The Union Ministry of Environment, Forests and Climate Change (MEFCC) in the BJP led new government at the centre has, through Office Memorandum (OM no 22-15/2014-IA.III) dated Aug 29, 2014 constituted High Level Committee (HLC) under the chairpersonship of former cabinet secretary TSR Subramanian, “to review various acts administered by Ministry of Environment, Forests and Climate Change”. Let us try and look at this proposal on its merits.

Firstly, it should be noted that the HLC has a far-reaching mandate to review the core legislations that are supposed to protect India’s environment, including the Environment Protection Act (1986), the Forest Conservation Act (1980), the Wildlife Protection Act (1972), the Water (Prevention and Control of Pollution) Act (1974) and the Air (Prevention and Control of Pollution) Act (1981). Considering that these acts are the back bone of MEFCC’s environmental governance, the recommendations of this committee can have far reaching impact on India’s environmental governance.

Secondly, there are no doubts that India’s environmental laws and governance needs to be reviewed and strengthened. While the industry and vested interest lobbies have been claiming that MEFCC’s work is a hindrance to India’s development and growth, the reality is quite the opposite. MEFCC provides environment clearance (for projects covered under EIA notification of Sept 2006, which is the current notification and which excludes large number of projects from requirement of environment clearance), forest clearance, wildlife clearance, coastal zone clearance and also certifies if the projects applying for CDM (Clean Development Mechanism under the United National Frame Convention on Climate Change) are sustainable development projects.

The committee has been explicitly constituted for reviewing the five environmental laws. These laws need to be strengthened so that there is inclusive, democratic, bottom up process in which people have a decisive role. The governance related to the laws thus needs to be changed in this context so that there is greater transparency, accountability and participation and better compliance is achieved. This is what we mean when we say we need to improve the environmental governance.

MEFCC’s zero rejection rate With respect to giving any of these clearances, the MEFCC has almost zero rejection rate in most crucial sectors. For example a review[1] of the functioning of the Expert Appraisal Committee on River Valley and Hydropower project shows that the committee has not rejected almost any of the proposals that came its way in last seven years. The MEFCC has not rejected any of the proposals that applied for CDM status. Even in other sectors, the MEFCC has rejection rate below 3%, if at all and projects for which clearances have already been given like coal mining, are far from being implemented.

States already have enormous powers Some people have been claiming that states do not have sufficient powers in environmental decision making and hence the powers need to be delegated to the states. The fact is that the states already have enormous powers in environmental governance, including in all clearances. The pollution control regime is completely under the states. The states are empowered to clear several categories of projects in the context of all the clearances. The state pollution boards are supposed to give consent to establish and operate, before which no project can operate, they are also supposed to conduct public consultations even for projects requiring central clearances. Before National Wildlife Board clears a project, State Wildlife Boards need to clear the projects. Consent of Forest Officials from the states is mandatory before Forest Clearance application is processed to higher levels. Which state in India has shown exemplary conduct to inspire confidence that they are in a position to achieve necessary environmental governance? We do not know of any. Unless the capacity of states in this regard is increased, we cannot improve environmental governance in India only in the name of entrusting it in the hands of the states.

Is MEFCC responsible for delays? This is another bogey raised against the MEFCC. The fact is that the EIA notification has clearly defined timelines that says that if MEFCC fails to respond within the timeline, the project can be deemed to have secured the clearance. The fact of the matter is that no project has claimed or gotten such deemed clearance, since most project developers are uninterested in fulfilling even the minimalist demands of MEFCC. On the other hand, most dams and hydropower projects get delayed beyond the promised time frame even after getting the clearances! For any objective person, the claim that MEFCC is responsible for delays and lengthy procedures is clearly a bogey.

Do projects need too many clearances? Another argument made by some is that MEFCC needs too many separate clearances for the same project, which leads to delays. This is again not borne out by facts and clearances that are required now are bare minimum. Except environmental clearance, rest of the clearances do not need public consultation process. Even in case of environment clearance, except the projects covered under EIA notification, rest of them do not need public consultations. The five clearances that MEF gives as listed above are required under each specific law and it is completely justified that separate appraisal process is required for each of them as the issues considered and sectors affected are specific in each case, which cannot be clubbed. We need to strengthen each one of these appraisals, rather than weakening them or clubbing them together.

