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Delhi District Court

Of Nurenburg vs . Superintendent, Presidency Jail, ... on 20 September, 2011

                     IN THE COURT OF SH. ARUL VARMA :
        LD. METROPOLITAN MAGISTRATE (SPECIAL COURT - 2) :
                        DWARKA COURTS : NEW DELHI



In the matter of: ­

FIR No.          :   78/10.
PS               :   IGI Airport.
U/s              :   419/420/468/471/120B IPC & 14 Foreigner's Act.



State

V/s

Chandra Kumar & Others.



             ­ :: ORDER ON SENTENCE AND DEPORTATION :: ­



FACTS



1.      Before  an   order   on   sentence  is   passed  in   the   present  matter,   it 

        would be apposite to succinctly recapitulate the facts of this peculiar 

        case:­



        The convict Chandra Kumar is a Sri Lankan Tamil refugee who has 

        been staying at a refugee camp in India from the year 1990.   He 

        sought to eke out a better life in Italy but while leaving India, he was 

        apprehended by the immigration authorities as he did not possess 

        valid travel documents.   Thereafter, he was charged for committing 

        the offences of cheating, impersonation and forgery r/w/s 14 of the 


FIR No.: 78/10.                                                       Page No. 1 of 49
      Foreigners Act, 1946.   He claimed that he was duped by a travel 

     agent.   He moved an application for plea bargaining.   Pursuant to 

     moving   of   an  application  under  the  benevolent  provisions  of   plea 

     bargaining recently incorporated in the Code of Criminal Procedure, 

     1973, Chandra Kumar was convicted of the aforesaid offences upon 

     his admission of guilt.  Had he been an Indian citizen, he would in 

     all probability have been set free at this stage, having been already 

     incarcerated in judicial custody for a period of almost 6 months.  An 

     order on sentence would have been passed forthwith.  However, the 

     Ld.   Additional   Public   Prosecutor,   on   instructions   from   the 

     State,  contended   that  an  order  of  deportation  should   form  a 

     part of the order on sentence.  It is in light of these circumstances 

     that   a   detailed  order  is   required  to   be  passed  while  handing   out 

     sentence  to   the   accused.    The   issue   of   deportation   needs   some 

     expatiation.



SUBMISSIONS



2.   The   Court   had   a   query   regarding   whence   this   Court   derives 

     authority to deport the convict herein.  Ld. APP had contended that 

     the Court has powers u/s 3 (2) of the Foreigners Act, 1946 to order 

     deportation.  However, a bare reading of the provision indicated that 

     it is the prerogative of the Central Government to order deportation 

     and   the   Courts   do   not   possess   any   authority   to   do   so.     This 

     understanding was fortified by the below mentioned observation of a 

     Constitutional Bench of the Hon'ble Supreme Court in Hans Muller 



FIR No.: 78/10.                                                    Page No. 2 of 49
      of Nurenburg  Vs. Superintendent,  Presidency  Jail,  Calcutta  & 

     Others, 1955 AIR SC 367: ­



            "20. ... ... ...  The right to expel is conferred by Section  
            3(2)(C)   of   the   Foreigners   Act,   1946   on   the   Central  
            Government   and   the   right   to   enforce   an   order   of  
            expulsion and also to prevent any breach of it, and the  
            right to use such force as may be reasonably necessary  
            "for the effective exercise of such power" is conferred by  
            Section 11 (1), also on the Central Government.

            22. The   Foreigners   Act,   1946   confers   the   right   of  
            expulsion   on   the   Central   Government.     Therefore,   a  
            State Government has no right either to make an order  
            on expulsion or expel."


3.   Thus it is clear that the order to deport cannot be passed by this 

     Court.     But,   the   question  remains  that  is   there   any   bar   which 

     prohibits this Court in passing an order whereby the convict herein 

      shall  not
                 be deported
                            ?  This order seeks to shed some light on this 

     aspect.



4.   The   Ld.   APP   had   stated  that   relevant  documents  containing  the 

     modalities   of   deportation   would   be   in   the   possession   of   the 

     Foreigner's   Regional   Registration  Office  (FRRO),  New  Delhi.  Court 

     notice   was   issued   to   the   FRRO,   and   consequently   Incharge, 

     Immigration Cell from the FRRO entered appearance and produced 

     Government   Order   F.No.   25019/3/97­F.III  dated  2.7.1998  of 

     the   Foreigners   Division,   Ministry   of   Home   Affairs,   Government 

     issued  by   Under   Secretary  to   the   Government   of   India   to   Home 

     Secretaries of all States/UTs.   The Courts attention was invited to 


FIR No.: 78/10.                                                    Page No. 3 of 49
      para   no.   2   of   the   aforesaid   Government   Order.     The   same   is 

     reproduced as hereunder: ­



            "2.     However, there have been cases where foreigners  
            either   overstay   illegally,   go   underground   or   engage  
            themselves   in   undesirable/illegal   activities.     In   minor  
            offences,   action   is   taken   to   deport   the   foreigners   by  
            serving   them   with   Leave   India   Notices   u/s   3   of   the  
            Foreigners   Act.     For   serious   offences   like   long  
            overstayal, commission of offences under various other  
            Acts like IPC, NDPS, Customs etc., cases are instituted  
            in   the   court   of   laws   and   the   foreigners   may   undergo  
            long   periods   of   imprisonment   awarded   by   court.  
            Finally, in both these cases, the foreigners have to be  
            deported out of India."


5.   The FRRO also filed a copy of Notification No. F.22(29)/91­PPF­4058 

     dated   22.8.1991   issued   by   the   Delhi   Administration   and 

     Government of India's Notification No. 4/3/56(II)F.I dated 30.9.1992 

     whereby the power to deport under the Foreigners Act, 1946 was 

     delegated  by   the   Central  Government   to   the   FRRO.    It   was  also 

     submitted that all the foreign nationals who are received from jail 

     after conviction/acquittal are handed over to the FRRO by the local 

     police for their further deportation to their country of origin.



6.   A   query   was   raised   regarding   the   existence   of   any 

     notification/order/regulation   etc.   specifically   dealing   with   the 

     modalities   of   deportation   of   Sri   Lankan   refugees.     Counsel   for 

     convict also sought information regarding grant of citizenship to the 

     convict herein in order to avert his deportation.  However, the official 

     from FRRO submitted that the Foreigners Division, Ministry of Home 



FIR No.: 78/10.                                                       Page No. 4 of 49
      Affairs   would   be   in   a   better   position   to   clarify   the   intricacies 

     regarding deportation, and accordingly, court notice was sent to the 

     Ministry   whereupon   Dy.   Secretary,   Ministry   of   Home   Affairs 

     (Foreigners  Division)  entered  appearance  to  furnish  the  necessary 

     clarification which would enable the Court in the determination of 

     the following queries: ­



            "1.(A)      In general, what are the documents which  
            contain   the   rules/regulations/notifications/orders  
            governing the deportation of a Sri Lankan refugee.

            (B)           In                  particular,                     the  
            rules/regulations/notifications/orders   which   makes  
            deportation   of   a   Sri   Lankan   refugee   mandatory   upon  
            being   convicted   of   an   offence   under   the   laws   of   the  
            land.

            2.              A   copy   of   1996   order   of   the   Centre   (G.O.  
            370).     The   reference   to   this   order   has   been   made   in  
            page no. 132 of the written submissions filed on behalf  
            of the convict.

            3.          Can   a   refugee,   who   has   been   convicted  
            under the IPC, apply for citizenship in India?  If so, the  
            procedure thereof.

            4.           Does the Government make any distinction  
            between   the   nature   of   offences   committed   while  
            ordering deportation of a refugee?  In other words does  
            the   commission   of   a   less   serious   crime   result   in   the  
            grant of some exemption from deportation?

            5.             Whether   the   State   of   Tamil   Nadu   has   a  
            specific   policy   whereby   Sri   Lankan   refugees   are   not  
            deported?

            6.              What   are   the   modalities   involved   in  


FIR No.: 78/10.                                                         Page No. 5 of 49
              procuring citizenship of India by a refugee?   Does the  
             sojourn   by   a   refugee   for   the   last   20   years   in   India  
             entitle him to avail the benefits extended to a citizen?"


7.   On   20.8.2011,   the   Dy.   Secretary   filed   a   detailed   reply   to   the 

     aforesaid queries.  The reply of the Ministry was to the effect that the 

     convict herein was liable to be repatriated as he was liability of Sri 

     Lanka.



8.   On the other hand, counsel for convict filed his written submissions 

     and placed reliance on the following judgments: ­



     (i)     Hasan Ali Raihany Vs. Union of India, (2006) 3 SCC 705.



