‘Untrustworthy and Unbelievable’ The women in this limited sample were able to present multiple documents before the FT. Eight different types of documents were identified (see table above), which were submitted in different combinations in different cases. However, the court applied stringent standards and rejected each of these documents on various, often arbitrary, grounds. One of the most common documents presented is the certificate by the local government official called the Gaonburah. It was found that this document was rejected in several instances on account of the failure of the woman to produce the Gaonburah in question before the Court. This requirement has been upheld in the upper judiciary — in Jalekha Khatoon v Union of India,'*° the Gauhati High Court held that the production of the Gaonburah certificate, which is an admissible document, is not enough on its own to prove the citizenship of a woman; it must be corroborated through the testimony of the issuing authority. However, even this is not always fool proof; in one of the cases we examined, it was proven that the woman in question was linked to her father through the Gaonburah’s deposition. However, discounting this, the Court then went on to cast doubt on the question of whether her father was related in turn to his father, and on this basis dismissed her documents. Despite there being three witnesses to attest to her account, the Court held that, *... she [failed] to prove any vital document to prove her linkage that she is the granddaughter of Jel Haque, s/o Tofer Ali, the projected grandfather of the proceedee by any cogent oral or documentary evidence.’ !4! In summary, the process seems to be rife with inconsistencies, with no clarity on what direction the FT may take. Voter lists, electoral ID cards and any documents issued post the cut-off date of 1971 are dismissed. The 1951 NRC data is not considered as admissible evidence. Given that most of these women are not educated, they are unable to produce educational documents to attest their claims. Moreover, it is not a stretch to assume that it would be difficult for women to produce the issuing authority for their marriage certificate Gaonburah certificate before the Court, given that women migrate on account of marriage or due to climatic factors. !4 In all but one of the cases we examined, the land records were produced in the name of the father of the woman, which was not sufficient to prove her citizenship. While we do not make the claim that these arbitrary dismissals exercised by the FT are solely based on gender, it is nonetheless clear that there are huge structural barriers for women to prove their identity before the adjudicatory bodies. Acquiring valid documentation, as discussed, presents a far more monumental challenge for women. The multiple intersections of identity work in tandem to disadvantage the body of women who undergo the legal process of citizenship in India. While the text of the judgments is careful to avoid reference to the religion or ethnic identity of the person in question, identity markers such as the surname point to the women being either Bengali or Muslim, or both. This is consistent 140 Jalekha Khatun v Union of India (2019] WP(C) No 7919/2018, 2—3 (High Court of Gauhati). 141 State of Assam v Hanufa Khatun [2018] FT Case No 214/15 (Foreigners Tribunal 4 Goalpara). Chandrani Sinha, ‘Climate Refugees Stripped of Citizenship in Assam’, Zhe Third Pole (online, 8 August 2019) <https://www.thethirdpole.net/2019/11/08/climate-refugeesstripped-of-citizenship-in-assam/>. 142 253