EAC lacks credible independent members or chairpersons It is public knowledge that most of the people who are appointed on the various committees that appraise the projects for clearances are those who are ready to toe the official line without raising too many uncomfortable questions. There are known cases when the chairman of the EAC or  member of FAC were found to have direct conflict of interest with their involvement in companies whose projects they were to consider for clearance. Recently, NGT has ordered that the chairs of the EAC cannot be generalist administrators but must have domain knowledge and experience. The lack of credible independent members in these committees is a major reason why the Ministry manages to clear almost anything that comes its way.

Poor quality impact assessments It is also well documented how most of the environment & social impact assessments, environment management plans or the cumulative impact assessments are shoddy, inadequate, incomplete, cut paste or dishonest efforts. Even media has reported several cases, environment groups have  repeatedly sent detailed analysis and critiques of these assessments, but the ministry and its committees have the distinction of not rejecting any of such assessments or recommending punitive action against the agencies that are submitting such dishonest or problematic reports.

Public consultations in name sake Under the EIA notification of Sept 2006, the projects are supposed to have public consultations which include public hearing at each of the affected project districts. Here again there have been several documented cases how the public hearings are hijacked by the project developers, they are conducted by partisan government officers and there is no application of mind from the MEFCC to ensure that the issues raised at the consultations are addressed. Several observers, including a former environment minister has accepted that these consultations are largely for namesake only, a box to be ticked. Even when all the people present at the public hearings have said that they do not want the project, it has no impact on the decision of giving clearance to the project.

Non-existent compliance All the clearances given are conditional, and the project developer is supposed to follow these conditions and implement environment management plan. However, how is compliance to these conditions and management plans, a very crucial aspect, to be achieved? The project developer is supposed to submit six monthly compliance reports, but there are no consequences if they do not do that for years! The officials at MEFCC or their regional offices do not have the time to go through these reports and check if these indicate adherence to the required measures and norms prescribed. Neither do these agencies take steps when the compliance reports do not follow the norms. They are never known to have taken any steps in this regard. The monitoring visits from regional offices of the MEFCC are always preplanned and the project developers get away with window dressing at best. There are no surprise visits. Even after monitoring visits, the MEFCC has never taken any steps when MEFCC finds lack of compliance.

We have narrated this list of known problems to show how lax is our environmental governance and how necessary it is to strengthen it rather weakening it. If the review is being done with a view to strengthen the environment governance, it would be welcome.

Review of functioning of institutional set up in environmental governance The review of functioning of institutional set up responsible for environmental governance also becomes imperative after such a long period since these institutions were set up. For example, state and central pollution control boards were set up under the Water Act of 1974, but we do not have experience of a single river or even a tributary of a river having been cleaned up because of the efforts of the pollution control institutions. This failure is a major reason for the state of our rivers today, including the Ganga.

New Issues In addition to the need for strengthening the environmental governance, the review of environmental laws and institutional architecture connecting with their implementation is also necessary in view of the emerging new issues. For example issues like climate change, need for cumulative impact assessments, need for environmental flows in the river, need to protect, preserve and rejuvenate rivers (a proclaimed priority of the current government) or assessment of impact of projects on disaster potential of the area were not as important and urgent as they were when these laws were formulated.

CURRENT REVIEW What I have written above provides sufficient ground for need for review of laws and institutional set up for environmental governance in India. For this we need a credible independent team with clearly defined terms of reference and transparent, participatory and confidence inspiring process. Let us see if the review set up under the HLC qualifies to achieve such a review.

Sinisterly ambiguous TOR Firstly, if we read the four Terms of Reference (TOR) given to this committee under the above mentioned OM, the first TOR says the review will assess status of implementation of the act vis a vis “the objectives”. But the TOR does not define what is meant by “the objectives”. The second TOR is not problematic as it says the review will “examine and take into account the various court orders and judicial pronouncements relating to these acts”. The Third TOR is the most sinister. It says the HLC will recommend specific amendments in the acts, “so as to bring them in line with current requirements and to meet objectives”. The trouble is, neither “current requirements” nor “objectives” have been defined. Without defining them, these are open to any interpretation that is suitable to the committee! Such ambiguous TORs which are open to manipulation are completely unacceptable and do not inspire any confidence in this exercise.

Constitution of HLC The committee chaired by former cabinet secretary T.S.R. Subramanian has four members (including the chair) and two secretaries (both government officials). The constitution of the committee and criteria for selection of the members has remained completely non transparent, which itself raises many questions.

