This article is written by Shweta Pathania, from Uttaranchal University (Law college) Dehradun.
“Reservation is not a poverty alleviation programme, reservation is a nation-building process.”
Table of Contents
Introduction
The bible of the India “The constitution” binds the people of India together in robust ties maintaining the same the government had put into force many provisions observed through amendments. So residing in country like India where emphasis is given on “unity and diversity” we can’t lead a major portion of our country to face the repercussions of historical oppression and hate crimes. So the provision for reservation got here to furnish justice to such people.
Meaning of the term ‘reservation’
According to Justice Chinappa Reddy “reservation is not a charity it is representation”. Reservation sometimes denoted as ‘affirmative action’ it refers to the action taken by the state to uplift the stipulations of underprivileged sections of the society and reduce the disparities.
Historical background of reservation in India
It ought to be stored in thinking that the policy of reservation is a lengthen notion since pre-independence it is prevailing in our society. In ancient period according to Hindu subculture, the society was once divided into 4 varnas which had its origins in the Rig Veda. The Brahmins secured the absolute high-quality region of honour and repute in society they have been viewed as educated category accompanied by skills followed by the Kshatriya warriors type followed through the Vaishya the enterprise category at the backside has been the Shudras whose responsibility was to supply help to the above three classes. The least favourably placed classification have been ati-shudras/dalits who have been viewed as untouchables or the impure caste had suffered from quite a number ailments and have been denied all rights and privileges.
Why caste-based reservation and not on economic basis
To reply this query we should first apprehend why the want for the reservation has arisen. Reservation is based on the notion of equal representation moreover it is being used as a strategy or as a compensatory exercising to overcome discrimination and exploitation brought about by means of caste device and caste hatred towards the SC, ST and OBC’s. The exploited disadvantaged caste were denied any kind of sovereign, socio-economic, political and spiritual rights. They were denied any customary rights and even educational institutions have been closed for them. They were pressured to live in small segregated and unhygienic condition.
Example: Mahar the untouchable caste have been forced to tie a broom with their back so that their footprint got erased when they walk accordingly it is evident that even their shadow was once believed to be untouchable. Even nowadays if one is getting beaten up or one has been raped or if one is not allowed to sit down in bus or one is now not allowed to enter in temple or mosque or one is now not allowed to function the last rites of his family member due to the fact he belongs to a particular caste or sub-caste. From such atrocities, the backwardness of such a populace can be estimated. So in order to compensate and overcome the disabilities for the historical denial castes and have shield in opposition to caste exploitation the solution has to be designed on the basis of caste only.
Early referenced to schedule caste
‘Chandalas’ and ‘Panchamas’ had been the terms used at some stage in the Rig Vedic era for the schedule caste. Simon Commission used the term ‘untouchables castes’ representing the schedule caste. During the government of India act 1935, agenda caste appeared.
Pure/Impure concept -We understand that “untouchability” is an output of the caste system that predominated the Hindu society at some point of a long time ago. Many eminent social reforms such as DR BR Ambedkar, Jyotiba Phule, Raja Ram Mohan Roy and others laboured tirelessly to eradicate untouchability. The practice of this strategy leads to a certain stigma:
- Deprived of the rights including, socio-economic, cultural, education rights.
- Repudiation of possibilities and many different platforms.
- It was once a far-fetched question to ask their opinions, they were even now not allowed to participate in decision-making.
It means that one form of debarring leads to another kind of deprivation. Further adding to them: poverty, ill-health, disability, etc.
Dr Ambedkar in his essay; “Mukti Kaun Pathe?” said:’untouchability’ is nothing but concrete inequality. Such a living example of inequality is to be found nowhere. No where at no point of time in the history of the world can we find such inequality which is more intense than untouchability…
Mahatma Gandhi regarded this practise as ‘a leper wound in the whole body of Hindu politics’.
Harmful consequences of the practice of untouchability-
Untouchable encompass person who:
- Decompose dead animals.
- Work as a manual scavenger.
The corrupt exercise of untouchability has segregated our society and also resulted in division of society into ‘pure’ and ‘impure’ groups. The factors ‘purity’ and ‘pollution’ have been temporary at varna system, grew to become permanent beneath the caste system and from here itself untouchability emerged. Because of the consistent practice, some multipotential people are deprived of possibility at one-of-a-kind stages and this has resulted the wrong people in unsuitable occupation, also the Nation has been deprived of making use of such talents. Therefore the inflexible caste mechanism acts as a barrier to top of the line productivity. Because of untouchability, the sentiments of the fraternity are slowly disappearing and hostility, hate, crime against dalits have taken their place.
