2020 Statelessness & Citizenship Review 2(2) administratively. Transgender women often lose all connections with their families, hampering evidence-gathering later in life. 148 The roots of inter-ethnic conflict in Assam may be traced even earlier, to the mid-19th century, when British colonisers sponsored the migration of Bengali speaking Muslims to work in the tea industry. 149 By the beginning of the 20th century, migrants comprised close to one third of Assam’s population. 150 Thus, Assamese nationalism grew against a population they considered to be a threat: primarily Bengali speaking Hindus and Muslims. Soon after independence, in 1951, the concerns about the influx of migrants to Assam led to the Parliament of Indian enacting the Immigrants (Expulsion from Assam) Act, 1950. The Act allowed authorities in Assam to expel immigrants whose entry and stay is ‘detrimental to the interests of the general public of India or of any section thereof or of any Scheduled Tribe in Assam’. 151 In addition, the government initiated a first attempt at a ‘National Registry of Citizens’. 152 Xenophobia against real or perceived migrants in Assam continued after independence and was the cause of major outbreaks of inter-ethnic violence. The reaction of the authorities was primarily repressive. For example, between 1961 and 1967, Assam implemented a ‘detect and deport’ policy which saw the deportation of 66,000 persons to East Pakistan. 153 After the independence of neighbouring Bangladesh from Pakistan in 1971, there was an additional influx of refugees into Assam, accompanied by further anti-Bengali riots. 154 The tensions grew steadily. In 1979, it was discovered that 45,000 undocumented Bangladeshi migrants had been listed on the electoral rolls, sparking further unrest led by the All Assam Students Union. In the 1983 elections, Assamese Nationalists perpetrated the ‘Nellie Massacre’, which took the lives of at least 2,000 persons, mostly Bengali Muslims. 155 Continuous pressure by Assamese Nationalists led to the signing of the ‘Assam Accord’ in 1985. This agreement provided that: 148 Nanrita Pandecha, ‘The National Register of Citizens in Assam: A Flawed Policy Process’ 149 150 151 152 153 154 155 Geopolitical Monitor (Blog Post, 30 July 2019) <https://www.geopoliticalmonitor.com/thenational-register-of-citizens-in-assam-a-flawed-policy-process/>. Monica Encinas, ‘Migrant Rights and Extraordinary Law in India: The Cases of Assam and Jammu & Kashmir’ (2017) 40(3) South Asia: Journal of South Asian Studies 463. ibid 465, quoting Sanjib Baruah, India against Itself: Assam and the Politics of Nationality (University of Pennsylvania Press 1999) 46. Immigrants (Expulsion from Assam) Act, 1950, Act No 10 of 1950 (India) s 2; Designed to Exclude: How India’s Courts are Allowing Foreigners Tribunals to Render People Stateless in Assam (Report, Amnesty International 2019) 8 <https://amnesty.org.in/wpcontent/uploads/2019/11/Assam-Foreigners-Tribunals-Report-1.pdf> (‘Designed to Exclude’). Roli Misra and Shipra Srivastava, ‘Identity Crisis and National Register for Citizens in Assam’ (2018) 11(1) UPUEA Economic Journal 104; Ipsita Chakravarty, ‘Why Did Assam Prepare the 1951 NRC, Which Has Become a Touchstone for Citizenship Today?’, The Final Count (online, 17 July 2019) <https://scroll.in/article/931879/why-did-assam-prepare-the1951-nrc-which-has-become-a-touchstone-for-citizenship-today>. Monirul Hussain, ‘State Development and Population Displacement in North-East India’ in C Joshua Thomas (ed), Dimensions of Displaced People in North-East India (Regency 2002) 288, quoted Encinas (n 149) 466. ibid. Makiko Kimura, The Nellie Massacre of 1983: Agency of Rioters (Sage 2013). 216