     (ii)    Dr. Malavika Karlekar Vs. Union of India & Another, Writ Pet. 

             (Crl. No.) 583 1992.



     (iii)   National  Human Rights Commission Vs. State of  Arunachal 

             Pradesh & Another, AIR 1996 SC 1234.



     (iv)    Louis De Raedt & Others Vs. Union of India & Others, 1991 

             AIR 1886, 1991 SCR (3) 149.



     (v)     State of Arunachal Pradesh Vs. Khudiram Chakma, AIR 1994 

             SC 1461.



     (vi)    U. Myat Kyaw & Others Vs. State of Manipur & Others, Civil 

             Rule No. 516 of 1991.



FIR No.: 78/10.                                                         Page No. 6 of 49
      (vii)   Seyed Ata Mohamamdi Vs. Union of India & Others, AD 1458 

             of 1994.



     (viii) Zothansangpuii  Vs.  State  of   Manipur,   Civil  rule  No.  981  of 

             1989.



     (ix)    Khy Htoon & Others Vs. State of Manipur, Civil Rule No. 515 

             of 1990.



     (x)     Raju Vs. State of Tamil Nadu & Others, Writ Pet. No. 24063 of 

             2005 and WPMP No. 26235 of 2005.



     (xi)    Ktaer Abbas Habib Al Qutaifi & Others Vs. Union of India & 

             Others, 1999 Cri LJ 919.



     (xii)   Vishaka & Others. Vs. State of Rajasthan & Others, 1997 (6) 

             SCC 241.



     (xiii) David Patrick Ward & Another Vs. Union of India & Others, 

             (1992) 4 SCC 154.



     (xiv)   Premavathy @ Rajathi presently interned at Special Camp for 

             Srilankan Refugees Chengalpattu Vs. State of Tamil Nadu & 

             Others,  HCP  No.   1038  of   2003  and  HCP  Nos.  11.1,   1118, 

             1119, 1120, 1121, 1122, 1123, 1085, 1170 and 1226 of 2003.




FIR No.: 78/10.                                                Page No. 7 of 49
       (xv)    Ram Singh Vs. State of Rajasthan, 1978 WLN UC 90.



      (xvi)   J.  Vasantha Gladis Daisy Vs. The Superintendent of  Police, 

              WP (MD) No. 10423 of 2005.



      (xvii) Suo   Moto   Vs.  State  of   Rajasthan,   RLW   2005  (2)   Raj  1385, 

              2005 (4) WLC 163.



9.    Counsel   for   convict   further   stated   that   the   convict   has   valid 

      documents to stay in India and that he is in possession of a Refugee 

      Certificate.     Counsel   for   convict   further   submitted   that   the 

      Government   Order   F.No.   25019/3/97­F.III   dated   2.7.1998   is 

      applicable only to foreigners who overstay illegally, go underground 

      etc. and that the order is not applicable to the convict herein as he 

      possesses   valid   documents.     It   was   further   contended   that 

      deportation can be ordered only when there are compelling reasons 

      which threaten to jeopardize national security.  Traveling on a forged 

      passport  is   not   that  heinous  an   offence  to   pose  a   danger  to   the 

      security of the country, and cannot be equated with grave offences 

      like sedition, murder, rape, dacoity etc.



10.   The   arguments  of   counsel  of   the   convict  can   be   summed  up   as 

      under: ­



      •       The convict has a well founded fear of persecution in case 

              he is deported to Sri Lanka.




FIR No.: 78/10.                                                     Page No. 8 of 49
      •     India   is   bound   by   the   Customary   International   Law   and 

           consequently   the  principle   of   non­refoulement  forbids 

           deportation of the convict herein as he has a well founded fear 

           of persecution.



     •     Article 21 of the Constitution of India which protects life and 

           liberty  of  all­citizens and  non­citizens alike, is applicable in 

           the   present   case  and  the   convict  refugee's  life   ought   to   be 

           protected as per the mandate of Article 21.



     •     If an individual poses no danger or threat to the security of 

           the country, he ought not to be deported.



     •     Various High Courts have stayed the deportation proceedings 

           invoking humanitarian grounds.



     •     Our nation must march with the international community and 

           the municipal law must respect rules of international law just 

           as nations respect international conventions.   The comity of 

           nations   requires   that   rules   of   international   law   may   be 

           accommodated  in   the   municipal  law   even   without   express 

           legislative sanction.



     •     Article 51 (c) of the Constitution of India mandates that the 

           State shall endeavour to foster respect for international law 

           and treaty obligations in the dealings of organised people with 

           one another.


FIR No.: 78/10.                                                   Page No. 9 of 49
       •     The   provisions  of   a   convention  which   elucidate  and   go   to 

            effectuate   the   fundamental   rights   guaranteed   by   our 

            Constitution   can  be  relied  upon  by   the  Courts  as  facets  of 

            those fundamental rights, and thus can be enforced.



      •     An international convention consistent with the fundamental 

            rights, and in harmony with its spirit, must be read into those 

            provisions to enlarge the contents thereof.



      •     An opportunity should be granted to the convict to approach 

            the UNHCR, Delhi to avert deportation.



11.   During the course of arguments, counsel for convict filed additional 

      written submissions in response to the reply dated 20.8.2011 filed 

      by the Dy. Secretary, Ministry of Home Affairs, the gist of which is as 

      hereunder: ­



      •     Para 2 of annexure VI is explicit in as much as it states that 

            there  is  no   policy  or   plan  to   deport  any  of   the  Sri   Lankan 

            Tamil refugees living in Indian camps, to Sri Lanka.



      •     Para 2 of annexure VI also reads "if a refugee in a camp is 

            involved  in  any  illegal  activity  punishable  under  the  Indian 

            Penal Code, he is dealt with in accordance with the provisions 

            in criminal law".  According to this para the refugee should be 

            dealt in accordance with criminal law.  However, the criminal 


FIR No.: 78/10.                                                   Page No. 10 of 49
              laws do not provide for deportation.



      •      The   Ministry   of   Home   Affairs   had   replied  that   the   convict 

             himself has to establish fear of persecution.   It is submitted 

             that only a well founded fear of persecution is required to be 

             established and not a fear of persecution beyond reasonable 

             doubt.



      •      Para   no.   (iii)   of   the   Government   Order   No.   370   dated 

             10.9.1996,   which   is   reproduced   as   hereunder,   is   not 

             applicable: ­



                    "(iii) Srilankans who have arrived in India from  
                    January   1993   onwards   may   be   dealt   with   in  
                    accordance  with the existing legal provisions  as  
                    applicable to any other foreigner."


             At this juncture, it would be pertinent to note that the convict 

             herein   came   to   India   prior   to   1993   and   as   such   the 

             Government Order ought not to be applicable to the convict 

             herein.



12.   After hearing submissions of both the parties, and at the request of 

      the counsel for convict, intervention of the UNHCR was also sought 

      vide   order  dated  5.8.2011.     However,  the   court   notice   issued  to 

      UNHCR was returned  unserved  as  the  Chief  of Missions,  UNHCR 

      claimed immunity from due legal process and requested the Court to 

      obtain information from  the  UNHCR  only   through  the  Ministry  of 

      External  Affairs,   Government   of   India.     Court   notice   was   issued 

FIR No.: 78/10.                                                   Page No. 11 of 49
       afresh apprising the UNHCR that no action had been taken or was 

      ever  contemplated  to   be   taken  against  the   UNHCR  and  that   the 

      Court  had  merely sought  its intervention in order  to arrive  at  an 

      informed decision.  At the same time, the order dated 5.8.2011 was 

      routed   to   the   UNHCR   through   the   Ministry  of   External   Affairs. 

      Despite being personally apprised of the proceedings in the Court by 

      the   DCP   (F),   Ministry   of   External   Affairs   and   after   receipt   of 

      assurance of consideration by the UNHCR, none appeared on behalf 

      of   the   Agency.   A   positive  response  from   the   Agency   would  have 

      thrown more light on the matter. Be that as it may, it is imperative 

      to deal with the contentions of both parties.



INTRODUCTION



13.   The  annals  of   history   are  replete  with   instances  where   prolonged 

      suppression and tyranny gives rise to rebellion and ultimately to a 

      revolution that might lead to dethroning the unjust regime.   After 

      the enaction of the 'Sinhala only' law which made 'Sinhala' as the 

      national language of Sri Lanka and which curtailed job opportunities 

      for the minority Tamilians, led to peaceful protests in the island.  A 

      time  came  when  peaceful  agitations  did  not   yield  any   result  that 

      some fundamentalists took to arms and formed organisations that 

      propagated violence and terror as a means of achieving one's goal.



