‘Untrustworthy and Unbelievable’ in the voter list, and with one bureaucratic motion, their rights are deprived. !!7 Individuals are marked as D Voters arbitrarily with no logic or inquiry and the status can only be changed through extensive litigation before special bodies called the Foreigners Tribunals.!!8 The notification Sabjan Nessa received informed her of the dreaded ‘D’ next to her name. The onus is now on her to show that she is truly a citizen. C The NRC The events and legislative changes described in the previous part finally culminated in the demand for a stringent tool to codify who amounted to a citizen. This was the National Register of Citizens. The NRC is a form of citizenship identifier, aimed at screening illegal migrants and deporting them to their ‘homelands’. The VRC has been defined as a ‘register containing details of Indian citizens living in India and outside India’.!!° In 2009, a petition called for an update to this list, which was taken up by the Supreme Court of India. !2° Inclusion in the NRC is essentially a documentary exercise based on the notion of lineage. The documents needed to get a person’s name enlisted in the NRC require that a relationship be established with any member of their family who settled in Assam prior to the cut off year.!2! Not surprisingly, this lineage requirement has strong patriarchal connotations. In multiple cases women were unable to prove that they were related to their parents, since most of their documents are usually in the name of the husband. !22 This challenge is aggravated in context of child marriages, which are common; Assam bears the dubious distinction of having the highest number of child marriages in the country. !23 Marriage to a citizen is not considered sufficient grounds — jus soli principles make it imperative that a link to the parents be proven. Women also move into their marital homes, and as a result leave their original constituencies, which 117 ibid. 119 Citizenship (Registration of Citizens and Issue of National Identity Cards) Rules, 2003, GSR 937(E) r 2(k) (India). The National Register of Citizens is divided into state, district, subdistrict and local registers and consists of the 18" ibid 25-26. name, parents’ name, sex, date of birth, place of birth, residential address (present and permanent), marital status — If every married, name of the spouse, visible identification mark, date of registration of citizen, serial number of registration, and National Identity Number. 120 121 Assam Sanmilita Mahasanga and Ors v Union of India [2015] 3 SCC 1 20 (b) (Supreme Court of India) 12 [20]. ‘What Are the Admissible Document?’, Government of Assam, Office of the State Coordinator of — National Registration (NRC) Assam (Web Page) <http://nrcassam.nic.in/admin-documents.html>. These include 1. 1951 NRC 2. Any electoral rolls up to 24 March 1971. 3. Land and Tenancy records 4. Citizenship Certificate 5. Permanent Residential Certificate 6. Refugee registration certificate 7. Passport 8. Life Insurance Corporation certificate 9. Any government issued license or certificate 10. Government service or employment certificate 11. Bank or post office accounts 12. Birth certificate 13. Board or university educational certificate 14. Court records or proceedings. The rules provide that married women, who are expected to face challenges in proving their lineage, can produce a certificate issued by the Circle Officer or a Gram Panchayat Secretary along with a ration card issued before 25 March 1971. 122 Siddique (n 115) 26. 123 ‘Smriti Irani: 501 Child Marriages Reported in India in 2018; Maximum in Assam’, Pune Mirror (20 March 2020) <https://punemiurror.indiatimes.com/news/india/smriti-irani-50 1child-marriages-reported-in-india-in-20 1 8-maximum-in-assam/articleshow/74731949.cms>. 249