Background
Forest-dwelling communities share a deep relationship with nature, but more than that, they bear witness to history and provide insight into the management of forests. According to the State of Forests Report of 2019, approximately 300 million people are dependent on forests in India (PIB Delhi, 2023). The romanticisation of indigenous, forest-dwelling communities often limits the generational accumulated knowledge that is born out of their dependence and coexistence with the forest. For many of these communities, their identities are tied to their ancestral rights.
Yet, this has been one of the most tenacious struggles for legal recognition of land rights. The rights of land ownership for forest-dwelling communities has remained the same as set under colonial structures for decades after India’s independence. However, the Forest Rights Act (FRA) of 2006 became a momentous piece of legislation in the recognition of the rights of the forest- dwelling communities.
The act that came into force in 2008, also known as the Scheduled tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, which recognized the rights of the forest-dwelling tribal communities and other traditional forest dwellers to forest resources (MTA, n.d.). The legislative intent and objectives of the act were to recognize the historical injustices against the forest-dwelling communities and to ensure land tenure.
However, a fact-finding committee by the Call for Justice Delhi found that the implementation of the FRA has been scattered, especially around community forest rights, even two decades after its introduction. The fact-finding report looked at select districts of five states, which include Maharashtra, which is considered a model for the implementation of the FRA, as well as Odisha, Chhattisgarh, Assam, and Karnataka (Call for Justice, 2024). The report observed that there was insufficient focus on community forest rights, and more individual forest rights claims were granted. In other states like Uttarakhand, the number of claims granted is staggeringly low, with only 2.7% of the titles being distributed respectively (Raman, 2025).
The situation has gotten more complex with the more recent developments. The Forest Amendment Act of 2023 further complicated land rights concerns by removing community consent for the diversion of forest land for infrastructure or industrial projects. It further weakened the definition of the term ‘forests’ and ‘deemed forests’, excluding nearly 28% of India’s forest cover (Aredath, 2023).
The effects have been visible through the struggles of the forest-dwelling communities. Recently, in Odisha’s Sijmali region, Adivasi and Dalit communities protested against the bauxite mining by Vedanta Limited, resulting in police arrests and the forceful removal of these communities (Padhi, 2026).
In recent times, it has become increasingly clear that legal frameworks, including the Wildlife Protection, the 2023 Forest Conservation Amendment, and even the recent Green Credit programme, have been built with an exclusion of the forest-dwelling community simply by not acknowledging the FRA’s guarantees. This paper questions that exclusion. It examines the gap between the Forest Rights Act promises and the legislative and bureaucratic forces working against it.
Protests & Eviction
Odisha is home to the third-largest tribal population in the state. As per the last Census, the total number of Scheduled Tribes (ST) in the state is 95,90,756 (PIB Delhi, 2026). It has also been recognized for its exceptionally rich mineral value with immense reserves for iron ore, bauxite, chromite, coal, and minerals, which have led to drastic mining expansions (MoM, n.d). In the fiscal year 2024-25, the mining of mineral resources in Odisha reported a total value of INR 64,785 crores, contributing 9.5 percent to the state’s Gross State Value Added (GSVA) and 23.1 percent to the industry gross value added (GVA) in 2025-26, supplying minerals such as chromite, bauxite, and iron ore ( Government of Odisha, 2026). Behind these numbers are conflicts and tensions that emerge from these expansions of mining projects.
The Adivasi and Dalit communities in Odisha’s Sijmali region have protested against the bauxite mining project, and have been met with intense police action and midnight raids in the villages of Kantamal and Talaampadar, leading to the arrests of more than 21 people. The villagers have also reported the loss of important documents, including Aadhaar cards and Voter IDs. (Padhi, 2026). Ground reports have also noted the role of indigenous women in leading the protests and protecting their homes (Rao, 2023; Sahu,2026). The women have collectively and religiously attended public hearings regarding the projects and raised objections, which they consider violate the FRA 2006, Land Acquisition Act, and the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation, and Resettlement Act 2013 (Rao, 2023).
