2/13/25, 2:40 AM Constitutional Provision Regarding Refugee Law in India - International Journal of Law Management & Humanities

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Constitutional Provision Regarding

Refugee Law in India

Harshit Rai and Vaibhav Dwivedi Show Author Details

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Abstract

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2/13/25, 2:40 AM Constitutional Provision Regarding Refugee Law in India - International Journal of Law Management & Humanities

India is home to many refugees. Whenever India is faced with

humanitarian crisis of dealing with refugees it has done as any
mature democratic republic would do. It has tried to balance the
national security issue with that of the need of asylum seekers.
However, the lack of domestic laws makes the administrative action
subject to suspicion and high handedness. The threat of terrorist
attacks as seen in recent past makes the Government cautious of
drafting laws which may limit its power to protect its own people.
Not becoming party to the Convention on Status of Refugees, 1951
and its 1967 Protocol is not the solution to the problem. India needs
to revisit its policy on refugees and have municipal laws.

Keywords

Asylum Terrorism Refugee Convention Protocol

Citizenship

Type
Research Paper

Information
International Journal of Law Management and Humanities, Volume 4, Issue 3,
Page 261 - 272
DOI: https://doij.org/10.10000/IJLMH.11446

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This is an Open Access article, distributed under the terms of the Creative Commons
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building upon the work for non-commercial use, provided the original work is properly cited.

Copyright
Copyright © IJLMH 2021

I. Introduction

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Human Rights of Refugees are one of the major problems of the

world. According to Article 1 of United Nations Convention on
Status of Refugees, refugees are those who are “owing to a well-
founded fear of being persecuted for reasons of race, religion,
nationality, membership of a particular social group, or political
opinion, is outside the country of his nationality, and is unable to or,
owing to such fear, is unwilling to avail himself of the protection of
that country.” India has one of the largest refugee population in the
world. Regardless of the fact that India serves to the diverse group of
refugees, example: – Syrians, Afghans, Palestinians, Persians,
Ethiopians and Christians, etc., the country does not have specific
domestic laws and policies for the refugees. Although India is not
the party to the 1951 Refugee Convention or its 1967 protocol, even
do not have a national refugee protection framework, but still, it
continues to give asylums to refugees of the neighbouring countries.
Asylum seekers can get the refugee status from UNHCR if the status
is not protected by the Indian Government. According to the
Universal Declaration of Human Rights (UDHR) States have a duty
to protect the inherent dignity and worth and dignity of every
human being thereby including those of refugees and asylum
seekers. The principle of non-refoulement also ensures that lives of
asylum seekers are not put in danger by pushing them back into
countries where they face persecution. Even States which are not
signatory to the conventions are not outside the purview of the
mandate to fulfil the basic rights of refugees as these rights have
acquired customary nature. There has been development of refugee
jurisprudence wherein not only the rights of political refugees are to
be protected of refugees covered under Convention of 1951 but even
those who are forced to leave on other grounds like economic
deprivation. This is due to the development of protection of
economic social and cultural rights as part of human rights first
under Universal Declaration of Human Rights 1948 (UDHR)
followed by enforceable conventions under International Covenant
on Economic Social and Cultural Rights (ICESC). Originally ICESC
was not considered binding and it was according to the capacity of
the States that the provision required to be enforced. However,
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Human Rights interpretation tends to include Economic Social and

Cultural rights along with civil and political rights. States today
cannot refuse equal rights to all groups based on economic or social
limitation of States. India has followed a liberal policy of
humanitarian protection of refugees and asylum seekers. It is home
to several groups of people who have come here and made it their
home. However, the absence of a refugee specific legislation can be
attributed to India’s volatile situation in South Asian politics and the
threat of terrorism faced by it. Even in such absence of a specific
law, India has addressed the needs of refugees who have fled from
their home country into its territory.

II. Refugees
The term ‘Refugee’ has a particular meaning in international law
and its legal definition is laid down in the United Nations 1951
Convention relating to the Status of Refugees (to be referred to as
“1951Convention”) and its 1967 Protocol. Article 1 para. 2 of the 1951
Convention defines the ‘refugee’ as “A person who owing to well-
founded fear of being persecuted for reasons of race, religion,
nationality, membership of a particular social group or political
opinion, is outside the country of his nationality and is unable or,
owing to such fear, unwilling to avail himself of the protection of
that country.” It should be appreciated that a person becomes a
refugee because of circumstances which are beyond that person’s
control, often poignant. He/she is left with no other option but to
flee from human rights violations, socio-economic and political
insecurity, generalised violence, civil war or ethnic strife all these
leading to fear of persecution. Thus, it may be noted that there are
well-defined and specific grounds, which have to be satisfied before
a person can qualify to be a ‘refugee’. These grounds are well-
founded on fear of persecution and considerations of a number of
factors which may operate individually or collectively.