Among the four members, two are former bureaucrats and two are with legal backgrounds. None of the members are either expert in environmental issues or environmental governance. None of the members (including the chair and the secretaries) are known to have fought for or campaigned for or worked for improving environmental governance in India. There are no credible, independent non-governmental members or independent experts here.

Viswanath Anand, one of the two former bureaucrat members of the HLC and former environment secretary, does not inspire confidence due to his track record either as environment secretary (1997-2000) or as Vice Chair of National Environment Appellate Authority (2002-2005). His tenure at NEAA was described by the Delhi High Court as “a one-man show” in the absence of a chairman and three technical members of the authority.[2] Media further reports: “Very few appeals were admitted by Anand during his three-and-a-half-year stint at NEAA. In the Loharinag Pala case, he drew sharp criticism from the Delhi High Court for “adopting a very hyper-technical approach in rejecting the petitions” and overlooking “that these petitioners deserve to be heard on merits”. The court quashed Anand’s order and reinstated the appeal.” That says a lot. There are several other narrations about the role played by Mr Anand at NEAA[3]. Mr Anand is also on Coca Cola India’s Advisory Council on Environment and Sustainability[4], which seems to be in conflict with his role in HLC.

Appointment of Mr Hardik Shah (one of the two secretaries) as the Member Secretary of Gujarat Pollution Control Board was challenged in Gujarat High Court by RTI activist Amit Jethwa before he was killed, as per Indian Express report, see link in End Note 2 bleow.

Considering the non-transparency in its appointment and known background of some of the members, the constitution of the committee too does not inspire any confidence that it will help improve environmental governance in India.

Process of participation The MEFCC has said that within a month, that is by Sept 27, 2014, people can send submission to the committee in less than 1000 characters (or an email)! This is completely ridiculous and shows how non-serious the government and the HLC is about the submissions. This article, with already more than 13000 characters would clearly disqualify for submission to the HLC! Besides the issue of length, there is not even a clearly defined process that tells the people what will happen to their submissions and how are they sure to know that their submissions will be even acknowledged and responded to or even read. The process of participation is completely unacceptable. The whole process limits the participation to only English speaking and writing people who have access to internet, leaving out vast majority of the people out of the review process.

Conclusion It is clear from all accounts that the HLC does not carry any credibility or inspire in any confidence for any objective person. The best course for the MEFCC is to dissolve the HLC and restart the process keeping in mind the comments from groups and individuals without vested interests. The government should in the first place institute a credible independent review of the experience with environment laws, institutions and governance in India. This has also been highlighted by organisations like ESG. The report of this exercise should then be made available to all the gram sabhas in local languages. It is only based on such a report that a review of the environmental laws, institutions and governance be taken up, in which then the people and groups on ground can participate. At least 50% members of the review process should be women, when today there are none.

We have looked at this process purely on its merit, without looking at what the new BJP led government at the centre has done over the last four months. The government has been very busy diluting and dismantling whatever little exists in terms of environmental governance in India. If we add that track record to this analysis, then the conclusion is loud and clear: The formulation of HLC is aimed at completely dismantling the laws and institutions related to environmental governance in India. This is not a good sign for the future of this country and her people.

Himanshu Thakkar, SANDRP

ht.sandrp@gmail.com

Another blog on this issue: https://sandrp.wordpress.com/2014/10/10/strengthen-and-not-dilute-environment-laws-submission-to-the-mefs-hlc-to-review-environment-laws/

END NOTES:

[1] For details, see: https://sandrp.in/env_governance/TOR_and_EC_Clearance_status_all_India_Overview_Feb2013.pdf

[2] http://indianexpress.com/article/india/india-others/the-six-minds-that-will-look-afresh-at-environment-laws/#sthash.RMohoCW9.dpuf

[3] See for example: http://infochangeindia.org/environment/analysis/national-environment-appellate-authority-puppet-of-the-moef.html and http://www.deccanherald.com/content/22796/tribunal-coming-justice-can-wait.html and http://indiatogether.org/neaa-environment

[4] http://www.coca-colaindia.com/sustainability/final-bios.html and http://www.coca-colaindia.com/sustainability/viswanath.html, accessed at 3.37 pm (IST) on Sept 26, 2014

POST SCRIPT 1:
Those who agree may send this to hlc.moef2014@gmail.com, Sept 27,  2014 is the last date for sending submissions, but we need to keep sending submissions on these lines even after that deadline.

