Case Comment on Nandini Sundar & Ors Vs. State of Chattisgarh [AIR 2011 SC 2839]

Anita Yadav
Asst. Professor
Campus Law Centre, University of Delhi
Delhi, India

Volume II – Issue II, 2019

The case dealt by me is Nandini Sundar and Ors vs. the State of Chattisgarh (hereafter the ‘Salwa Judum’ judgment).This is one the important case to understand how Indian Judiciary has analysed the legality to use special police officers (SPOs) during armed conflicts between Indian government and a Maoist/Naxalite in Chhattisgarh. Instant case was brought to the Supreme Court through writ petition in 2007. This case was decided by Hon’ble Division Bench of a Supreme Court (Hon’ble Justice B. Sudershan Reddy and Justice Surinder Singh Nijjar).The primary concern of the Court in this case was to analyze the Constitutional validity of the appointment of tribal people as special police officers (SPOs) by State of the Chhattisgarh Government to counter the insurgency.


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