Refugees are considered under the term ‘alien’ in India. The term
appears in Constitution of India (Article 22), Section 83 of the

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Indian Civil Procedure Code, Section 3(2)(b) of the Indian

Citizenship Act, 1955, as well as some other statutes.

III. History of Refugees

Asylum seekers are existing from many years, the early man used
to migrate for finding food, shelter and other resources. Around AD
600, the right to seek asylum in a holy place or a church was
codified in law by King Ethelbert of Kent. Many such laws were
rising around Europe during the Medieval Period which was the
th
start of such provisions. But it was the 18 century when it was
required for people to show id verification to cross borders in many
countries. The biggest Refugee crises occurred during the World
Wars. The first world war lasted almost 4 years. One million
refugees of Belgium went to the Netherlands and there on
transferred to the UK and other countries. France, Germany was
also the worst affected. When Russia attacked Prussia, 870000
fled. World War 2 was one such war which never happened in the
history of the world. By 1959 some 900,000 European refugees
were taken by European countries. And 461,000 had been accepted
by the USA, and 523,000 by other countries. World War 2 caused
around 60,000,000 refugees in Europe itself.

(A) History of Refugees in India

Pre-Independence

India is one of the few countries to experience the refugee situation

in the last half century. Indian history is evident by large-scale
migration of people from different countries. These migrations had
taken place in 2 ways: “Hindukush Mountains in the West and the
Patkoi range in the East”.

Post-Independence

the first twenty-five years of India was spent on accepting the

responsibility of 20 million refugees. This was due to the partition of
India and Pakistan. As a result, India had to confront a task by
providing relief to the displaced persons from West Pakistan. “At the
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initial stage, 160 relief camps were organized and the total
expenditure incurred was Rs. 60 crores approximately.” There
were many steps taken by the government of India to overcome with
the refugee problem. The most important step that had been passed
by the government was the Rehabilitation Financial Administration
Act, 1948. A Huge number were displaced from India to Pakistan
and vice versa and the problem was much similar to Refugees.
Another instance was in 1959 when Dalai Lama and his followers
approached India as refugees and India provided them a Political
Asylum. The year of 1971 saw many refugees travelling from East
Pakistan to India. In 1983 and 1986 India had refugees coming in
from Sri Lanka and Bangladesh respectively. At the end of 1992,
India has hosted 2,000,000 migrants and 237,000 displaced
persons. India always has some or the other Refugees coming in
throughout its history.

IV. Status of refugees in india

A brief look at the refugee scenario in India will help appreciate in
the proper perspective, the complexities of law enforcement in a
variety of situations impinging upon the refugees. India has been
home to refugees for centuries. From the time when almost the
entire Zoroastrian community took refuge in India fleeing from the
persecution they were then subjected to on religious grounds in
Iran, India has, from time to time continued to receive a large
number of refugees from different countries, not necessarily from
the neighbouring countries alone. The most significant thing which
deserves to be taken note of is that, there has not been a single
occasion of any refugee originating from the Indian soil except the
transboundary movement of the people during the partition of the
country in 1947. On the other hand, it has invariably been a
receiving country and in the process, enlarging its multi-cultural and
multi-ethnic fabric. In keeping with its secular policies, India has
been the home to refugees belonging to all religions and sects. It is
relevant to point out that since its independence India has received
refugees not only from some of its neighbouring countries but

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distant countries like Afghanistan, Iran, Iraq, Somalia, Sudan and

Uganda.

V. India status on religious

refugees
Afghanistan

Currently, there are around 8,000 to 11,684 Afghan refugees in

India, most of whom are Hindus and Sikhs. The Indian government
has allowed the United Nations High Commissioner for Refugees
(UNHCR) in India to operate a programme for them. In 2015, the
Indian government granted citizenship to 4,300 Hindu and Sikh
refugees. Most were from Afghanistan, and some were from
Pakistan.