Post Script 2: Press Release from Environment Support Group, Bangalore after the meeting with HLC in Bangalore on Sept 27, 2014:

Press Release : Bangalore : 27^th September 2014
(Attached PDF with pictures)

High Level Committee of Ministry of Environment and Forests and Climate Change walks out of Public Consultation in Bangalore

The High Level Committee headed by Mr. T. S. R. Subramanian, former Union Cabinet Secretary, constituted by the Union Ministry of Environment and Forests and Climate Change to review environment, pollution control and forest conservation laws, invited the public at large for a consultation between 12 and 1.30 pm today (27^th September) at Vikas Soudha, the high security office complex of the Government of Karnataka. Advertisements to this effect had been issued by the Karnataka Department of Forest, Ecology and Environment in various newspapers on 21^st September 2014, followed up by various press releases inviting the public to interact with the Committee.

When various individuals and representatives of public interest environmental and social action groups turned up for the meeting, the police prevented their entry at the gates. It was only following a spot protest that the police consented to allow them to participate in the consultation. Despite this indignifying experience, all who gathered proceeded to the meeting hall with the intent of engaging with the High Level Committee.

The meeting commenced with introductory remarks by the Chairperson Mr. Subramanian. Broadly, he shared that the intent of the Committee was to hear views from across India on the type and nature of changes that were required in the environmental and forest protection laws. He stated that the Committee had the mandate of the Government to propose necessary changes that would help improve the quality of life and environment. But he said the need to ensure develop was primary, as the country was very poor (over 80% were poor he claimed) and thereby it is found essential to streamline environmental clearance processes that thwarted growth. Mr. Subramanian also shared that it was a matter of concern to the Government that several development projects were getting mired in litigation on environmental grounds, leading to needless delays. Concluding his introductory remarks he shared that the Committee is not in any manner guided by the Ministry and their recommendatory report would be submitted to the Union Government. The Committee’s proceeding, he clarified, were not open to the public, unless the committee decided to engage with the public. Responding to a question, Mr. Subramanian said that nothing that was submitted to the Committee would be shared with anybody, and that only the report would be submitted to the Government. Mr. Subramanian also said that the Ministry never proposed a public consultation exercise, but he had suggested this should take place.

Mr. K. N. Bhat, Senior Advocate and a member of the Committee, shared that there were a variety of submissions the Committee had received and each of this would be considered. He aired that environment and development should go side by side and the objectives of the laws if not found sufficient to address current needs, need for their review exists. The industry in particular, he said, had raised concerns over delays in environmental and forest clearances when the Committee met with them.

On these introductory notes Mr. Subramanian asked the members of the public to suggest changes to the existing environmental law framework. Officials assisting the Committee did not provide any rationale for the Ministry proposing changes to existing laws. The Committee also did not have any procedure, excepting online submissions of opinions on the Ministry’s website (limited to 1000 words).

When the turn of the public came, a submission was made by the Karnataka Planters Association about procedural difficulties in securing forest clearance and conforming with pollution control norms, and sought amendments for the benefit of plantations. Thereafter, Mr. A. C. F. Anand, an RTI Activist, suggested that all environmental laws must be translated so that it would be understood by all and thus the compliance rates improved.

Speaking next, Mr. Leo F. Saldanha of Environment Support Group requested the Committee to address the basis for its functioning, and whethere the TOR constituting the Committee was sufficient for such a massive and onerous task that involved fundamentally reviewing all environmental laws that were intricately linked to Right to Life, Clean Environment and Livelihoods. He sought to know what it meant, as is main TOR, ““(t)o recomment specific amendments needed in each of these Acts so as to bring them in line with current requirements to meet objectives”.

Mr. Subramanian responded that neither he nor any other members of the Committee were influenced by the TOR in any manner and that they worked per their own understanding of the mandate given to them by the Government. But when Saldanha pressed to know how a Committee consisting of high ranking former civil servants, a former Judge and a Senior Advocate could at all have agreed to such vague terms, Mr. Subramanian reacted dismissively. He claimed that this was a non-substantive issue and sought to move on to hear others. Saldanha argued that it is disturbing that Mr. Subramanian unilaterally rules a legitimate concern over vague and weak TORs as being of trivial concern, when, in fact, it would have been fit and proper for the Committee to have first explained in the interest of public accountability and transparency how they found the terms rationale and acceptable to them. And in case the terms were acceptable, then the High Level Committee, unshackled as it were by the bureaucratic norms of the Ministry, could have provided a clear note on the nature of the reforms being considered and also explicated on the procedure of consulting and receiving criticisms from various sectors, peoples, regions, geographies, etc.

