Introduction: The Roots of Rebellion and Resistance
India’s Naxalite movement, often referred to as Maoism in its contemporary form, represents one of the longest-running internal insurgencies in the world. Emerging from the socio-economic fractures of rural India, it traces its origins to the late 1960s in the village of Naxalbari in West Bengal, where a peasant uprising against exploitative landlords ignited a radical left-wing revolution inspired by Mao Zedong’s ideology. This movement sought to address deep-seated grievances like land inequality, poverty, and marginalization of tribal communities, evolving into an armed struggle against the state. Over decades, it spread across India’s “Red Corridor,” encompassing states like Bihar, Jharkhand, Odisha, Andhra Pradesh, and notably Chhattisgarh, where dense forests and mineral-rich terrains provided both sanctuary and a fertile ground for recruitment.
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In Chhattisgarh, carved out from Madhya Pradesh in 2000, the Naxalite presence intensified amid rapid industrialization and mining activities. The state’s Bastar region, home to indigenous Gond tribes, became a hotspot due to grievances over land dispossession for projects by corporations like Tata and Essar. By the early 2000s, the Communist Party of India (Maoist), formed in 2004 through mergers of various Naxal factions, established “liberated zones” where they ran parallel administrations, collecting “taxes,” enforcing justice, and resisting development projects perceived as exploitative. This led to a cycle of violence, with security forces clashing against guerrillas, resulting in thousands of deaths annually.
It was against this backdrop that Salwa Judum emerged in 2005. Translated from the Gondi language as “peace march” or “purification hunt,” it was initially framed as a spontaneous tribal uprising against Naxalite excesses. Led by local politician Mahendra Karma, a Congress MLA from Dantewada, Salwa Judum mobilized villagers into anti-Maoist rallies and vigilante groups. However, it quickly morphed into a state-backed militia, arming tribal youth as Special Police Officers (SPOs) to aid counter-insurgency efforts. This transformation sparked allegations of widespread human rights abuses, forced displacements, and a de facto civil war in Bastar.
The Salwa Judum experiment culminated in a landmark Supreme Court case, Nandini Sundar & Ors. vs. State of Chhattisgarh (2011), which declared it unconstitutional, highlighting the perils of outsourcing state security to untrained civilians. This article delves into the story behind Salwa Judum, its operations, the legal battle, and its enduring legacy on India’s internal security landscape. Drawing from historical analyses, human rights reports, and judicial records, it examines how a purported “people’s movement” became a symbol of state overreach and the complex interplay between development, insurgency, and justice in tribal India.
The Naxalite ideology, rooted in Marxist-Leninist-Maoist principles, posits that armed revolution is essential to overthrow what they term a “semi-feudal, semi-colonial” system. In Chhattisgarh, this resonated with adivasis (indigenous people) facing exploitation by forest officials, moneylenders, and mining firms. Official data from the early 2000s showed Naxalites controlling vast swathes of Bastar, imposing bans on tendu leaf collection (a key tribal livelihood) and road construction to hinder security forces. Frustrations boiled over, with villagers resenting forced recruitment into Maoist squads, known as sanghams, and arbitrary killings of suspected informants.
Enter Salwa Judum. What began as protests in Bijapur district against these impositions was co-opted by the state government under Chief Minister Raman Singh of the Bharatiya Janata Party (BJP). Mining agreements signed in 2005 with industrial giants coincided with Salwa Judum’s rise, fueling suspicions that the militia was a tool to clear tribal lands for extraction. Over the next few years, it displaced hundreds of thousands, burned villages, and deepened divisions, all while claiming to restore peace.
This narrative is not without controversy. Proponents viewed Salwa Judum as a necessary bulwark against terrorism, while critics, including human rights organizations, labeled it a state-sponsored terror campaign. The Supreme Court’s intervention underscored the constitutional imperative for the state to uphold the rule of law, even in conflict zones. As we explore this saga, it becomes evident that Salwa Judum’s story is a microcosm of India’s struggle with inequality, governance failures, and the human cost of counter-insurgency.
Origins and Formation: From Grassroots Grievances to State-Sponsored Militia
The genesis of Salwa Judum can be traced to the simmering discontent in Chhattisgarh’s Bastar division during the mid-2000s. The region, characterized by its rugged terrain and predominantly tribal population, had long been a Maoist stronghold. The insurgents, operating under the banner of the People’s Liberation Guerrilla Army (PLGA), enforced strict control over local resources and activities. For instance, in 2005, Maoists banned the collection of tendu leaves—a vital source of income for tribals—protesting low procurement rates by contractors. They also halted road-building projects, viewing them as enablers for security force incursions.
Initial protests erupted in villages like Bedre and Kutru in Bijapur tehsil, where locals, frustrated by these restrictions, sought police protection. Mahendra Karma, a charismatic tribal leader and former Communist who had switched to the Congress party, capitalized on this sentiment. Having personal grudges against Maoists—who had targeted his family—he organized rallies framing Salwa Judum as a “people’s movement” for peace. The first major gathering occurred in June 2005 in Kotrapal, a Maoist-dominated village, where thousands rallied against insurgent interference.