Bangladesh

Many people from East Bengal, mainly Hindus, migrated to West

Bengal during the partition of India in 1947. The native population
of West Bengal sometimes referred to these refugees as “Bengal’s”.
From 1947 to 1961, the percentage of the population of East Bengal
that was Hindu decreased from 30% to 19%. In 1991, it was down
to 10.5% The percentage further decreased from 2001, where the
census recorded it to be 9.2%, to 2008, when it was estimated to be
8%.

Chakmas are a Bangladeshi Buddhist community. Chakma

immigrants from Bangladesh have settled in the southern part of
Mizoram because they were displaced by the construction of the
Kaptai Dam on the Karnaphuli River in 1962. Because there was no
rehabilitation or compensation, they fled from Bangladesh to
India.

In 2001, the BBC reported that many Bangladeshi Hindu families

had entered India to escape repression in Bangladesh because they
were members of minority religious groups.

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Pakistan

Partition of India

Following the partition of India, massive population exchanges

occurred between the two newly formed nations, spanning several
months. Once the borders between India and Pakistan were
established, a total of about 14.5 million people migrated from one
country to the other, seeking safety from being an adherent to the
religion of the majority in their new country. Based on the 1951
census, immediately after the partition 7.226 million Muslims
migrated from India to Pakistan, while 7.249 million Hindus and
Sikhs moved from Pakistan to India. About 11.2 million migrants
crossed the western border, making up 78% of the total migrant
population. Most of them travelled through Punjab. 5.3 million
Muslims moved from India to West Punjab in Pakistan, and 3.4
million Hindus and Sikhs moved from Pakistan to East Punjab in
India. Elsewhere in the west, 1.2 million moved in each direction to
and from Sind. The initial population transfer on the east involved
3.5 million Hindus moving from East Bengal to India and only 0.7
million Muslims moving the other way.

Recent arrivals

Non-Muslims face constitutional and legal discrimination in

Pakistan. Consequently, Hindus and Sikhs from Pakistan have
sought asylum in India; many have arrived in the 21st century.
There are almost 400 Pakistani Hindu refugees in Indian cities.

Tibet

Many religious refugees come from Tibet. The 14th Dalai Lama, a
leader of the Tibetan migration movement, left Tibet for India after
the 1959 Tibetan uprising. He was followed by about 80,000
Tibetan refugees. Prime Minister Jawaharlal Nehru agreed to
allow Tibetan refugees to settle in India until their eventual return
to Tibet. The Tibetan diaspora maintains the Central Tibetan
Administration, a government-in-exile, in McLeod Ganj, a suburb

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of Dharamshala, Kangra district, Himachal Pradesh. The

organisation coordinates political activities for Tibetans in India.

In 1960, the government of Mysore State (now Karnataka) allotted

nearly 3,000 acres (12 km2) of land at Bylakuppe in Mysore
district. In 1961, Lugsung Samdupling, the first Tibetan exile
settlement in India, was formed. A few years later, another
settlement, Tibetan Dickey Larsoe (TDL), was established. Three
more settlements were built in Karnataka: Rabgayling in
Gurupura village near Hunsur, Dhondenling at Oderapalya near
Kollegal, and Doeguling at Mundgod in Uttara Kannada. With the
settlements, the state acquired the largest Tibetan refugee
population out of every Indian state. As of 2020, Karnataka has 12
schools run by and for the Tibetan community.

Other states have provided land for Tibetans. Bir Tibetan Colony is
a settlement in Bir, Himachal Pradesh. Jeerango in Gajapati
district, Odisha, has a large Tibetan community and South Asia’s
largest Buddhist monastery.

The government of India has built special schools for Tibetans,

providing free education, healthcare, and scholarships for students
who excel in school. A few medical and civil engineering seats at
universities are reserved for Tibetans.

A document called the Registration Certificate (RC) is a permit for

Tibetans to stay in India, renewed every year or half-year
depending on the area. Every Tibetan refugee above the age of 16
must register for it, and RCs are not issued to refugees who have
newly arrived. Another official document, the Indian Identity
Certificate, nicknamed “Yellow Books”, allows Tibetans to travel
abroad. It is issued one year after an RC is given.

