TO: Mr. James Wolfensohn, President, World Bank
Executive Directors of the Bank
FROM: Sidney Jones, Executive Director for Asia
Mike Jendrzejczyk, Washington Director for Asia
RE: World Bank projects in the Singrauli region of India
Summary and Recommendations
Over the past several months, Human Rights Watch has become increasingly concerned about reports of human rights violations in the Singrauli area of India, home to several World Bank-funded projects. On March 2 - March 7, 1998, we sent a team consisting of a U.S. and an Indian national to the Singrauli region to investigate some of those reports; our findings and recommendations are summarized below.
- The police, members of the Central Industrial Security Force (CISF), civilian authorities, and officials of the National Thermal Power Corporation (NTPC), often acting in concert, have engaged in a pattern of clear human rights violations, including arbitrary detention, degrading treatment in custody, and indiscriminate use of force, against persons displaced by the Bank-funded Vindhyachal Super Thermal Power Project (VSTPP) and Rihand Super Thermal Power Project (RhSTPP) and against those who have protested compensation levels, conditions of resettlement, and environmental damage. We urge that all disbursements of current loans and all future loans to the NTPC be conditioned on respect for fundamental rights of those affected by the project, including the right to peacefully and freely express their views without unreasonable or illegal restrictions or abuse by local authorities and the right to be fully consulted with respect to appropriate compensation and resettlement in accordance with the Bank's own resettlement and environmental policies and its emphasis on good governance.
- The Bank needs to develop a long-term strategy for more effective, ongoing monitoring as a way to establish a means to address abuses. As one component of that strategy, we urge that the one-year term of the Independent Monitoring Panel (IMP) be extended and that the model of a national-level monitoring board be applied to other countries in which the Bank works. We also urge that the IMP be permitted to report its findings directly to the Inspection Panel and the Bank's Executive Directors. The presence of the IMP should not, however, undermine the equally important role of the Inspection Panel, without whose report the IMP might not have been established.
- The Xavier Institute of Development Action and Studies (XIDAS) has also played a critical role in bringing to light the problems associated with the Singrauli project. Its report will form the basis of the IMP's efforts to resolve conflicts between those affected by the project and the NTPC. We urge that the full XIDAS report be sent directly to the Executive Directors, that its recommendations concerning the participation of project-affected people be implemented without delay, and that XIDAS continue to be involved in the project until all of the issues concerning resettlement and compensation have been resolved. Without such direct involvement, the human rights abuses we document in this report may continue.
- Neither the IMP nor XIDAS, however, should be seen as a substitute for direct Bank supervision of the project, which to date has been lacking. The Bank's Executive Directors should ensure that Bank management staff exercise oversight of the project, including on-site visits, and that the Bank implement the recommendations of the IMP and XIDAS.
- The Inspection Panel (IP) should be called to review progress with regard to the recommendations of the IMP and the XIDAS within one year and report directly to the Executive Directors of the Bank. The Inspection Panel has played and continues to play an important role in exposing some of the problems of compensation and resettlement that lie at the root of the human rights violations we documented. Following a visit in July 1997, the Inspection Panel had requested that it be permitted to conduct a more thorough on-site investigation. Had it been able to do so, some of the subsequent problems might have been averted. The Bank should now deploy an Inspection Panel team to the Singrauli area to conduct an on-site investigation and to formulate measures to prevent further human rights abuses. Continued involvement of the Inspection Panel is critical to ensuring that a fair resolution of the problems affecting the displaced communities in the Singrauli project area is achieved.
- Given the vital role the Inspection Panel has played with regard to the Singrauli project, we urge that the Bank, in its review of the Inspection Panel, ensure that its powers are not diluted and that it be permitted to continue to perform its function as an independent body to investigate complaints and monitor Bank projects in all countries.
- The Singrauli case has raised many critically important and interlinked issues of human rights, resettlement, compensation, and environmental protection. In accordance with its 1993 policy of transparency and disclosure, the Bank should make public as much of the internal debate and discussion on the case as possible, including the results of missions and site visits and the reports of the IMP and XIDAS. We further urge that the Bank's Executive Directors meet to discuss the Singrauli project as soon as possible.