14.   It is when the ongoing conflict between the government and the rebel 

      forces   were   taking   place,  refugees   from   Sri   Lanka   came   in   four 

      waves.  The convict herein had also to leave his country of birth in 


FIR No.: 78/10.                                                    Page No. 12 of 49
       order to save himself and his family from being massacred.



15.   The   following   poignant   theme   is   evocative   of   the   ordeal   that   a 

      refugee has to suffer: ­



      "One refugee without hope is too many."



      This is also the Global Theme for the World Refugee Day, in 2011. 

      The   video   can   be   seen   at   the   UNHCR  website   where   Hollywood 

      actress Angelina Jolie, Goodwill Ambassador has appealed the world 

      to 'do one thing' for the cause of refugees.



16.   Refugee   problem   is   a   global   problem.     A   successive  stream   of 

      humanitarian crisis has high lightened the plight of the victims, as 

      well as the threat, that large scale population movements pose to 

      regional security, stability and prosperity.  The Government of India 

      has seen the refugees problem from a broader prospective, derived 

      from its ancient cultural heritage.  Reminding the Indian ethos and 

      the humanitarian thrust, Justice V.R. Krishna Iyer former Judge of 

      the  Supreme  Court  of   India  had   given  a   message  as   Chairman, 

      ICHLAR in these words: ­



             "The   Indian   perception   is   informed   by   a   profound  
             regard   for   person­hood   and   a   deep   commitment   to  
             prevent   suffering.     Ancient   India's   cultural   vision   has  
             recognised   this   veneration   for   the   individual.     The  
             Manusmrithi   deals   elaborately   with   Dharma   even  
             amidst   the   clash   of   arms.     The   deeper   springs   of  
             humanitarian law distinguished the people of India by  
             the very fact that Dharma Yudha or the humanitarian  

FIR No.: 78/10.                                                     Page No. 13 of 49
              regulation   of   warfare,   is   in   the   very   blood   of   Indian  
             history.     Cosmic   compassion   and   ecological   empathy  
             flow   from   the   abundant   reservoir   of   Bud­dha's  
             teachings whose mission was the search for an end to  
             human sorrow or Dukha.  'Emperor Ashoka' renounced  
             war as he beheld slaughter in the battle­field.   In the  
             Mahabharatha and Ramayana the great epics of India,  
             we   find   inviolable   rules   of   ethics   and   kindness   to   be  
             observed  even by warring  rulers  in battle­fields.   One  
             may conclude that the Indian Constitution, in enacting  
             fundamental   duties   in   Article   51­a   has   cast   on   every  
             citizen   the   duty   to   promote   harmony   among   all   the  
             peoples of India, to have compassion for living creatures  
             and to develop humanism and abjure violence.   Thus,  
             humanitarian   legality   and   concern   for   refugee  
             status are writ large in the Indian ethos.  ... ... ..."


17.   Refugee protection not only has ancient roots but the principle of 

      protecting the "necessitous stranger" can also be found in virtually 

      all religions.



18.   It would be interesting to know that our neighbour Pakistan hosts 

      the maximum number of refugees in the world numbering to almost 

      2   million  followed  by   Syria   (1.5   million  refugees),  Iran   (9,63,500 

      refugees), Germany (5,78,900 refugees), Jordan (5,00,300 refugees) 

      and Tanzania (4,35,600 refugees) (Source: Encyclopedia of Human 

      Rights Vol. 4, Edited by: David P. Forsythe, Oxford University Press 

      Publications).



PRINCIPLE OF NON­REFOULEMENT



19.   Refoulement   refers   to   the   expulsion,   deportation,   removal, 



FIR No.: 78/10.                                                        Page No. 14 of 49
       extradition,   sending   back,  return  or   rejection  of   a   person  from   a 

      country to the frontiers of a territory where there exists a danger of 

      ill­treatment i.e. persecution, torture or inhuman treatment.



20.   Although, India is not a signatory to the United Nations Convention 

      On   Refugees  1951   and   its   Optional  Protocol   1967   and   has   not 

      ratified   it,   yet   it   would   be   apt   to   peruse   Article   33.1   of   the 

      Convention  which  contains  the   principle  of   non­refoulement,   and 

      the same is reproduced as hereunder: ­



             "No Contracting State shall expel or return ("refouler") a  
             refugee   in   any  manner   whatsoever  to   the   frontiers  of  
             territories   where   his   life   or   freedom   would   be  
             threatened on account of his race, religion, nationality,  
             membership   of   a   particular   social   group   or   political  
             opinion."


21.   Article 33.1 prohibits the refoulement of any refugee who has a 'well 

      founded  fear  of   persecution'   and  does  not   require  any   additional 

      demonstration that a threat is "more likely than not" to materialise 

      before the prohibition against returning a refugee to a place where 

      he fears persecution becomes operative.



22.   The refugee must be outside his or her country of origin and possess 

      a   well  founded  fear  of   persecution   and  this  persecution   must  be 

      based on one of the following 5 factors i.e. political opinion, religion, 

      race, nationality or membership of a particular social group.  The 4th 

      category i.e. nationality has been left undefined by the convention. 

      The UNHCR handbook attempts to fill this void: ­



FIR No.: 78/10.                                                       Page No. 15 of 49
              "The term 'nationality' is not to be understood only as  
             'citizenship'.   It refers also to membership of an ethnic  
             or  linguistic   group  and  may  occasionally  overlap  with  
             the term  'race'.    Persecution  for reasons  of nationality  
             may   consists   of   adverse   attitudes   and   measures  
             directed against a national (ethnic or linguistic) minority  
             and   in   certain   circumstances  the   fact   of   belonging   to  
             such a minority may in itself give rise to a well founded  
             fear   of   persecution."             (Source:   para   74, 
             http://www.unhcr.org/publ/PUBL/3d58e13b4.pdf).


23.   Apart   from   the   convention,   there   are   other   human   rights 

      instruments   to   which   India   is   a   party   State   that   proscribe 

      refoulement   and   influence   the   treatment   of   refugees,   principle 

      among   them   being  Convention  Against  Torture   and   Other  Cruel, 

      Inhuman   or   Degrading   Treatment   or   Punishment,   1984,   the 

      Genocide Convention, 1948, the International Covenant on Civil and 

      Political Rights, 1966, Convention on the Elimination of all Forms of 

      Discrimination  Against  Women,   1979,   International   Covenant   on 

      Economic   Social   and   Cultural  Rights,   1966,   Convention   on   the 

      Rights   of   Child,   1989   and   most   importantly   the   Universal 

      Declaration of Human Rights, 1948.



24.   It may not be out of context to reiterate India's reluctance to become 

      a   party   to   the   Convention  and  Protocol.    Merely  highlighting   the 

      Euro­Centric approach of these instruments is no longer sufficient 

      to deny to thousands of refugees in India a National Legislation in 

      order to protect their rights.  It is difficult to understand that India, 

      inspite   of   adopting   a   Constitution   which   was   entirely   western­

      centric/Euro­Centric and which was almost entirely influenced by 

FIR No.: 78/10.                                                     Page No. 16 of 49
       European and American traditions and concepts, would reject the 

      convention on refugees just a couple of years thereafter. Keeping in 

      mind the large influx, and presence of refugees on our soil, it is time 

      that India becomes a State Party to the aforesaid Convention. The 

      Hon'ble   Supreme   Court  has,   in   a   catena   of   verdicts   held   that 

      foreigners   shall   enjoy   the   same   fundamental   rights   as   those 

      available to citizens of India.



WELL FOUNDED FEAR OF PERSECUTION



25.   Counsel for convict had vehemently remonstrated that the convict 

      herein has a 'well founded fear of persecution' in the eventuality of 

      his deportation to Sri Lanka.   The following paras of the affidavit 

      filed by the convict echoes his perturbation: ­



             "4.     ...   ...   ...    If   I   deported   to   the   Sri   Lanka,   the   Sri  
             Lankan Army will put me in jail without any enquiry on  
             the   suspect   of   militancy/terrorism  they                    will   kill   me  
             and   it  is   also  very  important  to mention  herein  that  I  
             came  to India for the purpose  of only to save my life.  
             (sic)

             5.    ...   ...   ...     The   Hon'ble   Court   may   consider   the  
             present situation of Sri Lanka as per UN Panel report so  
             far 40,000   common  people  has  been killed  by the  Sri  
             Lankan   Army   and   there   is   no   hope,  no   guarantee   to  
             secure my life in Sri Lanka.  (sic)  ... ... ..."