Rohingya

Rohingya people are also known as Arakanese Indians who are

stateless people from Myanmar. They are declared by UN as the
most persecuted minorities in the world. The Rohingya population

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was denied citizenship according to the 1982 Myanmar Nationality

Law. They had to flee due to the ongoing military crackdown by the
Myanmar Army. More than 6700 Rohingya’s were killed in August
2017. They are in heavy numbers in different cities in India, but the
government of India does not recognize them as refugees. Most of
those refugees have migrated to Bangladesh. There was a mass
displacement of refugees and forced relocations. Rohingya refugees
face multiple protection risks as of December 2017. Though India
refused to let Rohingya refugees enter the country as it posed
security threats, 40,000 refugees have taken shelter in Assam and
West Bengal. Though Bangladesh has stood up to help those
refugees, it falling short of resources. In the case of Dongh Lian
Khan v. Union of India the Delhi High Court held that the principle
of non-refoulment is part of the guarantee under Article 21 of the
Constitution of India irrespective of nationality. In the case of NHRC
vs Arunachal Pradesh, the Supreme Court held that the state is
bound to protect the life and liberty of every human being, citizen or
otherwise. Even then India is not ready to take Rohingya refugees
and help them.

VI. Constitutional provision to

refugees in india
Constitution of India are applicable to the refugees when they are in
India. The most important Article is Article 21 which deals with
Right to Life and personal liberty, it applies to everyone irrespective
of whether they are a citizen of India. Many judgements have been
given based on Article 21 on refugees. Article 14 guarantees the
person right to equality before the law. Article 5, 6, 7, 8, 9, 10,11,12,
20, 22,25-28, 32, 226 also available for non-citizens of India
including Refugees.

Treatment given to the Asylum people were divided into three

heads-

National Treatment
Treatment that is accorded to foreigners

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Special Treatment

1. National Treatment:The national treatment to the asylum

people is same as the citizens of India. There are certain Articles
in the Constitution of India, which takes care of the
Fundamental Rights of all people in India. The rights such as
equal protection to law under article 14, religious freedom under
article 25, the right to life and personal liberty under article 21,
right to social security and educational rights are guaranteed in
Part III of the Indian Constitution.
2. Treatment that is accorded to foreigners:– Under this
head, there are rights which are related to the housing problems,
movements, etc. the rights which are provided under this
treatment are: right to employment or profession under article
17, freedom of residence and movement under article 26, right to
housing under article 21, right to form association under article
15 and right to property under article 13 of the 1951 Refugee
Convention.
3. Special treatment: – This treatment includes the identity and
travel document under article 28, exemption from penalties
under article 3(1) of the 1951 Refugee Convention.

In the case of Louis De Raedt vs. Union of India[3], the court held
that the fundamental rights to life, liberty, dignity are available to
non-citizens of India. In the case of Visakha vs. State of
Rajasthan[4], the court has held that “International Conventions
and norms are significant for the purpose of interpretation of the
guarantee of gender equality, right to work with human dignity in
Articles 14, 15 19(1)(g) and 21 of the Constitution and the
safeguards against sexual harassment implicit therein”.

VII. Laws for refugees in india

India does not have specific laws regarding to the Refugees.
However, India does have the Refugee and Asylum (Protection) Bill
of 2009. But the main legislation that supports Refugees and
Asylum is the Foreigners Act of 1946.

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The laws related to refugees are:

Citizenship Act, 1955 (No.57 of 1955)

Extradition Act, 1962 (No. 34 of 1962)
Foreigners Act, 1946 (No.31 of 1946)
Illegal Migrant (Determination by Tribunals) Act, 1983 (No.39
of 1983)
India Penal Code Act, 1860 (No.45 of 1860)
Passport (Entry into India) Act, 1920 (No.34 of 1920)
Passport Act, 1967 (No.15 of 1967)
Protection of Human Rights Act, 1993 (No.10 of 1994)
Registration of Foreigners Act, 1939 (No.16 of 1939)
Immigrants (Expulsion from Assam) Act, 1950
Administration of Evacuee Property Act, 1950

VIII. Role of judiciary for the

protection of refugees
Judiciary plays a vital role in protecting refugees, many cases gave
landmark judgements regarding refugees. The judiciary has made it
easy with the concepts of Social Action Litigation and Public Interest
Litigation. When any of the refugees are detained or arrested by the
Indian authorities, there would always be a danger of refoulment,
repatriate or deportation. Those refugees who are arrested for the
illegal stay can be detained illegally under administrative order
without charges. The Foreigners Act vests an absolute and
unfettered discretion in the Central Government to expel foreigners
from India. The Supreme Court of India in Hans Muller of
Nuremburg vs. Superintendent[5], Presidency gave “absolute and
unfettered” power to the Government to throw out foreigners. The
said judgment was again upheld by the Supreme Court in Louis De
Raedt & Ors. vs. Union of India. In the same judgment, Supreme
Court also held that foreigners have the right to be heard.