Mr. Vinay Sreenivasa of Alternative Law Forum submitted that the process by which the Committee was conducting the consultation was rather opaque. The vague TOR and the fact that the Committee was constituted by a Government that sought to belittle the importance of the National Wildlife Board and rush pet projects through the clearance mechanism, seemed to suggest the entire exercise appeared to be merely ritualistic. Ms. Aruna Chandrasekhar of Amnesty International – India sought to know what specific amendments were being proposed or demanded by industry/corporate sectors, and requested the Committee put it all out. But Mr. Subramanian waved away this request too.

Prof. Puttuswamy wanted to know how a High Level Committee sought to improve environmental laws when notifications of Ministry were being issued to dilute the laws. To which Mr. Subramanian responded saying he is not a “Postman” for the Ministry. Ms. Priti Rao, meanwhile, asked for decentralised solid waste management. Mr. Vijayan Menon shared that even though he was not an official, he had walked into the Committee’s immediately preceding engagement with Government officials where a clear set of amendments were being proposed. He expressed surprise that this presentation was not being made for the benefit of the general public.

Ms. Bhargavi Rao of Environment Support Group wanted to know how law could be reformed when forest officials are unaware of biodiversity protection laws that had been passed over two decades ago and asserted that this rushed exercise in reviewing environmental laws had all the trappings of making light of people’s fundamental rights and concerns. Justice A. K. Srivatsav (Retd. Judge of the Delhi High Court) and a Member of the High Level Committee stated at this juncture that the public must have confidence in a Committee in which a senior retired Judge is a member. By which time Mr. Subramanian had remarked several times that the public was wasting the Committee’s time and there was no point continuing with this procedure. Several who had gathered protested such an assessment by the Chairman of the High Level Committee. Mr. Srinivas of Mavallipura sought to speak, saying he represents a community impacted by mal-development and waste dumping in his village, and he too was brushed aside.

At this point, Mr. Subramanian got up and said “We will end the joke here!” and walked out. He was followed by the rest of the Committee.

When Mr. Subramanian walked out, it was 1 pm. Members of the common public who had travelled great distances to engage with the Committee protested Mr. Subramanian taking them for granted and dismissing their views as of trivial concern. They demanded that the Committee return to hear the public and as advertised remained in the Hall till 1.30 pm. Neither did the High Level Committee return, nor did any official of the Ministry of Environment and Forests or Karnataka Environment Department come back to explain to the public why the High Level Committee had behaved in this manner. In fact, throughout the engagement with the public, not one Karnataka Government official was present in the Hall.

The undersigned are deeply disturbed by the manner in which the T. S. R. Subramanian headed High Level Committee has treated this public consultation process. The undersigned demand that the Ministry of Environment and Forests and Climate Change call off this exercise as it has all the markings of being a ritual exercise. In its place the undersigned demand that the Ministry must constitute a Committee that has a clear rationale for reform and Terms of Reference that are democratic, consultative and transparent. In particular, the following demands are made:

1. Environment Ministry must first come out with a White Paper discussing the nature of the reforms that it proposes in environmental, forest conservation and pollution control laws.
2. On the basis of such a Paper, an accessible Committee must be constituted that would hear peoples responses across the biologically, culturally and linguistically diverse country and also from various sectors equally.
3. The membership of the Committee should be so constituted that it would reflect diverse concerns and sectos, and in particular ensure that members conversant with tribal and human rights, environmental management, conservation biologists, biodiversity, risk assessment, planning, etc., and not merely ex-bureaucrats or members of the legal fraternity were included Particularly important is the need to ensure there is adequate representation of women on the High Level Committee, which presently is constituted only of men.
4. The process of the consultation to be followed has to be meaningful and conform with Principle of Prior and Informed Consent, even if this is not a consenting process.
5. The timeline for the Consultation mechanism for such a critical review has to be reasonable as laws sought to amended, or tweaked, fundamentally affect theRight to Life and Livelihoods, and Right to Clean Environment.
6. The entire process has to be transparent, all meetings must be recorded publicly, none of the deliberations must be in camera (as it appears to be the case now), and all proceedings, submissions, minutes and reports must be in the public domain.
7. Adequate facilities must be made to ensure that anyone interested can participated with dignity and without being inhibited by language or geographical location. To ensure this, the process must be devolved by enlisting the support of State and Local Governments.