National Crime Records Bureau data: Insults and humiliation made up 50% of crimes against dalits. Country wide 43,203 cases of atrocities against dalits were reported in 2017, about 6% more than in 2016. Cases preventing a dalit from using public space and social boycott were reported from Maharashtra, Himachal, Punjab, UP. Untouchability is like a termite, the society is being hollowed out day by day and it has given birth to the ‘reservation system’.
The self-image of the minorities has damaged it has inculcated inferiority complexion, lack of self-assurance which straight away assaults the personal growth of such castes. Untouchability is a black spot on the Hindu society. As Gandhiji said ‘it should become a thing of the past’.
Abolition of untouchability – Article 17
It is included under part lll of the constitution which guarantees the basic fundamental rights (right to equality). Our constitution does not define the term ‘untouchability’ but under article 17 provides: abolishment and forbidden practise of untouchability in any form also provide for punishment.
By virtue of article 35 parliament has the power to enact the laws for abolition of untouchability. Under this parliament enacted the following acts:
- The untouchability offence act 1955.
- Untouchability offences amendment act, 1976 ( Civil Rights Protection Act).
- The Scheduled Caste and Scheduled Tribe prevention of atrocities act 1989.
Case: Devarajaiah v. Padmanna AIR 1958 Mysore 84 (Vol. 45. C22)
It has been observed by the Supreme Court that “untouchability” under article 17 refers to practice developed historically in India.
A literal construction of the term would include persons who are treated as untouchables either temporarily or otherwise for various reasons such as their suffering from an epidemic or contagious disease or an account of social boycott resulting from caste or other disputes.
Reservation in ancient era (A brief study)
During the contemporary era in 1932, Dr. Bhim Rao Ambedkar who attended the 1st round table convention on behalf of the minorities demanded abolition of untouchability and demand for separate electorate for the Dakota. Mahatma Gandhi had begun fast-unto-death satyagraha in opposition to the ‘communal award’ conceded via the PM of Britain Ramsay MacDonald.This conflict was settled and it resulted in the well-known Poona Pact 1932. Reservation of 78 seats was provided beneath this settlement instead for a separate electorate. In early 1902 for the upliftment, to provide free education, employment possibility and the abolishment of untouchability against the dalits the king Chatrapati Sahuji of Kolhapur added reservation and created 50% of reservation in the State Kolhapur.
Reservation in India
- legislature- L
- Government jobs- J
- Higher educational institutions- E
Some of the events that took place were related to reservation policy-
- 1901- By Chatrapati Sahuji once introduced reservation in Maharashtra.
- 1902- Shahu Maharaj of Kolhapur gave reservation to non-brahmin backward classes.
- 1909- separate electorate to the Muslims, Hindu, Landlords.
- 1909- In government of India Act 1909 provision for reservation was made.
- 1921- Reservation including 44% for non-brahmins,16% for brahmins, 10% for Muslims, 16% for Christians in Madras by the government.
- 1935- The famous Poona Pact resolution was made by congress for having the separate electorate for dalits.
- 1947- Chairman of drafting committee BR Ambedkar he fixed the reservation for 10 years mainly with a purpose to make certain political representation of SC/ST and in the hope that inside this duration untouchability would end.
- 1951- Seats reserved to SC/ST in Lok Sabha and state legislature.
- 1982- Reservation in central government jobs to SC/ST (15/7.5%).
- 1992- Reservation in central authorities jobs to OBC’s (27%) based on Mandal commission report of 1978 (in Janata government), tried to provide 10% to economically poor in upper castes like now, but Supreme court docket revoked it.
- 1992- Indra Sawhney case, where the Supreme Court fixed maximum limit of reservation 50%.
- 1992-1993- 73rd and 74th constitutional amendments reserved seats to SC, ST, women in local government (mandatory), to OBC (optional: states wish).
- 2006- Reservation in higher education institutions to OBC.
- 2019- Reservation in greater schooling establishments and central authorities jobs to economically terrible in the top caste (including minorities).