26.   It was asserted that the Sinhalese are in a majority in Sri Lanka and 

      are   perpetrating   atrocities   against   the   Tamilian   minority.     The 

      convict has filed an affidavit in this regard alongwith a CD and the 


FIR No.: 78/10.                                                                Page No. 17 of 49
       latest  report   dated  31st  March   2011  of   the  United  Nations  titled 

      "Report of the Secretary­General's Panel of Experts on Accountability 

      in Sri Lanka".  An extract thereof at page no. 116 would be of utmost 

      relevance: ­



            "4.      Ongoing Violations by the Government

            428. Nearly Two years after the end of the fighting, the  
            root causes of the ethno­nationalist conflict between the  
            Sinhalese   and  Tamil   populations  of  Sri  Lanka   remain  
            largely   unaddressed   and   human   rights   violations  
            continue.  There are consistent reports of such activities,  
            some   committed   by   agents   of   the   State   or   state­
            sponsored   paramilitaries;   these   include   arbitrary  
            detention without trial, abductions and disappearances,  
            killings,   attacks   on   the   media   and   other   threatening  
            conduct.  ... ... ..."


27.   The convict has also filed a book titled "What Is To Be Done About 

      This" by Penny Cuic Publication Edited by J. Prabakaran which 

      contains  a   pictorial  representation   of   the  atrocities  committed  on 

      Tamilians in Sri Lanka.   The Court's attention has been invited to 

      the   following   excerpt  from   this   book   wherein  Mr.   Justice   V.R. 

      Krishna   Iyer,  former  Judge   of   the  Supreme  Court  of   India  has 

      penned down his anguish and pain in the following words: ­



            "The   pictures   in   the   book   sent   to   me   projects   the  
            horrendous injuries noxious by inflict.   The gory scene  
            when  presented  through  the photos  and  pictures  robs  
            my   sleep.     Can   man   even   be   so   beastly   with   little  
            babies,   raping   girls,   mutilating   men   and   women   and  
            massacre numbers?"



FIR No.: 78/10.                                                    Page No. 18 of 49
 28.   The book also quotes the words of the Nobel Peace Prize winner and 

      Nazi concentration camp survivor Professor Eile Wiesel: ­



             "The   Tamil   people   are   being   disenfranchised   and  
             victimized by the Sri Lankan authorities.  This injustice  
             must stop.  ... ... ..."


29.   There is no universally accepted definition of persecution.  However, 

      it   can   be   inferred   that   a   threat   to   life   or   freedom   constitutes 

      persecution.    Although,   it   is   common   to   think   of   persecution  in 

      terms   of   human   rights   violations   involving   imprisonment   or 

      violations of the physical integrity of the individual such as torture, 

      there is nothing in any definition that would restrict persecution in 

      this manner.  Protection against refoulement should also be granted 

      if the person is a member of a group against whom there exists a 

      pattern of persecution.



30.   The   problem  determining   the   nature   of   the   evidence  required  to 

      establish  a   'well   founded   fear   of   persecution'  remains,   i.e.   what 

      constitutes   a   'good   reason'   or   'well   founded   reason   to   fear 

      persecution',  and how does such evidence differ from that required 

      to establish a 'clear probability' that persecution will occur.



31.   One would argue that in order to enjoy complete protection and to 

      prevent  deportation,   the   refugee  would  have  to   establish  a   'clear 

      probability'   of   persecution   upon   return.     However,   in  INS   Vs. 

      Cardoza­Fonseca, 480 U.S. 421 (1987) it was held as under: ­




FIR No.: 78/10.                                                      Page No. 19 of 49
              "A   moderate   interpretation   of   the   'well   founded   fear'  
             standard   would   indicate   that   as   long   as   an   objective  
             situation is established by the evidence,  it need not be  
             shown   that   the   situation   will   probably   result   in  
             persecution,   but   it   is   enough   that   persecution   is   a  
             reasonable possibility." (emphasis mine)


32.   The UNHCR has commented: ­



             "A substantial body of jurisprudence has developed in  
             common law countries on what standard of proof is to  
             be applied is in asylum claims in order to establish well  
             foundedness.    This jurisprudence  largely supports  the  
             view   that   there   is   no   requirement   to   prove   well  
             foundedness   beyond   reasonable   doubt   or   even   that  
             persecution  is more  probable  than not.   To establish  
             'well   foundedness'  persecution  must  be  proved   to  
             be   reasonably   possible."    (Note   on   Burden   and 
             Standard   of   Proof   in   Refugee   Claims   para   no.   17, 
             December   16,   1998   available   at 
             http://www.unhcr.org/refworld/pdfid/3ae6b3338.pdf).


33.   Helene   Lambert   in   "Protection   Against   Refoulement   from 

      Europe:   Human   Rights   Law   Comes   to   the   Rescue",  Vol.   48 

      International   &   Comparative   Law   Quarterly   page   515  has 

      rightly   observed  that   the   existence  in   the   State   concerned  of   a 

      consistent  pattern   of   gross,  flagrant  or  mass  violations  of  human 

      rights   strengthens   the   findings   of   'substantial   grounds',   thus, 

      contributing to lowering the standard of proof.



34.   A 'well founded fear of persecution' also includes within its ambit 

      inter alia fear of being subject to torture.  India, being a signatory to 

      the   Convention   Against   Torture   and   Other   Cruel,   Inhuman   or 


FIR No.: 78/10.                                                     Page No. 20 of 49
       Degrading Treatment or Punishment, 1984, should ideally be bound 

      by   its   international   commitment   to   follow   the   principle  of   non­

      refoulement. Article 3 (1) of the Convention reads as under: ­



             "No State Party shall expel return (refouler) or extradite  
             a person to another State where there are substantial  
             grounds   for   believing   that   he   would   be   in   danger   of  
             being subjected to torture."


35.   In arriving at a conclusion that there are substantial grounds for 

      believing  that   the   individual  faces  a  danger  of  torture,  conditions 

      that may be taken into account would include criteria such as the 

      individual's ethnic background, his or her alleged political affiliation, 

      his or her history of past detention or torture.   In addition to the 

      specific  situation   of   every  case,  the   general  circumstances  of   the 

      country of  return should  also  be  considered.   Article 3  (2)  of the 

      aforesaid  Convention   would   be   relevant  in   this   regard   which   is 

      reproduced as hereunder: ­



             "For   the   purposes   of   determining   whether   there   are  
             such grounds, the competent authorities shall take into  
             account   all   relevant   considerations   including,   where  
             applicable,   the   existence   in   the   State   concerned   of   a  
             consistent pattern of gross, flagrant or mass violations  
             of human rights."


36.   A reading of the aforesaid provisions, decision and comments of the 

      Convention, Cardoza­Fonseca case and of the UNHCR respectively 

      coupled with the evidence filed by the convict has established the 

      fact   that   he   has   a   reasonable  fear   of   being   persecuted  in   the 

      eventuality of his deportation to Sri Lanka.

FIR No.: 78/10.                                                      Page No. 21 of 49
 PERSECUTION AND ARTICLE 21 OF THE INDIAN CONSTITUTION



37.   Notwithstanding the fact that India has neither signed nor ratified 

      the United Nations  Convention  on Refugees,  1951 or  its Optional 

      Protocol   relating  to   Status  of   Refugees,  1967   which   contain   the 

      principle of non­refoulement, yet the following deliberations would 

      make it abundantly explicit that this basic human right is implicit in 

      Article 21 of the Indian Constitution.



38.   Article 21 of the Constitution of India reads as under: ­



             "Article 21.  Protection of Life and Personal Liberty.

             No   person   shall   be   deprived   of   his   life   or   personal  
             liberty   except   according   to   procedure   established   by  
             law."


      Thus not mere animal existence but the right to live with dignity is 

      envisaged by the mandate of Article 21.



39.   Article   21   is   the   procedural  magna   carta  protective  of   life   and 

      liberty. The right to life within the meaning of Article 21 means the 

      right   to   live   with   human   dignity   and   the   same  does   not   merely 

      connote   drudgery.     It   takes   within  its   fold   some   finer   graces   of 

      human civilization, which makes life worth living.   The right to life 

      embraces  not   merely  physical  existence  but   the   quality  of   life  as 

      understood   in   its   richness   and   fullness   by   the   ambit   of   the 

      Constitution.


