Friday, 29 January 2010

Rights Based Entitlements in India

Mandakini Devasher Surie

In recent years, rights based people's movements have had considerable success in gaining legal recognition for basic rights and services such as the right to education, food information etc. According to Pratap Bhanu Mehta, "The rights movement rose against the backdrop of state failure. What people are groping for is different instruments through which the Constitution's objectives may be realized.” Summarised below are some examples of basic rights that have found legal recognition in recent years:

Right to Education
The Right of Children to Free and Compulsory Education Act (Right to Education Act (RTE) in short) was passed by Parliament in August 2009. The Act gives effect to the 86th Constitutional Amendment Act 2002 which requires the State to provide free and compulsory elementary education to all children. The RTE Act guarantees free and compulsory elementary education for all children between the ages of 6-14 years. Government schools are required to provide free and compulsory education to all children admitted while aided schools are required to provide free and compulsory to a minimum of 25% of enrolled children. Under the Act no child shall be held back in class, expelled or required to pass a board exam until his/her elementary education is complete. The physical punishment and mental harassment of children is prohibited under the law. The Act also makes provisions for schools (government and unaided) to admit at least 25% of students from SCs, STs, low-income and other disadvantaged groups. The Government has recently framed model rules for implementation of the law.

Right to Food
To combat the challenges of hunger, starvation, malnutrition and food insecurity, the Congress Party in its 2009 Election Manifesto promised to enact a “National Food Security Act” to provide 25 Kgs of rice or wheat at Rs 3 per Kg for Below Poverty Line (BPL) families. However, the draft “National Food Security Bill” has been extensively criticised - in particular for limiting the list of beneficiaries to BPL households. Right to food campaigners and activists are demanding a more comprehensive “Food Entitlements Act” which goes beyond the limited provision of 25 kgs of grain at Rs 3 Kg for BPL households. Key provisions of the proposed “Food Entitlements Act” include: a universal Public Distribution System (providing at least 35 Kgs of grain per family); special food entitlements for destitute households (including an expanded Antyodaya programme); consolidation of all entitlements created by recent Supreme Court orders (e.g. cooked mid-day meals in primary schools and universalisation of ICDS) etc.

Forest Rights Act
The Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 was passed by Parliament in December 2006. However the Act was officially notified into force a year later in December 2007, while the Rules for the Act were notified on 1 January 2008. The Forest Rights Act (as it is popularly known) recognizes and secures the forest rights of Scheduled Tribes and other traditional forest dwelling communities and provides them with a voice in forest conservation issues. Specifically, the Act recognises three kinds of rights: (i) land rights over land that has been occupied for cultivation or residence (ii) usage rights over forest produce and traditional knowledge and (iii) legal rights to protect and conserve forests. The Forest Rights Act has been criticized by conservationists who feel the law will hasten the depletion of India’s forest cover and wildlife. There are also serious concerns about how the Act is being implemented in different parts of the country.

Right to Information
The Right to Information Act 2005 (RTI Act) was passed in 2005 following a decade long grassroots and civil society campaign. Notably, even before its enactment into law, the right to information had been recognized by the Supreme Court of India as a fundamental part of the right to freedom of speech and right to life (Articles 19 and 21 respectively) of the Constitution. The RTI Act sets out practical regime for citizens in India to access information held by the government. It guarantees a legally enforceable right to information to all citizens places a corresponding duty on the government to provide information proactively and on request. The Act covers the whole country (with the exception of Jammu and Kashmir) and extends to all branches of the government. The legislation spells out a detailed administrative structure to facilitate citizen’s access to information including provisions for the setting up of Information Commissions to handle appeals and complaints.

Wednesday, 27 January 2010

JNNURM - A Work in Progress

Avani Kapur

As India completes 60 years of being a republic, one can’t help but look around at our towns and cities and wonder where we are heading. And as a resident of Delhi, the first thought that comes to my mind (maybe due to the infinite signs that plague Delhi roads in anticipation of the Commonwealth Games) is that we today are a “work in progress”. Open drains, pot holes, roads dug up, lakhs of homeless people struggling to stay warm in the extreme cold are all constant reminders that urban chaos is becoming a way of life. And as Prime Minister Manmohan Singh recently noted, “our cities and towns are not an acceptable face of a rapidly modernizing and developing economy”.

This is despite the fact that on December 3rd, Jawaharlal Nehru National Urban Renewal Mission (JNNURM), India’s comprehensive flagship programme for urban development completed four of its intended seven year tenure. This is no small amount of money –a total of Rs. 103,462 crores has been approved of which the centre has committed assistance of Rs. 55,625 crores, provided states and local bodies give their prescribed share of funds. However, the programme is running at a very slow pace, with not even a quarter of the projects completed and less than a third having got off the ground. To give a simple example, 14.59 lakh houses for the poor have been approved under the mission. However, so far only 1.80 lakh houses have been completed and another 4.38 lakh homes are under construction.

