is not just a single sided phenomena. It also has to do with the urban form that has evolved because of consistent riots in a particular city and the causes are grossly political and during the state and national elections we see the ethnic divisions that really run deep. However, the idea that only homogeneous living brings security in residential living that has to be opposed tooth and nail that I am very sure about. It has to be done at the level of policy and through social engagements. So, but most importantly, it can only flourish with the assurance of a political will because without that it becomes very difficult to convince populations to kind of live together. That's my take.

Ms. Sinchan Chatterjee

Right. I do agree with this and this does,  make me think of drawing a parallel between solutions that are often posited in the Palestine-Israel conflict as well. When we talk about the one state or the two state solution, what exactly is the answer? And while a one state solution there is what is the ideal, as what you were saying, the social mixing and ensuring that the minority communities and those being subjected to marginalization are first protected. That should be the key first. And it needs to be politically motivated. And there needs to be some imperative on part of the government to ensure the same. So this, the process of social mixing is a very slow process and it would need a lot of uprooting and change in our cultural mindsets, So what is the solution till then? Is a homogeneous living the ideal for the safeguard and safekeeping of marginalized communities? Or is there an alternative to this?

Mr. Devansh Srivastava

I don't see an alternative because if we had there would be no ghettos today. And so homogeneous living is indeed the ideal. But the point is how do we instill a sense of confidence in the citizens. So even if we take the context out of spatially segregated cities in cities where the degree of conflict is much less, say cities like say Chennai or other city that I can think of is maybe Chandigarh. I mean, these are very ideal cases to begin with. But my question is even there are degrees of exclusion and latent forms of discrimination operating here. So the ideal is to come up with anti-discrimination legislations and at the same time instilling a sense of confidence that indeed comes from the state. I mean, these are very ideal cases to begin with. But my question is even there are degrees of exclusion and latent forms of discrimination operating here. So the idea is to come up with anti-discrimination legislations and at the same time instilling a sense of confidence that indeed comes from the state. At best, what we have as of now is indeed the idea of homogeneous living, but incremental changes have to happen. It is not a one night solution that can. 

Ms. Sinchan Chatterjee

So your paper points out the mismatch between the city's master plan and the reality of informal settlements. How can legal frameworks and urban planning be improved to better address the needs of low-income residents and potentially create more inclusive neighbourhoods, specifically in Ahmedabad?

Mr. Devansh Srivastava

I feel actually when we read works of urban scholars like Amitabh Bhaviskar, Ananya Roy and among many others, they point out that there is a mismatch between the urban planning itself and it actually widgets informality as a consequence. So the first response that comes to mind is where is the scope for populations to expand? in the age of real estate speculation and also the disturbed areas act limits the expansion of populations. So these are two restrictive kind of limitations that are there. But I think when we're talking about low income neighborhoods, the key is to think of inclusivity and that can may be come from two primary vantage points.

One is the formalization of informal settlements where we think of establishing legal mechanisms to recognize and formalize informal settlements within the city's planning framework because the planning framework does not really account take into account the informality of spaces. And second is through coming up with public housing schemes, especially in the X-Mill neighbourhoods that have been planned and if you see in world areas where the textile mills existed, there is a lot of vacant land. Now there are different kind of legalities attached to it, How the rights have been transferred to the workers and the negotiations that have happened. But I'm just saying in an abstract way, it may be coming up with a multi-story. apartments that would be one form of housing public housing that can be provided and that is also where the idea of social mixing can be tried out at least. 

Ms. Sinchan Chatterjee

So, I will move on to the next question. How far do you think we are correct in our approach to categorizing ghettoization as a self-sorting behavior by the masses? Do you believe there is an approach that has been adopted by similar instances outside of the Indian demographic that might be suitable to tackle this problem here considering how we call it self-segregation, even though it is also being furthered as a result of the existing legal framework itself. 

Mr. Devansh Srivastava

If we are calling ghettoization solely as a self-sorting behavior by the masses, then we are succumbing to a reductive definition of a ghetto in which ghetto appears as an apolitical consequence on some random episodes of riots in the past. What I mean to say is that we take away the responsibility and role of the state in facilitating the making of a ghetto. So self sorting behavior can be a community response contributing to exclusion of disadvantaged groups. As I have mentioned in the paper where the intent of the act itself is compromised because of ground level politics and there is abundant literature on ghettos in the global south as well as in the north. So the paper also builds upon Radhika Gupta's emphasis on ghetto as a cognitive effect and the effect also operates in peri-albanizing areas with a similar kind of a dynamic. To respond to the other question that you posed, I actually like to fall back on the idea of fair housing in the US that was passed I think in 1968 and there are scholarly studies telling us that the impact of the fair housing has been quite disparate and that race based discrimination is still systemic but at least there is a robust piece of legislation that the US has. In India, there is no anti-discrimination law as such. Not only in housing, but also in other arenas. And needless to say, the fair housing legislation at the height of civil rights and as it has a history of social movement,it is all there. But in India, we have not seen such a kind of mobilization happening in the context of housing rights. In the present circumstances in India, I can only pin my hope on the judiciary, though I may be wrong.And you're right in saying, how can we call it self segregation, even though it is also being furthered as a result of the existing legal framework itself. So that is where even vibrant ideas of equality, anti-discrimination and liberty they come to rest in the absence of political will. So if you see, if you slightly deviate from the discussion, you see the Sabarimala judgment. So on one hand we have the apex court saying that women should be allowed from now on to enter the temple premisesa nd we have a communist government in place but even the communist government is reluctant to implement it. So what is the use of legal framework when the object of a law or judgment is itself diluted? That's the question we need to ask.