FIR No.: 78/10.                                                      Page No. 22 of 49
 40.   In  Louis De Raedt Vs. Union of India,  AIR 1991 SC 1887, the 

      Hon'ble Supreme Court has held that the right to life under Article 

      21 is available to citizens and non­citizens alike.  Further in NHRC 

      Vs. State of Arunachal  Pradesh,  1996 (1) SCC 742  it was held 

      that every person is entitled to equality before the law under 'equal 

      protection of laws' and that the State is bound to protect the life and 

      liberty of every human being, be he a citizen or otherwise.



41.   In  Francis   Coralie   Mullin   Vs   The   Administrator,   Union 

      Territory of India 1981 SCC (1) 608 it was observed that any form 

      of   torture   or   cruel,   inhuman   or   degrading   treatment   would   be 

      offensive to human dignity and constitute an inroad into this right to 

      life and it would be prohibited by Article 21.



42.   Simon   M.S.   Kagugube   has   aptly   concluded  his   article  'Cardoza­

      Fonseca  and  the  Well  Founded  Fear  of Persecution  Standard' 

      (ILSA   International   Law   Journal   Vol.   12   (1998)   pages   85   to 

      115) in the following words: ­



             "Persecution   constitutes   a   fundamental   challenge   to  
             basic   ideals   of   the   essential   dignity   of   the   human  
             person.  Whenever we fail to adequately respond to that  
             challenge,  more than just the immediate  well  being of  
             the   refugee   is   at   stake.     An   essential   part   of   the  
             humanity   of   the   rest   of   our   community   is   also  
             compromised.".


43.   It is no longer res integra that persecution is the effective denial 


FIR No.: 78/10.                                                      Page No. 23 of 49
       of an opportunity to pursue a dignified existence.  Right to live 

      with dignity  is  a  fundamental right  enshrined in the Constitution 

      and this principle has been upheld in a plethora of judgments of the 

      Hon'ble Supreme Court of India discussed herein above.



      Thus, it can be inferred that persecution jettisons the right to live 

      with dignity and is thus, violative of Article 21 of the Constitution of 

      India.



 CONSTITUTIONAL   VALIDITY   OF   THE   FOREIGNERS   ACT,   1946   AND  
 GOVERNMENT   ORDER    F.NO.
                                25019/3/97­F.III   DATED   2.7.1998  IN
                                                                          
 SO FAR AS IT DEALS WITH REFUGEES


44.   How a judge would interpret and apply constitutional tenets would 

      greatly depend on which philosophy of constitutional interpretation 

      he   believes   in.     This   Court   believes   in   adopting   the   liberal 

      interpretation  so   as   to   keep   the   faith   of   the   common   man   that 

      Courts are indeed the last bastion when it comes to protection of 

      fundamental rights.



45.   At the outset, it is hereby clarified that this Court, in no way intends 

      to transgress into the boundaries which are in the domain of the 

      higher Courts of the land.   But circumstances have arisen, which 

      make it imperative for the Court to consider the matter in the light of 

      judgments of the Hon'ble Supreme Court of India, and to have some 

      deliberations on this aspect.



      In  Hans   Muller   of   Nurenburg   Vs.   Superintendent,   Presidency 


FIR No.: 78/10.                                                    Page No. 24 of 49
       Jail, Calcutta & Others, 1955 AIR SC 367 a 5 Judge Bench of the 

      Hon'ble   Supreme   Court  discussed   the   constitutionality   of   the 

      Foreigners Act, 1946 and held it to be valid.  However, the issue that 

      was raised in front of the Hon'ble Supreme Court was with respect 

      to expulsion and extradition of a German foreigner  against whom a 

      warrant of arrest was issued in West Germany in connection with a 

      number of frauds.  However, the constitutional validity regarding the 

      inclusion of a refugee within the term 'foreigner' in the Foreigners 

      Act has hitherto not been raised nor addressed.



46.   The Foreigners Act defines a 'foreigner' as hereunder: ­



             "Section 2 (a) "foreigner"  means  a person who is not a  
             citizen of India."


47.   This all encompassing definition includes within its ambit 'refugees' 

      also.  However, it is common knowledge that a refugee is a distinct 

      category from that of a illegal migrant or a tourist, and thus should 

      be treated differently.   It has already been discussed that refugees 

      are victims of circumstances and their peculiar condition should be 

      understood in a humane way.  In this Court's perception, there has 

      been  no  reasonable  classification in  including   refugees within  the 

      strata   of   foreigners.     Subjecting   refugees,   illegal   migrants   and 

      tourists  to   a   similar  law  does  not   augur  well  for  the  mandate  of 

      Article 14 of the Constitution of India in as much as this act has not 

      made any reasonable classification of these categories of people and 

      has not applied the principle of intelligible differentia.  Moreover, the 

      fundamental principle of right to life has been completely overlooked 


FIR No.: 78/10.                                                  Page No. 25 of 49
       as   there   is   no   mention   of   exceptional   circumstances,   like 

      persecution under which a foreigner may not be refouled.  These two 

      aspects have hitherto not been brought to the notice of the Hon'ble 

      Supreme Court of India and as such, this Court felt the need to have 

      some deliberations on this.



48.   The categorisation of refugees in the strata of 'foreigners' and not 

      making   any   distinction   between   them   and   illegal   migrants   and 

      tourists,   deprives   the   refugees   of   the   privileges   under   myriad 

      international instruments.



49.   While  expounding the concept  of Article 14, the  Hon'ble  Supreme 

      Court  in  Harnam Singh Vs. Regional  Transport Authority,  AIR 

      1954   SC   190  held   that   equal   protection   of   laws   means   equal 

      subjection of all persons to the law and  amongst  equals, the law 

      shall be equal and equally and administered.   Can illegal migrants 

      and tourists be considered 'equal' to refugees?



50.   It is no longer res integra  that reasonable classification is inherent 

      in the very concept of equality and that: ­



      (i)    The   classification   must   be   founded   on   an   intelligible 

             differentia   which   distinguishes   persons   or   things   that   a 

             grouped together from others left out of the group, and;



      (ii)   The  differentia  must  have  a  reasonable  nexus  to  the  object 

             sought to be achieved by the statute.


FIR No.: 78/10.                                                 Page No. 26 of 49
 51.   There should be equality of treatment under equal circumstances.  It 

      is well settled that Article 14 of the Constitution will be violated not 

      only if equals are treated unequally, but also if unequals are treated 

      equally.



52.   In State of Andhra Pradesh Vs. Nalla Raja Reddy, AIR 1967 SC 

      1458 it was held that a statutory provision may offend Article 14 of 

      the Constitution both, by finding differences where there is none and 

      by making no difference when there is one.



53.   In   the   11   Judge   Constitutional   Bench   case   of  T.M.A.   Pai 

      Foundations   Vs.   State   of   Karnataka,   (2002)   8   SCC   481,   the 

      Hon'ble  Supreme   Court  observed  that   implicit  in   the   concept   of 

      equality  is   the   concept   that  persons   who   are   in   fact   unequally 

      circumstanced cannot be treated on par.



54.    The leitmotif discernible from the aforesaid judgments lead to the  

      irresistible inference that since refugees on one hand and tourists 

      and migrants on the other,  are distinct categories, the law which 

       treat them at par is  prima facie
                                         unconstitutional
                                                         .

The Constitutionality of the Act (and Government Order) can also be challenged as the right to live with dignity entrenched in Article 21 gets impinged when a person is subject to persecution, or he has a well founded fear of persecution. It is on these two counts that the constitutionality of Foreigners Act, 1946 and the Government Order FIR No.: 78/10. Page No. 27 of 49 F.No. 25019/3/97­F.III dated 2.7.1998 is assailable. However, since this Court does not possess the requisite competence to adjudicate upon this aspect, it would be inappropriate to expatiate on this topic any further.

THE JUS COGENS NATURE OF NON­REFOULEMENT

55. Jean Allain in his article 'The Jus Cogens Nature of Non­ Refoulement', 13 Int'l J. Refugee L. 533 (2001) has attempted to demonstrate that non­refoulement is a peremptory norm of international law. That is, it is a norm of jus cogens. No derogation from it is permissible. At page 538 of the article, the author has remarked: ­ "At present, it is clear that the norm prohibiting refoulement is part of the customary international law, thus, binding on all States, whether or not they are party to the 1951 Convention."