However, evidence suggests the movement was far from spontaneous. Reports indicate police orchestration from as early as January 2005, with operations to mobilize villagers against Maoists. A pamphlet from the CPI (Maoist) alleges that Salwa Judum originated in police headquarters, with wireless messages from senior officers instructing brutal tactics like burning grain stores and targeting journalists sympathetic to Naxalites. The Dantewada Collector’s 2005 work proposal outlined funding and logistics for the “People’s Movement against Naxalites,” including village defense committees and police-led identification of “friendly” areas.
State involvement escalated rapidly. The Chhattisgarh government provided transportation, food, and security for rallies, with politicians like Karma addressing crowds. By mid-2005, Salwa Judum had evolved into armed patrols, with tribals appointed as SPOs under the Chhattisgarh Police Act, 2007. These officers, often young and illiterate, received minimal training—typically two months on basic weaponry and human rights—and a meager honorarium of Rs 1,500-3,000, largely funded by the central government.
Critics link Salwa Judum’s formation to economic interests. In 2005, the state signed MoUs with Tata Steel and Essar for iron ore mining in Bailadila and Lohandiguda, displacing tribals. Maoists opposed these, viewing them as corporate land grabs. Salwa Judum raids conveniently targeted villages in these areas, forcing relocations and clearing paths for projects. Human rights groups argue this was “ground-clearing” vigilantism, dividing communities and sparking civil war-like conditions.
Karma’s role was pivotal. As a Dantewada MLA, he projected Salwa Judum as a tribal-led resistance, drawing on his influence among the Koya tribe. Yet, his methods drew ire; he was accused of using coercion to swell ranks. By 2006, Salwa Judum claimed thousands of participants, but many joined under duress, fearing reprisals from both sides.
From a Maoist perspective, Salwa Judum was a fascist state ploy to exploit minerals, displacing adivasis into “concentration camps” while arming mercenaries. They formed counter-groups like the Koya Bhoomkal Militia to resist, viewing the conflict as a people’s war against imperialism.
Thus, Salwa Judum’s origins blend genuine grievances with state manipulation, setting the stage for years of turmoil.
Activities and Tactics: Raids, Camps, and the Machinery of Counter-Insurgency
Salwa Judum’s operations transformed Bastar into a battleground. What started as peace marches evolved into aggressive raids on suspected Maoist villages. Groups of 50 to 2,000 Salwa Judum members, backed by security forces like the Central Reserve Police Force (CRPF) and Naga Battalion, would descend unannounced, beating residents, looting livestock, and burning homes. The goal: force villagers to join anti-Naxal camps or flee, denying Maoists their support base—a tactic akin to “strategic hamletting” used in other insurgencies.
Raids were relentless, occurring multiple times per village between 2005 and 2007. In Kotrapal, attacked four times, Salwa Judum looted cattle and killed sangham members. Villages like Mukudtong saw huts burned, elders beaten, and women raped. A 2006 raid in Kamarguda resulted in 50 homes torched and three throats slit. Security forces often participated or stood by, providing cover fire.
Forced relocations were central. Villagers were herded into roadside camps, numbering around 46,000 by 2007. Camps like Dornapal and Errabor housed thousands in squalid conditions, with inadequate sanitation, rations, and healthcare. Residents were coerced into participating in further raids, creating a self-perpetuating cycle of violence. Children and women were particularly vulnerable; testimonies describe abductions from markets and beatings for non-attendance at meetings.
SPOs formed the backbone of operations. By 2011, 6,500 were appointed, tasked with intelligence gathering, guiding forces, and combat. Armed with rifles or traditional weapons, they manned checkpoints, harassed travelers, and enforced boycotts on markets in Maoist areas. The state divided districts into sectors, deploying SPOs for searches and establishing Village Defence Committees (VDCs) to sustain the campaign.
Tactics included psychological warfare: fines for missing meetings, threats of village attacks, and cutting off essential supplies. In Neeram, villagers trekked days to alternative markets after Salwa Judum blockades. Maoists retaliated with ambushes, landmines, and executions of Salwa Judum leaders, escalating the toll.
Statistics paint a grim picture: Over 644 villages affected, 3,500 homes destroyed, and up to 350,000 displaced. Official figures from 2005-2011 report 422 Maoists, 286 security personnel, and 543 Salwa Judum members killed. Camps became symbols of division, splitting families and eroding tribal unity.
While effective in temporarily disrupting Maoist logistics, these tactics bred resentment, boosting insurgent recruitment and prolonging the conflict.
Allegations of Human Rights Abuses: A Catalog of Atrocities
Salwa Judum’s legacy is marred by severe human rights violations, documented by organizations like Human Rights Watch (HRW), the National Human Rights Commission (NHRC), and independent fact-finding teams. From 2005 onward, reports detail systematic abuses by Salwa Judum and security forces, often with impunity.