Ms. Sinchan Chatterjee

Right, yes. Okay, I'll move on to the next question. So, which is on a bit of the similar lines, that ghettoization of minority communities is not a region-specific issue. It is found in every part of the nation, albeit like in lesser degrees as it happens in Ahmedabad or certain parts of Delhi also, I'd say. Instances of housing discrimination and ghettoization even in the national capital of the country is very prominent and studies show that this ghettoization is not only an evolutionary phenomenon where the members of a community particularly those who are minority settle together but it is also a result of systemic discrimination where the state actively prevents the socioeconomic development of these areas. Do you think the judiciary has the authority and the responsibility to intervene? If not, what is the solution for this issue? 

Mr. Devansh Srivastava

Segregation does not only have a negative connotation, it also has a positive tone, which is that of solidarity through various forms of residential living. And this is actually discussed at length in Michael Mary's work ‘In a difference of separation’. So the point that arises here is whether it is exclusionary in nature. When does it become so? So ghettoization as you said, it's actually not very a new phenomenon as such. It is very structural at multiple levels. And these are areas that lack basic necessities and many times town plan systematically exclude the extension of public services to such areas and one such example that I can think of is Juhapura and Ahmedabad and there is plenty of literature available on that. 

But in an ideal sense, I would say the legislature should take charge of formulating the policy indeed, but in a state of states, our expanding beyond its limit, which is the say abuse of power or something like that it is for the judiciary to take charge. And I really like to use a phrase of Professor Upendra Bakshi who says in a lecture that if the state is a voluntary bystander So I like this phrase of voluntary bystander so in the context of your question it is Judiciary's responsibility to intervene when the state appears as a voluntary bystander to systemic discrimination or being indifferent to the plight of a particular area And if we can deviate a bit from our discussion here, and we come to the recent developments in India, that is of housing demolitions and bulldozer justice as it is called then we need immediate intervention of the court and the situation has not just emerged due to the lack of accountability and transparency of the state institutions, it is also Sushma Pati says about the apolitical nature of the basic necessities such as housing but with the way Court’s have responded to the plight of the housing in the recent decade, it is in stark contrast to the socialist bend the judgemebnts of the 70s and 80s, one such example is the OIga Tellis case, however, I am not in the position to discount the activists do to run to the courts for justice. So Judiciary is very important, one pertinent example of what the work actvitist do is that of Mr. Mujahid Nafees, who is with the Minority Coordination Committee in Gujarat and the recent Gujarat HC ruling in the public flogging case of a Muslim Youth against an errring Policeman was an enormous task that the committee took upon. So the question is of Accountability of the state so the Court becomes a mediator as well as of a facilitator in addition to being an authority. So, indeed there is a moral, ethical dilemma that arises out of it. In the end, I do believe in Courts and Judges, so let’s pin our hope on that.

Ms. Sinchan Chatterjee

To just ask this as follow up, you mentioned the Bulldozer Justice Jahangirpuri Demolition..

Mr. Devansh Srivastava

Juhapura

Ms. Sinchan Chatterjee

Oh Okay. I just wanted to ask, the SC took cognizance of the matter once the demolition had begun and then stayed it. Do you think that the case by case cognizance given by the court is enough or there should be some directions that should be given to the Union or States for that matter in this particular issue that the Judiciary needs to actively take up?

Mr. Devansh Srivastava

I just need to clarify one thing, I said Juhapura in the context of Systemic ignorance of the state, that is in Ahmedabad. But what you mean is Jahangirpuri in Delhi. I feel that merely cognizance is not enough, but at the same time there at least needs to be directive from the SC that such arbitrary nature of demolition is not to be done and is in a violation of the rule of law. So that kind of a directive is very much required, and apart from that SC needs to work swifty because the people have lost home and they are on the road and the matter comes to the SC is after three, four,  six month later. So the question arises is where is the sense of Justice that people can fall back on?