Human Rights Abuses Against Project-Affected Persons
Men and women in the Singrauli have been subject to human rights abuses perpetrated by various state actors including police, members of the Central Industrial Security Force (CISF), civilian authorities, and contractors or individuals acting on behalf of the National Thermal Power Corporation (NTPC), a government body. In some cases these abuses, which were still taking place in early 1998, have been carried out by local police or other security forces at the request or in the presence of NTPC. As has been well-documented by Indian and international non-governmental organizations, the basis for most of these abuses has been either complaints about levels of compensation given to villagers who were forced to relocate or opposition to relocation itself. Many of those we interviewed felt they had not been adequately consulted about problems related to displacement or environmental destruction, contrary to current Bank policies.
Our interviews echoed the findings of the Bank's Inspection Panel, which noted in its December 22, 1997 report on the NTPC project that it had found "serious violation of Bank polices on Environmental Assessment (Operational Directive 4.01) and Involuntary Resettlement (Operational Directive 4.30)."
Operational Directive 4.30 states that "arrangements for monitoring implementation of resettlement and evaluating its impact should be developed by the borrower during project preparation and used during supervision. Monitoring provides both a warning system for project managers and a channel for the resettlers to make their needs known and their reactions to resettlement execution." Despite these provisions, many project-affected persons told us that they had not been adequately consulted about resettlement arrangements or the environmental impact of the project. Others noted that because of the lack of consultation, alternative ash waste disposal arrangements that would have been less destructive to the environment were not explored. Many displaced persons stated that they felt obliged to protest the destruction of the local environment, as their fields and surrounding areas represented their only sources of livelihood. A lack of real community participation in critical decision-making processes appears to be a root cause of many of the problems related to the project.
Many of the displaced we interviewed described a cycle that would begin with physical abuse and harassment, and lead to arbitrary arrest and detention, ill-treatment and threats in custody, arbitrary application of the law, and intimidation to discourage further protest. They described a pattern of NTPC personnel engaging third parties to carry out acts of violence. Displaced persons demonstrating in front of the Rihand power plant gates reported that private "goon squads" had been used to intimidate and physically harass them.
Freedom of Assembly/Freedom of Association/Arbitrary Arrest
The displaced are discouraged from assembling in public and creating organizations through the use of intimidation, force, and the application of Section 144 of India's Criminal Procedure Code, a broadly worded, all-purpose clause that can be used to restrict freedom of assembly. Section 144 allows a district magistrate or sub-divisional magistrate to direct any person or group to stop any activity in order to "prevent injury to any person... or danger to human life, health, or safety, or a disturbance of the public tranquility." It is supposed to be used only in cases where urgent prevention or remedy is required and where there is an immediate perceived danger to public order. In the Singrauli area, it has become the instrument of choice in preventing organized protests, and we were told that authorities sometimes used it to prohibit gatherings of more than four people.
At the same time, local authorities generally did allow protests at specific dharma or sit-in sites, one in front of the Rihand and one in front of the Vindhyachal power plant colonies. Sit-ins at these sites have taken place intermittently over the past several years, and during our investigation in March 1998, displaced persons conducted small sit-ins in both places involving between two and twenty participants, apparently without incident.
On several occasions in recent months, however, police used force when the sit-ins became larger. In one case, two NGOs in the Singrauli area, Visthapith Samaj Seva Sang (VSSS) of Navjeevan Vihar and Grameen Kalyan Sangharsh Samiti (GKSS) of Bijpur, had planned a demonstration on December 16, 1997 in front of the Vindhyachal power plant colony, advocating for more compensation for those displaced by the projects.
According to witnesses at the demonstration site, approximately fifty people had gathered in a peaceful manner in the late morning on the December 16. Within minutes, police from the Navjeevan Vihar station began dispersing the protesters, beating them with batons and shouting insults. Five people were arrested by members of the Navjeevan Vihar police in front of the power plant. An elderly man arrived on the scene after police had attacked the demonstrators and attempted to help one participant who had been beaten. He told us,
When I arrived, I saw Sumant Sharma lying by the road with his clothes torn. When I walked toward him, the police raised their sticks and insulted me. They threatened to break my hands and my head. They said we've already arrested four or five -- we'll arrest you too.
In reference to the incident, the Station House Officer of the Navjeevan Vihar police told us in an interview on March 6 that the police had received complaints that demonstrators were insisting that people join their protest. He said the police had calmly asked the demonstrators to refrain from illegally detaining pedestrians. He also stated that four or five of the demonstrators were arrested. He also mentioned that the police had not filed cases against many of the displaced who were illegally farming their fields, now NTPC land. He even claimed that the police had been conservative in making charges against displaced persons in an effort to avoid bogging down the legal system.