Key allegations include extrajudicial killings, rapes, torture, and arson. HRW interviewed 52 eyewitnesses from 18 villages, revealing patterns of raids where Salwa Judum beat villagers, looted belongings, and burned homes without warning. In Pidmel, three raids in 2006 saw eight huts torched and livestock stolen. Mukudtong witnessed the rape of a 20-year-old woman and the stabbing of an elder.
Rapes were rampant. CRPF personnel were accused of gang-raping women during detentions, with one victim enduring repeated assaults over 10 days. Fact-finding reports note unrecorded crimes, including the gang-rape of adivasi women by Salwa Judum goons and police.
Children suffered immensely. Abductions separated families; a teenage boy from Basaguda described coercion into rallies. Camps forced child participation in activities, violating international norms.
Disappearances and abductions from markets were common. In Errabore, 15 were taken to camps, their fates unknown. Testimonies like Kadti Gowri’s highlight fears of killings.
The NHRC’s 2008 probe confirmed abuses, recommending investigations, though the state dismissed many claims. A Supreme Court petition cited 537 killings and 2,825 homes burned by 2007.
Maoists committed counter-atrocities, killing Salwa Judum participants and civilians, but critics argue state sponsorship amplified the cycle. The Administrative Reforms Commission criticized delegating law enforcement to vigilantes.
These abuses highlight the human cost, with long-term trauma and eroded trust in institutions.
The Supreme Court Case: Petition and Arguments
In 2007, sociologist Nandini Sundar, historian Ramachandra Guha, and former bureaucrat E.A.S. Sarma filed a writ petition under Article 32, alleging state-sponsored violations via Salwa Judum. They sought its disbandment, probes into abuses, and rehabilitation for displacees.
Petitioners argued SPO appointments violated Articles 14 and 21, citing inadequate training (e.g., 24 hours on law) and risks to youths used as “cannon fodder.” They highlighted incidents like 2011 village burnings in Morpalli and attacks on activist Swami Agnivesh.
The state defended SPOs as essential “force multipliers,” legally appointed under police acts, with roles limited to self-defense and intelligence. The Union supported funding under SRE schemes.
The court monitored the case, ordering NHRC probes and interim relief like vacating schools occupied by forces.
The Supreme Court Judgement: Reasoning and Orders
On July 5, 2011, Justices B. Sudershan Reddy and S.S. Nijjar declared Salwa Judum unconstitutional.
Reasoning rooted the conflict in socio-economic inequalities, criticizing neo-liberal policies and the state’s “iron fist” approach. SPOs violated Article 14 (arbitrary appointments) and 21 (endangering lives with poor training). The court likened it to colonial exploitation, emphasizing professional policing over vigilantism.
Orders: Cease SPO use in counter-insurgency, stop funding, recall arms, provide security to ex-SPOs, investigate crimes, and CBI probe 2011 incidents. SPOs limited to non-combat duties.
Aftermath and Legacy: Disbandment, Rebranding, and Ongoing Conflict
Post-judgement, Salwa Judum was disbanded, but SPOs rebranded as District Reserve Guards with better training. Karma was assassinated in 2013 by Maoists.
The ruling weakened immediate vigilantism but prolonged Naxalism by addressing symptoms over roots. Recent operations in 2025 show intensified anti-Maoist drives, but displacement lingers. Legacy: A cautionary tale on human rights in counter-insurgency.
Conclusion: Lessons from the Shadows of Bastar
Salwa Judum exemplifies the dangers of vigilante justice in democratic societies. While born from legitimate frustrations, its state-backed excesses violated core constitutional values, exacerbating rather than resolving the Naxalite conflict. The Supreme Court’s verdict reaffirms that security cannot trump dignity. Moving forward, India must prioritize inclusive development to quell such insurgencies, ensuring tribal voices shape their future.
Evidence, Records, and Court Judgement
Key Evidence and Records:
- HRW Report (2008): Documents 537 killings, 2,825 homes burned; testimonies of rapes and abductions.
- NHRC Report (2008): Confirmed abuses, recommended probes; dismissed some but noted violations by both sides.
- CPI (Maoist) Pamphlet: Alleges police origins, lists atrocities like gang-rapes.
- Fact-Finding Report (2007): Details raids in Bijapur, displacements of 30,000.
- Research Paper by Sundar: Notes annihilation tactics, long-term divisions.
Excerpts from Supreme Court Judgement (Nandini Sundar & Ors. vs. State of Chhattisgarh, 2011):
- Background: “The petitioners have alleged widespread violation of human rights… due to activities of Naxalites, and Salwa Judum.” (Para 23)
- Reasoning: “Appointment of SPOs violates Articles 14 and 21… treating unequals as equals.” (Para 74)
- Orders: “Cease using SPOs in counter-insurgency… CBI to investigate incidents.” (Para 75-79)