In the judgment of Ktaer Abbas Habib Al Qutaifi vs. Union of

India[6] the High Court of Gujarat held that the principle of non-
refoulment avoids ejection of a displaced person where his life or

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freedom would be undermined by virtue of his race, religion,

nationality, enrolment of a specific social gathering or political
conclusion. Its application ensures life and freedom of a person
irrespectively of his nationality.

Non-Refoulment and Right to refugee Status: In Malavika Karelkar

vs. Union of India[7], the deportation order issued against 21
Burmese refugees were stayed by the SC and allowed them to seek
refugee status under UNHCR.

IX. Problems faced by refugees

in india
Various countries protect their refugees by enacting refugee
legislation based on international recognized principle. The
countries that have signed the convention have a procedure for
identifying the refugees and addressing them protection issue.

Although India has not signed the convention but are providing
protection to the refugees. “However, consistency in the procedure
for determining refugees is still lacking.” Since India has no
uniform code for determining refugee status, there is no central
body that deals with the refugees. After so many years also, there are
various gaps that exist in the mechanism for dealing with refugees’
policy. This is because the government has not enacted a law for
refugees.

Due to the several problems faced by the refugees and no proper

legislation has not been passed the legal status of the refugees is
miserable.

Problems Rohingyas are Facing in India

There are reported complaints open drains, unsanitary

surroundings and slum-like conditions in the Rohingya camps
across India.
Few children have been dead due to pneumonia, during the
winter winds.

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Snakes make a regular appearance during rains, as so do

outbreak of dengue, diarrhoea and other diseases.
Some women refugees have reported instances of harassment.
The deporting announcements by Union government also made
the community anxious.

X. Supreme court on refugees

The Supreme Court has taken recourse to Article 21 of the
Constitution in the absence of legislation to regulate and justify the
stay of refugees in India. In NHRC vs. State of Arunachal
Pradesh[8], the Government of Arunachal Pradesh was asked to
perform the duty of safeguarding the life, health and well-being of
Chakmas residing in the State and that their application for
citizenship should be forwarded to the authorities concerned and
not withheld. In various other cases, it was held that refugees should
not be subjected to detention or deportation and that they are
entitled to approach the U.N High Commissioner for grant of
refugee status. In P. Nedumaran vs. Union of India[9] the need for
voluntary nature of repatriation was emphasized upon and the Court
held that the UNHCR, being a world agency, was to ascertain the
voluntariness of the refugees and, hence, it was not upon the Court
to consider whether consent was voluntary. Similarly, according to
B. S. Chimni, the Supreme Court has erred in concluding in Louis de
Raedt v Union of India that there is no provision in the Constitution
fettering the absolute and unlimited power of the government to
expel foreigners under the Foreigners Act of 1946. With regard to
adopting international conventions in domestic laws, in Vishakha vs.
State of Rajasthan, the Court observed that reliance can be placed in
international laws. Therefore, the question that arises is whether
India can refer to the 1951 Convention in interpreting the domestic
legislation and whether it is really necessary to ratify these
conventions. It is to be noted that merely ratifying the 1951
Convention does not ensure that the asylum seekers will not be kept
out and also Article 42 of the same Convention permits reservations
with respect to the rights of refugees which will defeat the purpose of
ratifying the Convention. In the recent case where around 40,000
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Refugees have come to India from Myanmar the Government on the

basis of National security and treat of terrorist elements entering
through this rout refused to give refugee status. The Supreme Court
in Mohammad Salimullah and others vs. Union of India and
Ors[10] while deciding whether the Government could deport the
Rohingya refugees, as minority.

XI. UNHCR and NHRC in india

UNHCR in India is participating very actively as the number of cases
regarding refugees is increasing day by day. If some refugee goes
back to his country after being a refugee in India, UNHCR watches if
the person is going back voluntarily. It performs the function of
determination of refugee along with providing resources to them.
UNHCR got involved since the issue of Tibetan refugees and the
Bangladesh crisis in 1971. The Delhi office of the UNHCR works to
help refugees become self-sufficient with assistance and income-
generating activates with the help of NGO’s. The main role of
UNHCR in India is to make sure that the refugees are not forced to
go back to their country from which they have fled until the issue
rests in their country.