- Now: SC/ST- 15/7.5% (L, J, E).
- OBC- 27% (J, E).
- Economically upper caste poor section 10% (J, E).
Different states follow different models:
- Tamil Nadu – reservation is up to 69% (SC 18%. ST 1%, OBC 50%) and was included in the 9th schedule.
- Maharashtra – on 2014, 25th June congress – NCP government had approved 16% reservation for Marathas and 5% for Muslim.
(In the case of public employment for backward classes under 2001 State Reservation Act – 52% of reservation).
- Haryana – an act passed on 26th May 2016 gave 10% reservation to jats, 10% was given to backward classes of general category.
- Telangana – Assembly passed a bill on 16 April 2017 giving 6% to 10% for backward classes and for backward classes among muslim 4% to 12% respectively.
Constitutional provisions governing reservation in India
- Part XVI deals with reservation of SC and ST in Central and State legislatures.
- Article 15(4) and 16(4) of the Constitution enabled the State to reserve seats in government offerings for the participants of the SC and ST.
Constitutional amendment:
- For the reason of reservation in matters of promotion of SC and ST clause (4) was once inserted in article 16 by 77th amendment act 1955.
- Through the 81st amendment act 2000, the authorities brought article 16(4B). The modification allowed reservation in promotion to 50% upper restriction which is set on a regular basis. The authorities were empowered to raise ahead unfilled vacancies from the preceding year as a separate type vacancy to be stuffed up in any succeeding year.
- 85th amendment (2001)inserted article 16(4-A)it extended the gain of reservation in choice of the residents belonging to the SC, ST as it empowers the nation “to furnish quota in promotion with consequential seniority”.
Reservation in India
Representation in legislative seats: Political reservation was given for 10 years and it can be extended through the capacity of the authorities from time to time. It is mischievous propaganda by people with a vested interest that reservations in education and jobs had been only for 10 years.
The fundamental objective of the reservation is to handle the historic oppression, inequality and discriminated face of these communities. It is supposed to enhance the social status and uplift the position of underprivileged committees and promise of equality enshrined in the constitution.
Reservation according to Constitution of India:
- Part 3 (Fundamental Rights) Article 15 clearly mentions “prohibition of discrimination on grounds of religion, race, caste, sex or place of birth or any of them.
- Part 4 (DPSP) Article 46 gives directions to the State to make special provisions for SC, ST and other weaker sections of the society.
So, here a conflict arises between the two articles.
Champakam Dorairajan case AIR 1951 SC 226
The Supreme Court held that whenever there will be a conflict between the part 3 and part 4 of the constitution. Part 3 will always prevail.
- So, now here the question arises whether special provision under article 46 shall be given?
If we look back during the time of independence approx 22.5% belonged to the SC, ST and in the race for development they have been felt far behind. So, Dr BR Ambedkar said for the reservation for “level Playing field” i.e equality. So, the special provisions under article 46 was giving “level Playing field”.
- Another question arises on which basis the weaker sections defined?
As the weaker sections could include the children, old people, financially weaker people.
1st constitution amendment act 1951: inserted article 15(4) according to which the state can make special provisions for SC, ST and backward classes of society.
Caste and politics
Casteism in politics is the first and foremost thing for us to understand because the reservation system has arisen somewhere through casteism. Since centuries the Caste has not affected several aspects of Indian society but also dominated Indian politics. The relationship between caste and politics reveals the politicised nature of caste in Indian politics:
- Besides voting, caste is an important factor influencing the selection of candidates in the election.
- Political bargaining is also done in caste lines.
- When political parties make the candidate stand on election they supply preferences on the foundation of caste sentiments.
- The events directly strategy the caste or neighbourhood leaders and they themselves inspire the use of caste, creed in politics.
- Besides voting, caste is an important thing influencing the decision of a candidate in an election.
- Political bargaining is additionally finished in caste lines.
As quoted by the scholar Rajni Kothari ‘it’s not politics that get caste-ridden, it is caste that gets politicized’.
In a society such as India, the caste has become the primary channel through which the parties secure their position and vote within the political system. People belonging to a specific caste play a key role to decide for the candidate in an election representing their respective caste intention in the lower back of is that the chosen candidate will work in the path of the betterment of their community.
Example – 1971 elections was completely on the basis of support from the caste who aligned together and voted for the Congress.