The National Human Rights Commission (NHRC) in New Delhi also conducted an investigation, but failed to take seriously the charges of police abuse. One official claimed that the NHRC was "satisfied that no act took place which calls for an action on the part of the Commission" and that they were "assured that nothing illegal has happened... and that there was no high-handedness by police as alleged." Upon further questioning, however, the same official admitted that he had not spoken to any of those arrested or involved in the demonstration and that he had only spoken with the police.
Further arrests occurred on December 18, 1997 near this demonstration site in fields that had been legally transferred to NTPC but were still in use by some of the displaced. According to one of the individuals arrested, NTPC personnel and contractors accompanied by police, members of the CISF, and private security guards of NTPC, arrived at the fields that morning with heavy machinery to destroy the fields. After hours of discussion between NTPC Resettlement and Rehabilitation personnel, the Additional Superintendent of Police, civilian authorities, and a group of displaced who were protesting the destruction, several of the protesters placed themselves in front of the machinery. Police responded by beating them with sticks and arresting seven. We interviewed one of the victims who claimed he had been beaten on his back and his hands; some ten weeks later, the marks of the beating were still visible.
When asked about these incidents, the NTPC General Manager of the Vindhyachal power plant described the problem as "not a question of resistance, but people trying to take as much as possible." He said that police had to come to the scene to remove protesters who were "in the way of construction." He also stated that NTPC had since left the fields and told local villagers to "please come cultivate."
Displaced persons also told us that abuses were frequently carried out by private security forces or "goon squads" employed by contractors working with NTPC or by NTPC itself. One such incident reportedly occurred on January 5, 1998 in the village of Mitihini. On that day, individuals attempted to resist ash dike construction on fields near the village, being carried out by KN Construction Company (KNCC) on behalf of NTPC. KNCC is a regular and major contractee of NTPC. According to one of the protesters, in order to proceed with their work, KNCC used over thirty "goons" to physically abuse the men and women from Mitihini who were on the scene. The same day, the Rihand power plant colony gate at Bijpur was closed to discourage other people from joining the protest.
On February 9, 1998, two men, Harish Chandranai and Bhagwati, were arrested in front of the Vindhyachal power plant by police, reportedly acting under orders from the Upper Collector, a local official. They were among a group of people that had set up market stalls on land immediately adjacent to a state road near the Vindhyachal colony wall; such land, according to the people we interviewed, is public land. The stall owners told us that they been displaced from their farms and the lack of other livelihood options had obliged them to set up the stalls.
Knowledgeable sources claim that NTPC officials had requested in writing to the Upper Collector that the market stalls be destroyed, possibly due to their location just adjacent to the power plant entry way. According to Bhagwati and other witnesses, the General Manager of the Vindhyachal power plant, his deputy, the local Upper Collector, and the Sub-district Magistrate had all visited the market stall site at various times on February 9. The same day, NTPC security guards and police attempted to dismantle the stalls. When people from the market stalls protested, the Upper Collector told police on the scene to arrest all those involved. Several, including Harish Chandranai and Bhagwati, were also beaten. According to R.S. Verma, who witnessed the incident, two female market stall operators were struck by NTPC security guards, had their clothes torn, and were pushed into an open sewer.
The security guards and police eventually left the scene without destroying the market stalls. On the afternoon of March 2, 1998, however, a flaming object was reportedly thrown from inside the NTPC colony onto the market stalls. Several of the stalls were seriously damaged by the subsequent fire. Human Rights Watch visited the site where signs of the fire were clearly visible.
Representatives of the NGO, Visthapith Samaj Seva Sang (VSSS) filed a First Information Report (FIR)-- the starting point for any investigation -- with police about the February 9 arrests of Bhagwati and Chandranai and the ill-treatment of the market stall owners described above. No investigation was pursued, and according to those we interviewed, this was the standard state response to complaints. Displaced persons claimed that police frequently failed to formally register their complaints. On December 17, 1998, following the arrests and ill-treatment of five displaced persons on the previous day, members of VSSS addressed a letter of protest to the local Upper Collector. As of March 6, 1998, they had received no response.
Arbitrary Detention/Ill-Treatment and Degrading Treatment in Custody
People from villages detained by police or serving jail time in the Singrauli area were subject to poor conditions and degrading treatment. In addition to physical abuse, displaced persons consistently spoke of threats and insults against them related to their demands for resettlement compensation.
