Chakrabarty: Citizenship Deprivation as an Act of Persecution: Case Study of t grounds of jurisdictional errors or violations of natural justice principles.141 Moreover, DFs are excluded from appeals.142 This is concerning, since there is no second appreciation of facts or evidence and more than often no ‘judicial’ application of mind. In several cases, appeal procedures have been reported as compromised, with individuals not even being issued speaking orders over their exclusion.143 Further, inclusion in the NRC and even citizenship determinations before civil courts, does not guarantee security. There exist procedures parallel to the application-verification method, where Electoral Registration Officers and the Border Police Organisation officials have the power to mark individuals as suspicious or DVs and refer them to the FTs. 144 In 2018, the GoI placed on record before the Court a Standard Operating Procedure meant for raising claims and objections (over inclusion or exclusion from the draft list). 145 But the procedure as it stands allows anybody to raise objections over the inclusion of an individual, with no penalties for false and frivolous complaints.146 These provisions allow individuals to be dragged into the citizenship conundrum multiple times, without any finality. Some media reports have also claimed that former authorities who presided over these tribunals felt compelled to rule against individuals, as a precondition to renewal of their contracts which was done at the instance of a state established “monitoring committee”.147 In 2008, the Assam High Court had directed the state to build detention camps for housing DFs and DVs.148 These camps are built within carceral institutions, but individuals are not allowed 141 State of Assam v Moslem Mandal, 2013 (1) GLT (FB) 809. FT (Orders) 1964, clauses 7 and 8. 143 Abhishek Saha, “Glaring gaps in orders: Gauhati HC indicts a Foreigners’ Tribunal”, Indian Express (7 October 2019), online: <https://indianexpress.com/article/north-east-india/assam/glaring-gaps-in-orders-gauhati-hc-indicts-aforeigners-tribunal/>. 144 White Paper, supra note 11 at 7, 23 (initially vested under sections 3(2) (a), (b), (c) and (cc) of the Foreigners Act, 1946 upon police authorities and local administrative officials). 145 Assam Public Works v Union of India, Writ Petition (Civil) No 274/2009 (Order dated 1 November 2018 & 12 December 2018) online: <https://cjp.org.in/wp-content/uploads/2018/08/20180816-SC-Order-on-NRC-Claims-andObjections-Modalities-Assam-Public-Works-vs-Union-of-India.pdf>. 146 “Standard Operating Procedure (SOP)/modalities for disposal of claims and objections in the updation of National Register of Citizens (NRC) 1951 in Assam”, Citizens for Justice and Peace at para. 3(1)(d), online: <https://cjp.org.in/wp-content/uploads/2019/05/SOP-Modalities-Claims-Objections.pdf>. 147 Arunabh Saikia, “The Highest Wicket-Tacker: Assam’s Tribunals are Competing to Declare People Foreigners”, Scroll (19 June 2019), online: <https://scroll.in/article/927025/the-highest-wicket-taker-assams-tribunals-arecompeting-to-declare-people-foreigners>. 148 Nazimuddin Siddique, “Inside Assam’s Detention Camps: How the Current Citizenship Crisis Disenfranchises Indians” (15 February 2020) 55:7 Economic and Political Weekly, online: <https://www.epw.in/engage/article/inside-assams-detention-camps-how-current>. 142 Published by Osgoode Digital Commons, 2021 25