- Bihar and Jharkhand – Almost all the top leaders inclusive of Mr Rajendra Prasad, A.N Singh, S.K Sinha had been connected with their response caste associations.In 1957 elections most seats were reserved for tribal and backward sections. In Bihar in 1978 CM Karpoori Thakur added a measure of reservation of government jobs for backward classes.
- Andhra Pradesh – It is clear that casteism and politics run parallel to each other in Andhra Pradesh. Casteism was so tremendous that until 1971 the Reddys were the single greatest crew (28% to 38%).
- Haryana – The two principal elections that took place in 1967 and 1968 the purpose at the back of the victory was once truly evident due to the fact the elections had been definitely primarily based on caste politics.
Institutions: the panchayat System and reservation
Panchayat means an institution of self government constituted under article 243(B) for the rural areas.
The constitution provides for reservations of seats for SC and ST in every Panchayat under article 243(D).
Who is entitled to reservation?
In the Indian constitution the article 15(4) added by 1st amendment act 1951, the state has been empowered to make any special provision in respect of the following classes of person-
- Scheduled Caste
- Scheduled Tribe
- Socially and Educationally backward classes
The above-noted class constitute underprivileged who have been exploited, suppressed, humiliated and deprived of equality, liberty and justice in various spheres of life.
Our Indian constitution though cited about socially and educationally backward lessons however now not true defines nor lays down any unique criteria for determining them. Even in article 341 and article 342 their definition is not properly disclosed. The post constitution list such as the SC, ST and backward instructions was once detailed through the President through order in 1950. Thus the Parliament is also empowered to amend that list from time to time.
The SC 15.74% and ST 7.8% population. About 52% of them constitute the agricultural labourers and 28% are marginal farmers and sharecroppers.
The commission was set up in 1978, it was renamed as the National Commission. The motive at the return of putting up the commission was once that it would work for their safeguards, rights, work for their socio-economic enhancement and will take exquisite measures for their protection and welfare.
Kalelkar Commission: For backward classes, 1st commission was appointed by the means of President on twenty-ninth January 1953 under the chairmanship of Kaka Kalelkar. It prepared a list containing 2399 and out of which 837 had been categorized as ‘most backward’.So, according to the list prepared, 930 alone accounted for an estimated population of 11.5 crores and SC, ST populating according to the 1951 census. It submitted 25 evaluations on March 30,1955 and in accordance with it an essential standard for identification of backward classes used to be based totally on their low social feature in the caste hierarchy of Hindu society.
Some noteworthy recommendations are:
- They considered women as a class to be backward.
- Reservation of vacancies in all government services on the following scale: class I- 25%, class II- 33%, class III and IV 40%.
- Reservation of 70% of seats in all technical and professional institutions.
The above recommendations were made keeping in mind the following factors which include the efficiency and running of administration, machinery, the interest of the state. Education performs an indispensable role as it emphasises on the reservation on educational institutions and employment so as to grant the chance to the backward area alongside with the general categories.
Government action on commission report
Census:
Comparison of the list of OBCs by the various state government and those prepared by Kalelkar commission:
Name of state Commission list Government list
- Haryana 88 64
- Tamil Nadu 156 124
- UP 120 56
- Kerala 48 76
- Himachal Pradesh 27 48
- Assam 44 119
- Karnataka 64 181
- Andra Pradesh 124 95
Reason for disparity in the list is the state government prepared list on the basis of field survey and investigation while on the other hand the commission mostly borrowed the list prepared by the ministry of education. So the commission recommendations were rejected by the government.
Government view if, bulk of the country’s population be viewed as backward the in actuality needy ones would be swamped away through way of the advantages, therefore, it would be of no simply really useful reason to grant separate remuneration to such classes nor they will reflect on consideration on any tremendous attention.
The caste requirements and fixing the proportion in any vacancies entirely on the groundwork of caste by using the rate approach regarded arbitrary to the authorities as this would upward shove the seeds of enmity and feeling of discrimination amongst one of a sort communities.
Mandal Commission: Under article 340 in January 1978, another commission for the backward section was shaped underneath the chairmanship of BP Mandal by using the presidential order.
Estimated Population of OBCs – The commission led two standards for figuring out non-Hindu OBCs:
- All untouchables of society transformed to any non-Hindu religion.