Signatories:

Mr. Leo Saldanha; Environment Support Group, leo@esgindia.org. Cell: 9448377403

Mr. Vinay Sreenivasa; Alternative Law Forum. Cell: 9880595032

Ms. Bhargavi Rao; Environment Support Group; bhargavi@esgindia.org Cell: 9448377401

Ms. Aarthi Sridhar; Dakshin Foundation, aarthi77@gmail.com. Cell: 9900113216

Mr. Vijayan Menon; menonvij@gmail.com

Mr. Davis Thomas; Environment Support Group; davis@esgindia.org. Cell: 9036180914

Ms. Swapna; sapna.sb@gmail.com

Ms. Priti Rao; priti007@yahoo.com

Ms. Padma Ashok; Save Tiger, padmaashok@gmail.com

Mr. Ashok Hallur; ashokhallur@gmail.com

dinnil@gmail.com

Mr. Rajeev Mankotia; rmanikoth@gmail.com

Mr. Sandesh Udyawar; sandeshudyawar@gmail.com

Ms. Marianne Manuel; Dakshin Foundation, marianne.manuel88@gmail.com

Ms. Shivani Shah; Greenpeace; shivani.shah@greenpeace.org

Mr. Sohan Pavulari; sohan_pavuluri@yahoo.com

Ms. Sangeetha Kadur; sangeetha.kadur@gmail.com

Mr. Bhaskar Bhatt; muggymach3@basejumper.com

Mr. Rohan Kini; rohan.kini@gmail.com

Mr. K.N. Somashekar; cmd_vilinfra@rediffmail.com

Mr. A.C.F. Anand; acfanand@gmail.com

Ms. Shashikala Iyer; Environment Support Group; shashi@esgindia.org

Mr. Leon Louis; Environment Support Group; leon@esgindia.org

Mr. Mallesh K.R; Environment Support Group; mallesh@esgindia.org

Mr. Prashanth; Environment Support Group; prashanth@esgindia.org

Post Script 3: 

Ramaswmay Iyer, Former Secretary, Union Ministry of Water Resources wrote this email letter to Chairman of HLC Shri T S R Subramanian, we are publishing this here with his permission:

On Sun, Sep 28, 2014 at 8:23 PM, Ramaswamy R. Iyer <ramaswamy.iyer@gmail.com> wrote:

Dear TSR,

I hold you in high regard and was pleased when you were appointed Chairman of the High Level Committee to review the enviromental laws. I hoped that you would save the environmental laws from decimation. I am beginning to lose that hope.

It is amply clear why the HLC has been set up.  This government and in particular Minister Javadekar (who is Minister not for environment butagainst environment) are firmly convinced that environmental laws are playing havoc with ‘development’. What is needed in their view is quick clearance. Both those words are important. The clearance must be quick in all cases, and it must be a clearance in all cases, not a rejection in any instance. In other words, the whole exercise should be reduced to a formality or a ritual. Of course a simpler way of achieveing the objective would be to scrap the clearance procedure altogether, and repeal all the environmental laws. However, that is not easy, and such a move may have a political cost. The next best thing to do is to extract all the teeth from the laws and weaken and dilute them to the point of virtual repeal. It is for such an exercise in emasculation that the MoEF has set up the HLC. I thought that you would not be a party to such an exercise in disingenuousness. I believed that you shared the environmental and ecological concerns of many of us to some extent, if not wholly, and that the environmental laws of the country were safe in your hands. I am not so sure now, after reading reports of what happened at the ‘Public Hearing’ at Bengaluru. It appears that your views on ‘Environment vs Development’  are the same as those of Minister Javadekar. I deeply fear that the report of your HLC will do immense harm to the country. Are you prepared to live with that possibility?

I can only hope that I am wrong. If I have misjudged your position, I am ready to aplogise without reservation.

I am copying this to a few friends.

Best Wishes.

Ramaswamy R Iyer
A-10 Sarita Vihar
New Delhi 110076
Tel: 91 11 26940708
41402709
E-Mail: ramaswamy.iyer@gmail.com