"... ... ... Perhaps the most important forum for identifying the value attributed to the norm of non­ refoulement is in the Conclusions adopted by the Executive Committee of the programme of the United Nations High Commissioner for Refugees (UNHCR). Such Conclusions reflect the consensus of States, acting in an advisory capacity where issues of protection and non­refoulement are addressed internationally. Their pronouncements carry a disproportionate weight in the formation of custom, as they are the States most specifically affected by issues related to non­ refoulement. ... ... ...
The first tentative mention of the norm of FIR No.: 78/10. Page No. 28 of 49 non­refoulement as jus cogens was broached by the Executive Committee in Conclusion No. 25 of 1982, where the States members determined that the principle of non­refoulement 'was progressively acquiring the character of a peremptory rule of international law'. (Executive Committee Conclusion No. 25, 'General Conclusion on International Protection', 1982: '(b) Reaffirmed the importance of the basic principles of international protection and in particular the principle of non­refoulement which was progressively acquiring the character of a peremptory rule of international law.') By the late 1980s, the Executive Committee concluded that 'all States' were bound to refrain from refoulement on the basis that such acts were 'contrary to fundamental prohibitions against these practices'. (Executive Committee Conclusion No. 55, 'General Conclusion on International Protection', 1989, '(d) Expressed deep concern that refugee protection is seriously jeopardized in some States by expulsion and refoulement of refugees or by measures which do not recognize the special situation of refugees and called on all States to refrain from taking such measures and in particular from returning or expelling refugees contrary to fundamental prohibitions against these practices.') Finally in 1996, the Executive Committee concluded that non­refoulement had acquired the level of a norm of jus cogens when it determined that the 'principle of non­refoulement is not subject to derogation'. (Executive Committee Conclusion 79, 'General Conclusion on International Protection,', 1996: '(i) Distressed at the widespread violations of the principle of non­refoulement and of the rights of refugees, in some cases resulting in loss of refugees lives, and seriously disturbed at reports indicating that large numbers of refugees and asylum­ seekers have been refouled and expelled in highly dangerous situations; recall that the principle of non­ refoulement is not subject to derogation.') As such, the member States of the Executive committee those -
FIR No.: 78/10. Page No. 29 of 49
States whose interests are most specifically affected by the safeguarding of international protection and prohibiting refoulement - concluded by consensus that the norm of non­refoulement was in fact a norm of jus cogens from 'which no derogation is permitted'."

56. India became a member of the Executive Committee of the High Commissioner's Programme (EXCOM) in 1995. The EXCOM is that of the organisation of the United Nations which approves and supervises material assistance programme of the UNHCR. Membership of EXCOM indicates particular interest and greater commitment towards redressal of refugee related matters. The principle of non­refoulement has found expression in various meetings of EXCOM where it has been unanimously reiterated that the fundamental humanitarian principle of non­refoulement is of such fundamental importance that this principle be observed 'both at the border and within the territory of the State' with respect to 'persons who may be subjected to persecution if returned to their country of origin irrespective of whether or not they have been formally recognised as refugees.'

57. This creates a paradoxical situation as India sits on the EXCOM and allows the UNHCR to operate on its territory, but refuses to sign the legal instrument that brought the organisation into existence.

58. It is not in dispute that the deliberations of the meetings of EXCOM are not binding on member States, however, time and again State parties and other countries attending the meetings of EXCOM have reiterated their commitment towards upholding the rights of FIR No.: 78/10. Page No. 30 of 49 refugees and have acceded to the fact that the principle of non­ refoulement is an essential part of the customary international law which ought to be followed in letter as well as in spirit by all States for whom human life is of paramount importance. Thus, it cannot be gainsaid that non­refoulement has assumed the character of a peremptory norm.

WHETHER INDIA IS BOUND BY THE CUSTOMARY INTERNATIONAL LAW OF NON­REFOULEMENT

59. An interesting question arises viz. to what extent can the provisions of international covenants/conventions be read into domestic law. Article 51 (c) of the Constitution of India casts a duty on the State to endeavour to "foster respect for international law and treaty obligations in the dealing of organised people with one another."

60. In Ktaer Abbas Habib Al Qutaifi & Others Vs. Union of India & Others, 1999 Cri LJ 919, the Hon'ble High Court of Gujrat dealt in extenso this aspect and from the conspectus of facts discussed therein, laid down inter alia the following principles for enforcement of humanitarian law: ­ "4. The international covenants and treaties which effectuate the fundamental rights guaranteed in our Constitution can be relied upon by the Courts as facets of those fundamental rights, and can be enforced as such."

"6. The principle of 'non­refoulement' is FIR No.: 78/10. Page No. 31 of 49 encompassed Article 21 of the Constitution of India and the protection is available, so long as the presence of the refugee is not prejudicial to the national security." and "8. Where no construction of the domestic law is possible, Courts can give affect to international conventions and treaties by a harmonious construction."

61. In this case the Hon'ble High Court stayed the deportation to Iraq of two Iraqi nationals against whom a case u/s 309 of the IPC was registered and who were let off after a days imprisonment. They had remonstrated before the Court not to return them as they feared they would be persecuted in their country of origin. The Court invoked the principle of non­refoulement which is part of the customary international law, and stayed their deportation.

62. In Ms. Zothansangpuii Vs. State of Manipur, Civil Rule No. 981 of 1989 Order dated 20.9.1989, the petitioner was convicted on her plea of guilt under the Foreigners Act as well as the Passport Act. The convict contended before the Court that she had a reasonable apprehension that she would be persecuted as a result of terror let loose by the military authority in Burma. Although, the judgment of Hon'ble Guwahati High Court has not explicitly mentioned or elaborated upon the principle of non­refoulement, yet it can be inferred that these principles were considered by the Judges when they ordered a stay on deportation.

63. In Malvika Karlekar Vs. Union of India, Crl. WP No. 243 of FIR No.: 78/10. Page No. 32 of 49 1988, Hon'ble Supreme Court stayed the deportation of Burmese refugees.

64. In Ktaer Abbas Habib (supra) the Hon'ble High Court of Gujrat quoted an excerpt from "The Refugees in International Law" written by S. Goodwin Gill, which is reproduced as hereunder: ­ "The evidence relating to the meaning and scope of non­ refoulement in its treaty sence (sic) also amply supports the conclusion that today the principle forms part of general international law. There is substantial, if not conclusive, authority that the principle is binding on all States, independently of specific assent."

65. In Vishakha Vs. State of Rajasthan, 1997 (6) SCC 241 it was held that "(14). ... ... ... It is now an accepted rule of judicial construction that regard must be had to international conventions and norms for construing domestic law when there is no inconsistency between them and there is a void in the domestic law. ... ... ..."

66. The Hon'ble Supreme Court in this case observed that in the absence of legislative measures, there is a need to find an effective alternative mechanism to fulfill the felt and urgent need of protecting women from sexual harassment at the work place. Invoking provisions of Article 51 (c), Article 253 and perusing Entry 14 of List I of the 7th Schedule to the Constitution of India, the Court held that "(7) In the absence of domestic law occupying the field, to formulate FIR No.: 78/10. Page No. 33 of 49 effective measures to check the evil of sexual harassment of working women at all workplaces, the contents of international conventions and norms are significant for the interpretation of the guarantee of gender equality, right to work with human dignity in Articles 14, 15, 19 (I) (g) and 21 of the Constitution and the safeguards against sexual harassment implicit therein. Any international convention not inconsistent with the fundamental rights and in harmony with its spirit must be read into these provisions to enlarge the meaning and content thereof, to promote the object of the constitutional guarantee. ... ... ..."

67. The Hon'ble Supreme Court had further quoted in para no. 11 from the Beijing Statement of Principles of the Independence of the Judiciary in the LAWASIA region wherein the objectives of Judiciary inter alia are "(a) To ensure that all person are able to live securely under the rule of law. ... ... ..." Basically, there should be no reason why international conventions and norms cannot be used for construing the fundamental rights expressly guaranteed in the Constitution of India which embody the basic concept of the equality in all spheres of human activity.

68. In Zambia, a similar issue was discussed by a UNHCR Senior Protection Officer, Karolina Lindholm Billing who had, while making submissions on the Revised Immigration and Deportation Bill, 2010 to the parliamentary committee on national security and foreign affairs, stated that there should be an inclusion of an effective remedy against the expulsion or deportation order which would FIR No.: 78/10. Page No. 34 of 49 allow asylum seekers and refugees to challenge deportation orders in the Court of law. (http://www.postzambia.com/post­ read_article/php?articleId=6943) Section 33 of the Penal Code of Zambia was discussed, which makes deportation compulsory in case of foreigners in general "upon conviction of any offence, except minor traffic offences". This provision, according to her was not in line with the spirit of the United Nation Convention of Refugees, 1951 and its Optional Protocol, 1957 which requires deportation to be ordered only when the crime is sufficiently grave in nature. The presence of the foreigner should raise a reasonable apprehension that the security of the country would be jeopardized.