- And the ordinary hereditary occupational communities including – dhobi, lohar, dargi, nai, gujar etc.
The commission came to the conclusion that the total population of Hindu and non-hindu obcs added up to nearly 52% (43.70 + 8.40)of the total population.
Quantum and scheme of reservation –
S No. Group name % of the total population
1 SC 15.05
2 ST 7.51
3 OBC 22.56
A pro-rata reservation in all services and public sector for the SC and ST. On the other hand the OBCs constitute 52% of the total population but if this pro-rata reservation would be fixed for them than it will go against the law laid down in a number of SC judgement and also clearly mentioned in our constitution in Article 15(4) and Article 16(4) respectively that the percentage of reservation should not exceed 50%. So the commission recommended a reservation of 27% although their total percentage was 52% this reservation was to be applied to all government services both in the centre and the state.
Should creamy layer be adopted in SC and ST?
If a person is financially affluent then it does not mean he will not be discriminated on social and caste grounds.
Example: On 18 march, 2018 Jagannath temple priest in Odisha raised robust objections closer to the President Ram Nath Kovind entry into the temple as he comes from the depressed class.
Judicial pronouncements:
1) Indra Sawhney AIR 1993 SC 477: (also known as Mandal commission case) decision given by the 6:3 majority observed that:
- A 27% reservation for OBC with certain conditions was upheld as constitutionally valid.
- Among the OBC (the creamy layer) ought to be excluded from the list of beneficiaries of reservation.
- No, reservation in promotion.
- Total reserved quota has to not exceed 50%.
- Backward classification of citizens can be identified on the foundation of the caste system and no longer on financial basis.
- Reservation can be made beneath article 16(1).
2) State of Madras v Champakam Dorairajan AIR 1951 SC 226: The Supreme Court verdict held that providing reservation on the basis of caste was in violation of article 16(2) of Indian constitution.
3) M Nagaraj v Union Of India on 19th October 2006: In this case, the constitutional validity of 77th, 81st, 82nd, 85th amendments act were challenged. The Supreme court upheld the constitutional amendments as legitimate and supported reservation in promotion however alongside this requested the states to comply with surely standard while giving reservation in promoting:
- Backwardness of community.
- Inadequacy of representation.
The court additionally upheld that reservation in promotion is an enabling provision and also the administrative effectivity is not to be altered while giving reservation. Similarly, the court held that the states need to accumulate quantifiable records showing the backwardness earlier than providing them quota in the promotion.
3) Jarnail Singh v. Lachhmi Narain Gupta on 26th September 2018: M Nagraj case reviewed in this unique case. The Supreme Court positioned that due to the reality the SC and ST are presumed backwards so there is no such requirement through the capability of the authorities to acquire quantifiable facts for providing them quota in the promotion.
5) Chebrolu Leela Prasad Rao v. State of Andhra Pradesh on 22nd April 2020: The supreme court held that a 100% reservation unconstitutional as it was as soon as discriminatory in the path of no longer, in reality, open category candidates alternatively moreover in opposition to agenda caste and different backward classes. Judgement surpassed through a 5 judge constitutional bench headed by way of Justice Arun Mishra quashed the authorities order issued with the aid of the governor of Andhra Pradesh had allowed a 100% reservation.
Present Status
The reason at the lower back of the reservation used to be quiet clear to abolish the discrimination and to correct advantageous injustice which had been practised for plenty of years. To restore that it was once thought to provide reservation for a tremendous duration of time to certain segments of people an greater gain for their upliftment and betterment so that they can live with admire and dignity and ought to stage up with the leisure of society. Unfortunately, the vision with which this workout used to be started has now stopped handing over the liked effects. The upliftment and betterment of the weaker sections appear to be someplace missing behind. No, work is being finished in their interests.The truth that reservation has flipped out to be a provision for political activities for their vote banks additionally can not be ignored.
According to the 2011 census about 79.5% of SC/ST people live in rural areas and rest 21.5% in urban areas. Thus the 21.5% of them are benefited from this policy and the rest of them who really need it are left out.
At present 22.5% of the government jobs are already reserved for the SC and ST on the pro-rata basis of them, share in the population.
To point out the politics and the political occasions for boosting or advertising the questioning of the reservation is no longer totally proper to accuse them. Because people also need to understand. If we take an example: when a candidate stands in an election then the people have to not vote for him by searching at his caste or background. It may also additionally be doable that the deserving candidate lags behind. In return the candidate belonging to any caste not lift a caste feeling and overriding loyalty to their caste.