Displaced persons detained on December 16 and 18, 1997 stated that they were held at the Navjeevan Vihar police station without food, water, or access to a toilet for twenty-four hours. They claimed that police harassed them while in custody, pulling their hair, insulting them, and threatening them saying, "We will ruin your life, we will let you rot in jail." At the station the detainees were not allowed to speak, did not have access to a lawyer, and were not told what charges had been filed against them.
A total of fourteen persons arrested on December 16 and 18 were transferred to the Sidhi district jail where they were subject to further degrading treatment and harsh conditions. Displaced persons detained at Sidhi jail stated that they "had to fight for each drop of water" for drinking and bathing, and were required to perform degrading tasks such as cleaning latrines by hand.
The former detainees told us that while they were in Sidhi jail some of their families received visits from Navjeevan Vihar police who threatened to send the detainees out of the district if their protest activities did not stop. Sending them out of the district would severely limit their access to their families and perhaps further delay court hearings. According to the displaced, bail was set only after court officials had been bribed; for one of the detainees this was after fifteen days in custody. The displaced claimed, contrary to common practice, that local magistrates were either absent or unwilling to set bail for them on December 19, increasing the length of their detention. The detainees were released from jail between ten and nineteen days later.
The people we interviewed stated that the length of detention for protesters was often arbitrarily prolonged due to special instructions from the police, local magistrates, or NTPC officials. In a June 27, 1996 police report from Bijpur, a copy of which we saw, the Station House Officer attempted to maximize the length of detention of a group of twenty-three displaced persons arrested in Mitihini. The twenty-three had been arrested for passively obstructing construction on their fields. Following their arrest, the Station House Officer in Bijpur issued a written report to the Sub-divisional Magistrate saying, "It is requested to Mr. Manu that Ram Narayan and others be put in jail for as long a time as possible." (Narayan was among the protesters.) This request was made despite the peaceful nature of the resistance. Fourteen of the detainees were transferred to Jabalpur jail where they were held for approximately two weeks. During this time, police officers visited the homes of two of the men arrested and attempted to intimidate their family members.
Court officials at times appeared to take harsh action against protesters. Following the arrest of twenty-three protesters in Mitihini village in 1996, a range of charges were filed. Approximately nine months later, the High Court of Allahabad found that the charges were without basis and dismissed them. The same day, a Sub-district Magistrate in Khaad told a resident of Mitihini village, "You're not going to get land or jobs. If you make trouble, we'll drop ten charges on you." Later the same day, local judicial authorities invoked Section 144 in the Bijpur and Mitihini area, prohibiting public assembly for the next fifteen days.
Hearings of cases against displaced often drag on over several months and involve costs that are crippling for displaced persons. Individuals with court cases stated that they were required to appear for hearings two to three times a month, at a cost of approximately 120 rupees (a little over U.S.$3.00) per person for court and clerk fees; some cases had dragged on for at least nine months. Missing a court hearing could result in arrest. Bail and miscellaneous fees often amounted to thousands of rupees, and displaced persons frequently complained of having to bribe court officials in order to move their cases forward. Due to their economic status, project-affected persons were also often required to use their land as collateral for bail. Several displaced persons who had false or inflated charges pending against them stated that the compensation they had received for relocation had been used to pay lawyers, court fees, bribes, and miscellaneous expenses incurred in order to defend themselves.
Freedom of Expression/Arbitrary Arrest
People in resettlement colonies and in villages both stated that they were subject to threats whenever they raised their voices, especially when speaking out against conditions regarding resettlement or compensation. One resident of Navjeevan Nagar resettlement colony stated, "Whenever we show them our bellies, they show us their sticks," in a reference to the reaction of security forces who accompanied NTPC personnel on visits to the resettlement colony.
Individuals arrested on December 16 and 18, 1997 claimed that they were not permitted to speak while in the custody of the Vindhyachal police, nor were they allowed to communicate with a lawyer.
Protesters are frequently charged with violations of the Criminal Procedure Code, apparently in an effort to restrict freedom of expression. We have documented such misuse of criminal procedures in other areas of India where members of civil society or political parties have attempted to exercise their rights to assemble, organize, or express themselves. Individuals with several cases pending against them find themselves entangled in costly and time-consuming processes of an over-burdened and highly bureaucratic legal system.