69. A similar analogy is sought to be drawn in the present matter as, in this Court's perception traveling on a forged document cannot be so severe a crime that can be equated with more heinous acts like sedition, murder, rape, dacoity or other offences which may affect the integrity of our country.

70. In the matter of Gurunanthan & Others Vs. Government of India, Writ Petition No. 6708 of 1992 order dated 27.3.1994 the Hon'ble High Court of Madras expressed its unwillingness to let any Sri Lankan refugee to be forced to return to Sri Lanka against his will. In Gurunanthan's case the repatriation process was stayed as it was not voluntary. It was held that when there was an international organisation to ascertain the voluntariness of consent it is not for the Court to decide whether the consent was voluntary or not. It also directed the Government to transmit this order in Tamil to the FIR No.: 78/10. Page No. 35 of 49 camps as well as an order that the refugees will not be sent back against their will.

71. India is a signatory to the Convention on the Prevention and Punishment of the Crime of Genocide and ratified it on 27.08.1959.This Convention bans acts committed with the intent to destroy, in whole or in part, a national ethnic, racial or religious group. It declares genocide a crime under international law whether committed during war or peacetime and binds all signatories of the convention to prevent genocide. By deporting the convict herein, there is every apprehension that he will become a victim of genocide, and thus the State of India would have failed to live up to its commitment of preventing genocide under the convention.

72. India signed the Convention against Torture and Other Cruel, inhuman or Degrading Treatment or Punishment on 14.10.1997. It forbids countries to return a refugee to his country if there is a reason to believe that he or she will be tortured, and requires host countries to consider the human rights record of the person's native country in making this decision. The evidence brought on record paints a poor picture of the treatment of Sri Lankan Tamils in Sri Lanka. Thus, it would be against the spirit and letter of the Convention to refoule the convict herein when his human rights are likely to be jeopardized.

73. India became a signatory to the Convention Against Torture on 14.10.1997 but has yet not ratified it. Even though the implications FIR No.: 78/10. Page No. 36 of 49 of signing and ratifying a treaty vastly differ, yet being a signatory to an instrument imposes upon the Contracting State certain obligations. It is common knowledge that a State does not express its consent to be bound by a treaty unless it ratifies it. However, the State that signs a treaty is obliged to refrain in good faith, from acts that would defeat the object and purpose of the treaty. The concomitant analogy that can be deciphered from the aforesaid philosophy is that India should refrain from refouling a hapless refugee who has a reasonable fear of being subject to torture due to his return to his country origin.

74. In view of the foregoing discussion, this Court holds that the principle of non­refoulement is a part of customary international law, and binds India, irrespective of whether it has signed the convention on refugees or not in as much as it is a party to other Conventions which contain the principle of non­refoulement. URGENT NEED FOR A NATIONAL LEGISLATION WHICH STRESSES UPON THE ASPECT OF NON­REFOULEMENT AND LAYS DOWN PROVISIONS WITH RESPECT THERETO.

75. This part of the order of the Court draws upon a thoroughly researched article titled 'Creating Legal Space for Refugees in India: The Milestones Crossed and the Roadmap for the Future' written by a Senior IAS Officer Sh. Prabodh Saxena, Joint Secretary, Department of Economic Affairs, Ministry of Finance, Government of India published in International Journal of Refugee Law, June 18, 2007. The officer has challenged set dogmas and has FIR No.: 78/10. Page No. 37 of 49 stressed the need to have in place a legislation which would cater to the needs of thousands of victims of circumstances. Even the NHRC and Law Commission of India have, in their successive reports, stressed the need for a national legislation on refugees.

76. The need for enaction of a comprehensive legislation to deal exclusively with the problems of refugees has arisen since time immemorial, and finally, pursuant to extensive deliberations a Model National Law: The Refugee and Asylum Seekers (Protection) Bill, 2006 had been drafted. The process was initiated at the Third South Asian Informal Regional Consultation on Refugee Migratory Movements, where a 5 member working group was constituted to draft a model refugee protection law for the South Asia Region. The first draft of this proposed law was present at the 1997 SAARC Law Seminar in New Delhi, modified and then adopted by the 4th Annual Meeting of the Regional Consultation at Dhaka, Bangladesh in 1997. The Refugee and Asylum Seekers (Protection) Bill, 2006 has drawn its fundamentals from the Convention on Refugees, 1951, the Optional Protocol, 1967, the Organization of African Unity Convention Governing the Specific Aspects of Refugees Problem in Africa, 1969 (OAU Convention), the Cartagena Declaration on Refugees, 1984 and the Bangkok Principles. It has also benefited from various conclusions of the EXCOM on different aspects of refugee protection.

77. Presently, the refugees are dealt under the Foreigners Act, 1946 and the rules framed thereunder. Refugees are treated as foreigners FIR No.: 78/10. Page No. 38 of 49 under the extant laws of our country. However, it would be extremely important to understand that a refugee cannot be placed the same platform on which illegal migrants, tourists and other 'foreigners' are placed. Tourists and illegal migrants come on their own volition in search of better livelihood or pleasure related purposes whereas refugees are victims of circumstances and have been compelled to leave their country of origin. The categorisation of refugees in the strata of 'foreigners' and not making any distinction between them and illegal migrants and tourists, deprives the refugees of the privileges available to them under the Geneva Convention and other Conventions and treaties.

78. It is unfortunate that in spite of having an impressive record of welcoming refugees, we do not have a national law in place in order to cater to the specific needs of this class. An important distinction needs to be made between persons who, on their own volition and in order to earn a livelihood or to explore the world, reach the shores of another country on one hand, and between a refugee who, under compulsion and duress, has no option but to take shelter in another country. They are a victim of circumstances. They do not throng the shores of another country for any pleasure or for any kind of economic gain. They take chances as they do not have choices.

79. The drafting of the Refugee And Asylum Seekers (Protection) Bill, 2006 was a welcome step in this direction. It is unfortunate that despite it been enacted after due deliberations and after various FIR No.: 78/10. Page No. 39 of 49 rounds of consultations, by eminent jurists including the Former Chief Justice of India Sh. P.N. Bhagwati, this Bill has not seen the light of the day. A perusal of some of the provisions would make it clear that if this Bill would have been enacted, it would have gone long way in securing certain rights for the refugees. The preamble to the Bill addresses the need for protection of refugees as is explicit from the following lines: ­ "To provide for the establishment of an effective system to protect refugees ... ... ... and, by providing necessary social and economic protection both before and after the date of asylum."

80. Further, a bare perusal of the following lines of the preamble would reveal the humane facet which is expected to be inculcated in our legislation: ­ "WHEREAS, the Constitution requires treating all persons in a fair and just manner consistent with the guarantees of equality fairness and due process of law;

AND WHEREAS, India has a long tradition and experience of dealing with refugees in a responsible and humane way;

AND WHEREAS, India has acceded to all major international human rights instruments and respects international law and human rights norms including the principle of non­refoulement;

AND WHEREAS, India recognises the rights of Refugees And Asylum Seekers to live a dignified life free from FIR No.: 78/10. Page No. 40 of 49 persecution." (emphasis mine).

81. It would be apposite to peruse the following provisions of this Bill in order to understand the significance and ramifications of its enactment. Chapter 2 of this Bill has defined the term 'refugee': ­ "4. Persons who are refugees. ­ Subject to the provisions of this Act, a refugee is a person who,

(a) is outside his country of origin and is unable or unwilling to return to, or is unable to unwilling to avail himself of the protection of, that country because of a well­founded fear of persecution on account of race, religion, sex, nationality, ethnic identity, membership of a particular social group or political opinion; or

(b) owing to external aggression, occupation, foreign domination, serious violations of human rights or other events seriously disrupting public order in either a part or whole of his country of origin, is compelled to leave his place of habitual residence in order to seek refuge in another place outside his country of origin:

... ... ..."
The convict herein has established such a well founded fear of persecution.
82. Most importantly Section 7 of this Bill would make it explicit that a refugee who senses a fear of persecution ought not to be expelled/deported/removed/refouled to the country from where such fear arises. Section 7 of this Bill is reproduced as hereunder: ­ FIR No.: 78/10. Page No. 41 of 49 "7. General prohibition against refusal of entry, expulsion, extradition, deportation, return etc. and provisions for removal from India. ­ (1) Notwithstanding anything contained in this Act or any other law for the time being in force, no person may be refused entry into India, expelled, extradited, deported or returned to any other country or be subject to any similar measure if, as a result of such refusal, expulsion, extradition, deportation, return or other measure, such person is compelled to return to or remain in a country where: ­
(a) he may be subjected to persecution on account of race, religion, sex, nationality, ethnic identity, membership of a particular social group or political opinion, or,
(b) his life, physical safety or freedom would be threatened on account of external aggression, occupation, foreign domination, serious violations of human rights or other events seriously disrupting public order in either part or whole of that country.