The situation of the SC and ST continues to be pathetic in spite of the numerous constitutional protections and one-of-a-kind programmes for their welfare neither the ban on untouchability nor reservation of jobs had made the harijans lot any better. Untouchability continues to be practised in one shape or the different especially in the rural areas of the country especially in the regions of Bihari, Orissa, Uttar Pradesh, Rajasthan, Karnataka and Tamil Nadu there have been conditions of discrimination in opposition to the SC’s they are still oppressed and facing the repercussions of history where the privileged class act as a barrier for their mobility in socio-economic ladder. The SC are no longer allowed to draw water from faucets used by the hindu and are also averted from getting into the temples. In some places they are denied the offerings of washerman, barbers and so on and are nevertheless compelled to pursue their age historic unclean occupations due to socio-economic reasons. The untouchability offences act which offers for imprisonment and punishment who practise discrimination is usually on newspaper and other social networking sites mainly in rural areas. 2018, witnessed the most religious hate crimes, deaths particularly towards the minorities.
In the words of B.N.Singh Former Assam Governor- “Dr. B.R.Ambedkar fixed the limit of reservation for 10 years in the hope that within this period untouchability would end and a new social order would emerge. We are still trying to solve the problem and fixing another limit, the end of the century to finally abolish scavenging which is the worst form of untouchability in the country”.
Critical analysis
The integral cause of reservation is moving in the contrary direction someplace demarcating the society. An eligible candidate need now no longer to exhibit his calibre with the aid of means of a mere certificate of being from a lower or backward caste. Through his ability and credibility to compete, he can lift change in his life. Grabbing a job via in simple phrases exhibiting underneath privileged certificates may additionally now not get them somewhere and in a roundabout way it will make a contribution to promote reservation.
Conclusion
If the reservation policy continues to run like this, it will soon end up a discriminatory process. The policy needs to be reviewed every year and a survey be conducted to find out whether the simply needed ones among the” backward” are getting benefited. It is additionally a responsibility of SC and ST members that if any-one unique vicinity among them is getting the gain of reservation from generation then this gain must be given to barring a doubt indigent ones. Because, it can also be additionally possible that among them the virtually needy are even now not conscious about the benefits.
The want is now not only for financial equality, but there is also a lot of need for mental change, and for this education is most essential it can be only feasible via education that basic human values are inculcated. Awareness at a huge scale has to be organized through mass media spreading focus on education and about the reservation policy. Building up a robust public opinion in opposition to the evil of untouchability is essential. The so-called upper castes also need to make a contribution by way of helping the backward castes to achieve the essential flow of society by encouraging them to increase their moral.In case of any sort of discrimination with the backward classes, the upper castes ought to come beforehand and protest against it. There is additionally a want the people belonging to the SC and ST need to come forward and say that they are self-dependent and competent enough that they no longer need any reservation.
Reservation is a systematic problem functional at a big scale and it can be solved solely at a systematic stage with the aid of addressing the inequality. Discrimination and oppression due to the truth of caste are no longer felonies however it happens on the other hand. This means that it is the moral responsibility of the system itself to correct for its incompetence. At the same time we need to by no means forget that it is a democracy. We can’t lead society to be segregated in this excessive manner, and we have to ensure that each individual is getting equal opportunity.
References
- Dr BR Ambedkar “Annihilation of Caste”.
- Narendra Jadhav “Ambedkar Awakening India’s Social Conscience”.
- HM Seervai “Constitutional law of India”.
- MP Jain “Indian Constitutional Law”.
- Subrata k Misha “Politics in India”.
- Vidhya Bhushan, DR Sachdeva “An Introduction to Sociology”.
- SP Aggarwal, Suren Aggarwal, JC Aggarwal “Educational and social uplift of backward classes”.
- Vishnoo Bhagwan, Vidhya Bhushan “Indian Administration”.
- Government of India report of backward classes commission 1st part volume I and II 1980.
- The Constitution Of India bare act.
- Crimes against the dalits available at https://indianexpress.com/article/explained/ncrb-data-insults-made-up-50-of-crimes-against-dalits-traps-of-corrupt-officials-spiked-6082791/
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