Raj Dev, one of the five individuals arrested on December 16, 1997 in Vindhyachal, was charged with five sections of the Criminal Procedure Code, including Sections 107, 109, 110, 116, and 151. Section 110, also known as the Goondas (goons) Act, targets "habitual offenders and desperate characters" or those who are "so desperate and dangerous as to render [their] being at large without security hazardous to the community." A resident of Uska village, told us, "They put five cases on me; it's like putting a gag on our mouth so we can't talk any more."
Several other leaders of the displaced were also charged with the Goondas Act and voiced similar complaints. Suryalal Sahu, approximately sixty-five years old, was among those arrested and beaten on December 18, 1997. Sahu stated that he had been charged with the Goondas Act, as well as Sections 147, 148, 194, 336, and 506B. Section 506 targets individuals who may be implicated in "criminal intimidation" or who threaten others with "death or grievous hurt." During interviews, NTPC and police officials informally referred to some of the protesters as goondas.
In addition to the violations of physical integrity noted above, Human Rights Watch is particularly troubled by the use of violence against women, including by female constables. As with police confrontations with male protesters, female police often used verbal abuse, beatings, or other brutal methods against women who passively resisted relocation from villages or obstructed NTPC destruction of fields.
Leelavati, a seventy-year-old woman who lives in Uska village near the Vindhyachal power plant, told Human Rights Watch of her experience with female police. Leelavati, who is in a precarious state of health, had refused to leave her home, claiming that she had not received any compensation for her house. In July 1997, police arrived at her home, accompanying NTPC personnel and laborers who had instructions to dismantle her house. When she refused to leave, two female police officers dragged her by her arm out of her house and said, "We'll give you a good beating if you don't stay outside." Laborers proceeded to dismantle her house, the remains of which were still visible during our site visit. She had moved in with neighbors who were also refusing to relocate, claiming the compensation they had received would not permit them to survive in the resettlement colony.
Residents in Mitihini village stated that nine women were detained by police on June 27, 1996. The women were part of a larger group of Mitihini residents who were blocking the work of a bulldozer sent to destroy fields. One of the nine, a woman holding a small child, was physically abused by three female officers and detained. Her child was reportedly taken from her arms by female police and thrown several feet away, suffering injuries. The nine women were held in the police station without food until late into the evening of June 27. One pregnant detainee fainted while in police custody.
Displaced women we met also drew attention to discrimination in the compensation system. Women were rarely offered jobs or monetary compensation despite the crucial role they have traditionally played in farming and supporting their families. Many women interviewed by Human Rights Watch in Navjeevan Nagar faced particular hardship following relocation as they apparently had even less access then displaced men to sustainable jobs or land as compensation. Our research also found caste-related discrimination. Displaced people from the lower Basohars caste in Navjeevan Nagar claimed that steady jobs with NTPC had been given exclusively to their former upper caste neighbors who now lived within the NTPC power plant colony.
Freedom of Movement
The only restriction on freedom of movement we noted was within the Rihand colony. The road leading through the Rihand colony constitutes the shortest route between much of the commercial section of Bijpur and the village of Mitihini. At Rihand, the gates close at approximately 11:00 p.m., after which access is subject to the discretion of CISF. People who wished night access to the hospital located inside the gates had to convince the CISF that they had good reasons for wanting access. CISF also frequently closed the gates to the colony during protests, thereby preventing access to the NTPC administration in Rihand.
Foreign nationals face further restrictions on access either to or through the Rihand power plant colony or to adjacent areas where villages are being destroyed for ash dike construction. On March 5, 1998, our team was denied access to the Rihand colony by CISF at the Bijpur gate as we were trying to get to Mitihini village. The officials who denied us access told us there was no other way to get there. Despite repeated efforts to call from the CISF office telephone at the colony gate, we never got through to the management of the Rihand colony. As we waited for more than two hours in the CISF office, CISF officers told us that Rihand management had been informed that we were coming and did not wish to speak with us.
Responses from the Indian Government
Despite the serious nature of the above abuses and a high level of tension among both displaced persons and authorities in the Singrauli area, most government officials we met downplayed problems related to resettlement. Officials from the police, NTPC, and NHRC interviewed by Human Rights Watch generally denied that serious human rights abuses had been committed against displaced persons. Officials frequently described the resistance to relocation as the efforts of a few individuals who were either not from the area or who were trying to exploit the situation.