Ms. Sinchan Chatterjee

While your passion for the situation in Ahmedabad is justified given your own nativity to Gujarat after your 2020 essay, ‘Fencing Neighbourhoods, Politics of Segregation, Restrictive Zoning and Searching Mobility in Ahmedabad’, and your 2021 essay, which was ‘Mobility as a Prohibited App, Thinking Desegregation through Clustered Neighbourhoods and Gendered Property Ownership in Ashran's Ahmedabad’, what prompted you to write another paper dealing with a similar topic? Have you discovered any changes in the legal landscape since publishing the previous works? And has there been any change in your own opinions when it comes to the topic of urbanised segregation? And perhaps even in other places between those articles and the current one, which is also much more focused on Gujarat in specific? 

Mr. Devansh Srivastava

So I would like to clarify that I am not a native to Gujarat. In fact, there is no association of mine with Gujarat at all. I have been researching social spatial segregation in Gujarat since 2018, though I began my doctoral work in 2021. And the first paper that you mentioned is an essay. So basically, it is a very speculative piece. It is devoid of any empirical insight. And it is a kind of ideal that I am trying to see in an integrated society. And the other paper is from my ample thesis, which is about a month of fieldwork that I did in Ahmedabad city and what I found. And I am thinking of the idea of desegregation in that. But the paper that we are discussing today is about the district areas act and the case laws. I am trying to understand how has the act fared, basically, and how does it speak to the promise that it makes, that is to prevent ghettoization in the city. And this is also a time that I am trying to understand the discipline of public policy. So responding to your question on what prompted me to write another paper on a similar topic, it is to engage with the policy. Actually, what a policy does over a period of time, how it evolves and develops. Also, I remember reading an interesting article where Jan O'Palo writes an African perspective that academic research and policy research are two different things. But what we see is policy research happening in academic institutions, it follows a certain trajectory where researchers are required to please their peers, publish papers, get grants. And this is not really beneficial for understanding policy making in the real world. This is what his argument goes like. And also he says that what is expected from me as an expert, so-called academic expert, is that I can speak to four different contexts in the same research area, which may not really have a bearing on the practicality of how policy develops, really, from small cases. So he actually advocates studying policy over a long period of time, and I think this is actually what I have been doing myself. It is actually for the scholar to speculate as to how they want to understand the impact of a policy. Is it through a period of time that they are seeing that how is it manifesting and having consequences through different institutions. 

Ms. Sinchan Chatterjee

Okay, alright. So your paper on religion and blasphemy laws tackle a wide array of themes. It goes from pre-independence thought to revolutions in America, to evolutions in history, philosophy and analysis in the Indian construct. The paper reads more, almost like a rapid, passionate train of thought, while if we look at your paper on the disturbed areas, act on urbanising spaces in Gujarat, we can see the clarity of thought and intention behind every word. While your first essay delved into numerous topics with brilliance, this newer one tackled a single issue with utmost precision and detail. As aspiring legal academicians amongst ourselves, we have faced the problem of being attracted to too many topics or being too haywire with our own writings. How does one achieve clarity and precision in their writings? And how did your own experience with finding specific areas of interest turn out leading to your writing to the juncture it is at today? 

Mr. Devansh Srivastava

There has been some change with regard to understanding of ghettos. In a recently published book review, I have argued that there is a contrasting view of ghettos emerging in Indian scholarship, and one needs to pay attention to Sander and West Copland's study in our industry, where her argument is on ghettos as centres of regional mobility, where residents living in ghettos are not only looked at from a receiving end, but they also have a certain sense of agency in their actions. So presently I am trying to engage with that. The essay on religion and blasphemy laws was written almost a decade back during my masters, and indeed I was a very passionate individual about freedom of speech, blasphemy. But actually the skill that I lacked that time was how to be coherent in my thoughts and how to put them together. And my journey from that time to the National Law School has taken some time, and it has been full of learning. It has been a very great source of learning and experience. I have learned to become coherent, clear and concise in writing, mostly after spending time again at the law school. And since teaching here is an intrinsic part of doctoral training, I believe it has also been critical thinking skills that doctoral scholars teach here, are taught here, and they also teach it to the masters students here. Learning how research works has taken actually a long time for me to understand. I also deviate at times because there are so many interesting topics going around, and there is so less time. So to me the topic should at least feel personal. When I am doing segregation, the question is why am I at all engaging with this as my doctoral topic. What I mean to say is that what is it that I seek as a value-based input that comes along with this research work. And since segregation is my prime area of interest, I have read a wide range of fiction and non-fiction on conflict settings. I do watch movies and documentaries revolving around the similar themes of segregation in different contexts. So writing skills also evolve over a period of time, and for my case also it is the same, it has taken some time to develop. So I would say that it is always good to stay connected to one's areas of interest. That is what I have learned and that is what I will tell fellow researchers and scholars. Thank you.