NHRC i.e., National Human Rights Commission in 1994, gave

directions to Tamil Nadu Government to provide medical help to Sri
Lankan refugees. In 1995, it filed a PIL on Arunachal Pradesh
Government regarding the government not supporting Chakmas,
and got the decision of the court ordering the government to provide
necessary help to the group. It gets involved in all the refugee issues
in India and provides some or the other help required.

XII. Conclusion
In the whole world, though there are a number of conventions and
laws governing refugees, the refugees still keep facing problems.
When a country as big as India doesn’t have a Refugee Law, we can
understand that many countries have the same face and are on the
same boat. If UNHCR and NHRC work together, there will be much
more development in the field of Refugee Law. There is definitely a

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need for India to set up a Law regarding Refugees, as in the future

there may be many more issues due to various reasons. Whenever
UNHCR tries to do something regarding refugees NGO’s should
actively help them. Though protection to refugees is given under
various articles of the Constitution, there needs to be a uniform Law
that give equal rights to all the refugees. India continues to take the
humanitarian view of the problem of the refugees. Considering the
security issues due to which India is not a signatory to the 1951
Convention, it should give due consideration to the same. It should
also take care that the refugee law is not mistreated and mis-utilized
by persons who come to seek opportunities. Many judgements in
India support the refugees. India has done a very good work
regarding refugees, but needs to do much more. Many Rohingya
refugees living in India are receiving support, but India is planning
to deport them to their territory. In the past NHRC submitted a
report for the ned for a Refuge law but didn’t receive a reply. If
UNHCR and NHRC together do the same, there may be an answer.
The Refugee Convention and its Protocol of 1951 and 1967 are the
Conventions that received global response with many countries
signing the convention. They consider most of the reasons of
refugees and tell us the rights and other provisions that they should
be given. India on the whole, needs a refugee law for governing
refugees entering India.

The absence of a specific domestic law and ad hoc asylum status

management might take away its soft power robbing it of the
credibility in International arena in spite of accommodating so many
groups of refugees even before the International rules for refugees
were developed. Lack of a strong political will is also among the
chief concerns. The issue of illegal migrations becomes important
during elections when political parties can take advantage of these
groups. India being one of developing countries and a deserving
candidate for a permanent member of the UN needs to make its laws
in compliance with the International regime. This is because even
without the municipal laws India is inundated with refugee influx
from different countries and it has more than often dealt with the

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2/13/25, 2:40 AM Constitutional Provision Regarding Refugee Law in India - International Journal of Law Management & Humanities

refugee issues very humanely Tibetan and Sri Lankan refugees being
good examples. Migration is continuing to grow and the reasons are
varied it is time India adopted laws to deal with the issues so that
there is transparency in administrative action. The process of
deciding who is a refugee is also unclear. While the Indian
government deals with asylum-seekers from Tibet and Sri Lanka,
the office of UNHCR in New Delhi deals with asylum-seekers from
other countries. There is need for greater coordination between
Indian Government and UNHCR.

*****

[3] Louis de Raedt vs. Union of India 1991 AIR 1886, 1991 SCR (3)
149.

[4] Visakha vs. State of Rajasthan (1997) 6 SCC 241.

[5] Hans Muller of Nuremburg vs. Superintendent 1955 AIR 367,

1955 SCR (1)1284.

[6] Ktaer Abbas Habib Al Qutaifi vs. Union of India 1999 CriLJ 919.

[7] Malavika Karelkar vs. Union of India Writ Petition (Criminal

No) 583 of 1992.

[8] NHRC vs. State of Arunachal Pradesh 1996 AIR 1234, 1996 SCC
(1) 742.

[9] P. Nedumaran vs. Union of India 1993 (2) ALT 291, 1993 (2) ALT
Cri 188.

[10] Mohammad Salimullah and others vs. Union of India and Ors.
Writ Petition (Civil) No. 793/2017.

*****

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2/13/25, 2:40 AM Constitutional Provision Regarding Refugee Law in India - International Journal of Law Management & Humanities

Volume:
4

Issue:
3

Page No:
261 - 272

DOI:
https://doij.org/10.10000/IJLMH.11446

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