The general manager of NTPC in Vindhyachal power plant, claimed that there were no serious problems in the area and that the Navjeevan Nagar resettlement colony was "one of the finest in India." When asked whether NTPC had a formal system to receive grievances from displaced persons, the general manager explained to us in a March 6, 1998 interview in Vindhyachal colony,
The Court has given directions. The state government has given everything -- every one has got it. If anyone has a complaint or needs something, I will ensure he gets it. Let them come to me and tell me. Why don't they come to me and tell me? I have received them numerous times right here in my office.
From our research, however, it appeared that there were no formal grievance procedures in place and that displaced persons experienced great difficulty in approaching the Vindhyachal power plant general manager with their complaints.
Members of the National Human Rights Commission have also downplayed the importance of events in the Singrauli area. In response to complaints from displaced persons in 1996, the NHRC conducted an investigation in Singrauli but found the complaints to be baseless. Their investigation was criticized by many villagers who claimed they had not sufficiently consulted the affected populations and had spent too much time in the Singrauli area with NTPC officials.
In February 1998, NHRC officials reported to Human Rights Watch that they had investigated the incidents of December 16 and 18 as well as January 15-16, 1998 and had found them also to be without foundation. In March 1998, however, an NHRC official admitted that this investigation had not included interviews with any of the affected villagers, as stated above. Nonetheless, three NHRC officials we spoke with, who had been involved in the Singrauli case, remained defensive of NTPC's role in resettlement and rehabilitation.
NTPC officials appeared to exercise significant influence over the actions of local police and civilian authorities, including local magistrates and police. Many displaced persons alleged that NTPC would manipulate these authorities in order to silence protesters rather than addressing root causes of their grievances. On January 15, 1998, residents of Mitihini village complained to Bijpur police that NTPC workers were attempting to bulldoze crops in Mitihini. The Bijpur Station House Officer reportedly reprimanded NTPC officials during a phone call in the presence of Mitihini residents and ordered the plowing to stop. Despite this order, the fields in question were destroyed early on the morning of January 16 by NTPC workers. An NTPC manager on the scene stated the following to residents of Mitihini:
Why are you running around saying that we're plowing crops? If you give our names, we'll beat you. Madhu Kohli and Sumant Sharma [activists involved in organizing protests among the displaced] are the ones that cut your crops and got you sent to Jabalpur.
Villagers told us that this type of response from NTPC was typical.
In reporting these responses of villagers, we want to stress that we understand the crucial role NTPC plays in the lives of people, not only in the Singrauli area but throughout India. To its credit, NTPC has taken over many functions usually reserved to local government agencies in this rural and impoverished region. In providing some infrastructure and certain services, such as road maintenance, it has improved the quality of life for many Singrauli residents.
The division of labor between NTPC and other government institutions in Singrauli, however, has caused some confusion. Many displaced claimed that they have "fallen between the cracks" as NTPC and other government institutions each claim that the other is responsible for providing particular services, maintenance, or infrastructure to the resettlement colonies. These lines of responsibility should be clarified in a manner that assures the provision of basic services to local residents and the displaced.
NTPC also appears to exercise important influence over crucial government agencies in the Singrauli area such as the police and the judiciary. These agencies play critical roles in the protection of human rights of the displaced. The important relationship between NTPC and government institutions, as well as the de facto replacement of the state by NTPC in many areas of administration, should be considered when developing strategies and recommendations to promote human rights of the displaced in Singrauli and elsewhere in India.
As the key financial backer of NTPC, the World Bank should work closely with the Indian government and NTPC to assure that past abuses against displaced persons are addressed and that the likelihood of future violations is minimized.
Many of the violations of civil and political rights noted by Human Rights Watch appear to have emerged due to conflict between the displaced and NTPC over resettlement related to Bank-financed projects. Any measures that can be taken to rebuild confidence and trust between displaced persons, NTPC, local authorities, and the World Bank itself and defuse rising tension in the Singrauli area would clearly be highly desirable.
In this regard, we want to again underscore the importance of the Independent Monitoring Panel which has already conducted at least three on-site investigations since January 1998. From our interviews with two members of the three-member panel, we understood that the mandate of the IMP involved looking at some of the incidents described in this memo as well as monitoring implementation of resettlement measures. We also want to stress the importance of the study undertaken by XIDAS, which has conducted a detailed technical assessment of the impact of the project, the adequacy of resettlement measures and the validity of the complaints made by local residents. We urge the Bank to give the recommendations of the IMP and XIDAS the highest priority.