(2) Subject to sub­section (1) of this section, a refugee or asylum seeker may be removed from India only if,

(a) he has been convicted by a final judgment of a crime against peace, a war crime or a crime against humanity and constitutes a danger to the community; or ... ... ..."

The non­obstante clause in Section 7 would have overridden the provisions of the Foreigners Act, 1946 and the Government Order. Had the Bill been enacted, the convict refugee herein would not have been deported.

FIR No.: 78/10. Page No. 42 of 49

83. There have been a plethora of instances wherein the Indian Courts have tried to evolve a humane and compassionate approach to redress individual problems, however, in the absence of a long term, consistent and uniform solution by the way of enactment of a national legislation, their treatment would be subject to, and would depend upon the individual outlook, social inclinations and other idiosyncrasies which would make it difficult for the subordinates courts to follow. India needs to live up to its humanitarian goals. The need for a refugee law is immediate. The uniform treatment of refugees is a must as long as India continues to accept asylum seekers across its porous borders.

CONVICTION AND SENTENCE: AFTER TRIAL VS. AFTER PLEA BARGAINING

84. The Foreigners Act, 1946 was enacted before India attained her independence whereas the benevolent provisions of plea bargaining were incorporated in 2006 in the Code of Criminal Procedure, 1973 vide an amendment in 2006. The legislature could not have foreseen that one day our country would emulate the West and introduce plea bargaining in our laws. The very basis of ushering this concept was to reduce the tremendous backlog under which our judiciary is reeling. In case an accused pleads guilty to the commission of an offence, his sentence is reduced significantly if he opts to avail the benefit of Chapter XXI­A of the CrPC. It is this ingenuity in the law that the accused willingly admit their guilt in order to avoid a long drawn out legal battle and to receive a swift FIR No.: 78/10. Page No. 43 of 49 sentence which may necessarily not result in imprisonment.

85. It has been observed that persons committing the offences for which the accused has been charged with and convicted for, suffer a sentence of imprisonment for a period already undergone in judicial custody, and imposition of some fine. The average period of detention usually varies from 15 to 20 days. It is pertinent to note that the convict herein has already been incarcerated for close to 6 months. The fact that he has already spent a long time behind bars while awaiting trial needs to be considered while sentencing him.

86. A question comes to one's mind is that: should the convict be punished twice over, for his offence? Should he be penalized by the Court and by the Government also? If that be so, the convict would not have approached the Court to plead guilty to his offence rather he would have faced the trial, which would inevitably go on for another few years. By that time, the conditions in his country would have ameliorated and his return would not have posed a risk to his life. Had the convict known that he would be deported pursuant to entering a plea of guilt, he probably would have not preferred a plea bargain.

87. It has already been laid down by the Hon'ble Supreme Court in Louis De Raedt (supra) that Indian and non­citizens are to be treated equally as far as Article 21 is concerned. Would it be fair to deport an already incarcerated individual? Doesn't it appeal to one's conscience that the convict had already spent 6 months in prison FIR No.: 78/10. Page No. 44 of 49 and that further deporting him would be nothing short of prolonging and continuing his agony? The very idea of deporting the convict herein to his country of origin where he has a well founded fear of persecution would not be in consonance with the principles of natural justice.

88. There has to be a discernible distinction between sentencing an individual after a protracted and contested trial on one hand, and sentencing him after he has entered his plea of guilt. The punishment meted out cannot be the same under both circumstances. Even the legislature had this distinction in mind whilst amending the CrPC and introducing the concept of plea bargaining. Since the convict has pleaded guilty on his own volition, an order on deportation should not form a part of the order on sentence.

FINAL ORDER:

89. When the substance of justice cannot be secured by 'legal justice', in order to achieve this solemn purpose 'natural justice' is to be called in aid of 'legal justice'. Natural justice relieves legal justice from unnecessary technicality, grammatical pedantry or logical prevarication. It supplies the omissions of a formulated law and helps fill the void therein. Natural justice principles are ingrained into the conscience of man. Natural justice is the administration of justice in a commonsense liberal way. The administration of justice is to be freed from the narrow and restricted considerations which FIR No.: 78/10. Page No. 45 of 49 are usually associated with a formulated law involving linguistic technicalities and grammatical niceties. It is substance of justice which has to determine its from.

90. S. Augender in "Questioning the Universality of Human Rights"

published in (1 & 2) Indian Sociological Journal (2002) at page 80 has given an all­encompassing definition of Human Rights: ­ "A human right is a universal moral right, something which all men, everywhere, at all times ought to have, something of which no one may be deprived without a grave affront to justice, something which is owing to every human simply because he is a human."

The right against refoulement is an important facet of 'human rights'. The convict has a right against non­refoulement as this right is owed to him simply because he is a human.

91. How can the Court become a party to the persecution of an individual? The Court can not retrograde itself to the position of a mute spectator. It is high time that this Bill (or another one drafted in similar lines) sees the light of the day and becomes a living document by being enacted. By doing so, lives of thousands of refugees in our country can be affected for their betterment, in as much as valuable rights can be conferred. Our commitment to adherence to international law can be fulfilled if we enact this law. The principle of non­refoulement is a cornerstone of basic human rights. By handing over a person to a nation where he fears persecution, would make us nothing short of abettors in that FIR No.: 78/10. Page No. 46 of 49 persecution.

92. This Court is aware that this ex aequo et bono order seeks to fill the casus omissus left by the legislature, but it derives inspiration from the following famous words of Retd. Hon'ble Justice Sh. P.N. Bhagwati spoken at a Common Wealth Conference on "Judicial Interpretation in Constitutional Law" by which he succinctly defined the role of, and expectations from a judge: ­ "I do not agree with the conventional view which has long held the field in common law countries that judges merely declare the law, they are simply living oracles of law; they no longer make or invent law. Law making is an inherent and inevitable part of the judicial process. Even where a judge is concerned with the interpretation of a statute, there is ample scope for him to develop and mould the law. It is he who infuses life and blood into the dry skeleton provided by the legislature and creates a living organism appropriate and adequate to meet the needs of the society and thus by making and moulding the law, he takes part in the work of creation."

93. On concluding, this Court is reminded of the following verses from the poem 'Refugee Blues' by W.H. Auden whereby he has captured the emotions that a refugee experiences: ­ Say this city has a million souls, Some live in mansions, some live in holes:

Yet there is no place for us, My dear, there is no place for us, FIR No.: 78/10. Page No. 47 of 49 Once we had a country and we thought it fair, Look in the atlas and you will find it there:
We cannot go there now, My dear, we cannot go there now.

94. The convict has been living in a refugee camp since the last 20 years and is dependent upon grants given by the Government. He has no independent source of income. The subsistence allowance doled out to him is just sufficient enough to make two ends meet. In these circumstances, levying of fine would be harsh upon him and thus, the convict is hereby sentenced to imprisonment already undergone.

95. The convict herein has already been incarcerated for a period of approximately 6 months. He has a family comprising of his wife and 2 young sons. If this Court accedes to the plea of the Ld. APP, then it would tantamount to irreversible fragmentation of this refugee family. Breaking a family unit forever was never in the contemplation of the laws of our land. Keeping this factor in mind coupled with the reasons hereinabove discussed in extenso, this Court orders that Chandra Kumar convict herein shall not be deported. He is directed to report back to the Tahsildar, Sri Lankan Refugee Camp, 62, Gummidipoonidi Taluk, Thiruvallur District, Tamil Nadu forthwith.

96. Copy of this order be sent to the Secretary, Legislative Department, Ministry of Law and Justice, Government of India to table a copy of the Refugee and Asylum Seekers (Protection) Bill, 2006 before the Parliament.

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97. Copy of this order be furnished to the Ld. Public Prosecutor.

98. Copy of this order be also given to the convict as prayed for.

99. Copy of this order be also provided to the DCP, FRRO.

100. Copy of this order be also sent to the Tahsildar, Sri Lankan Refugee Camp, 62, Gummidipoonidi Taluk, Thiruvallur District, Tamil Nadu­ 601201.

Announced in the open Court on 20.9.2011.

(ARUL VARMA) METROPOLITAN MAGISTRATE (SPECIAL COURT­2), ROOM NO. 210, DWARKA COURTS, NEW DELHI.

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