As more and more money gets pumped into the scheme (including a $1-billion loan which is currently being approved from the World Bank), serious questions need to be asked about state capacity and the ability of states to effectively utilize the money for urban development.

In particular, I would like to highlight three points that need careful attention as we move forward with JNNURM.

• First, Funds.
JNNURM works on a cost sharing model with centre, states and local bodies all having a prescribed share. Till March 2009, while states like Uttar Pradesh, Maharashtra and Tamil Nadu released over 70 percent of their share of funds, Madhya Pradesh and Punjab released just over half and Haryana only released 22 percent. Urban local bodies on their part too, have fallen behind. While Greater Mumbai and Hyderabad released over 80 percent of their funds, Chennai and Kolkata released only 24 and 18 percent respectively. Inability to release funds in time has resulted in significant delays to infrastructural projects. In Kanpur for instance, the repair work in the city, with a Rs 96.23 crore project allocated under JNNURM, is lying incomplete for the last three months due to a lack of funds. Reason: sanctioned funds from the state have already been used elsewhere.

• Second, Citizen Participation.
First principles of public accountability require that expenditures must adequately reflect citizens’ interests and priorities. Interestingly, citizen participation is embedded in the overall design of the JNNURM Mission. One mechanism is the creation of the National Technical Advisory Group, made of members of civil society. In addition, a Community Participation Fund (CPF) was also launched in September 2007 - to catalyze community participation by supporting the building of community assets. Moreover, states are mandated to enact community participation laws. However, while there is provision for about 1000 community projects under CPF, with Rs.90 crores already approved, only 21 projects have been sanctioned under this scheme for the mission cities as on May 2009, with 14 more awaiting approval. Even in terms of the enactment of the community participation law, out of the 26 states scheduled to implement it by the fourth year, only 8 have implemented it.

• And finally, Reforms.
In theory, these reforms ensure that governments at each level have the requisite autonomy, resources and power to carry out the duties assigned to them. In addition, they ensure accountability and efficiency. But in practice, these reforms have progressed very slowly. A quick look at the graph below indicates these inefficiencies. For instance, up to year 4, while 18 states had committed to implementation of the 74th constitutional Amendment Act (transfer of 12th schedule functions from states to urban local bodies), 8 states are yet to fully implement the reform. Similarly, while 29 states had committed to enact the Public Disclosure Law, only 15 states had successfully implemented the reform.

Another key objective of the JNNURM is to introduce e-governance in the municipalities to provide single-window services to the citizens, to increase efficiency and productivity of the urban local bodies (ULBs), and to provide timely and reliable management information. However, only 13 of 45 cities had enacted the reform.

In the coming years, as the quantum of money allocated for JNNURM increases, the pressure on states and local bodies to deliver will continue to increase. A careful look at the existing inefficiencies is therefore a priority – if our cities are to reflect our growth.

Avani Kapur is
Researcher and Coordinator of PAISA project at Accountability Initiative.

Thursday, 21 January 2010

Effect of Soaring Food Prices on Mid Day Meal Scheme

Sruti Bandyopadhyay

Mid Day Meal Scheme (MDM) is the world’s largest school-feeding programme aimed at promoting universalisation of elementary education by increasing enrolment, retention, attendance, and simultaneously impacting the nutritional status of students. It is learnt that besides rice and dal, MDM involves use of oil, vegetables, salt and spices and fuel. Keeping in view the rising cost of the commodities, effective from December 1, 2009, for primary schools the fund allocation norm for cooking costs has been increased to Rs. 2.50 per child per day(up from Rs. 1.58). For upper primary the allocation has been increased to Rs. 3.75 per child per day (up from Rs. 2.08).

However, the existing cost norms and the subsequent revision is based on overall inflation figures, not specifically on the costs of commodities used in the meals. Overall inflation statistics can hide the fluctuations in the prices of specific commodities relevant to the meal costs. The point becomes all the relevant as the country is now witnessing rising food prices despite negligible inflation. (Overall inflation is 7.31% in December)

Price rise of some essential food items (52-week period, in %)

Pulses.................... ...42.21
Onions..................... 40.07
Cereals................... 13.91

Source: (IANS), Week ended on December 26, 2009

The current procedure for revising the costing norms acts as a further roadblock to realistic pricing. Any revision needs to be approved by the EFC and the cabinet each time - after seeking comments from all relevant ministries - in a process that can take up to a year. By the time the cabinet approval is obtained, the revised norms become outdated and the exercise is redundant.

Instead, a mid-day meal pricing index which would consider fluctuations in the prices of five items essential to the scheme seems to be a better idea to tackle this soaring price inflation.
Sruti Bandyopadhyay is a Research Associate with the Accountability Initiative

Wednesday, 20 January 2010

Pratham Launches its Annual Status of Education Report 2009

Pratham's Annual State of Education Report (ASER) 2009 was launched last week. ASER is a path breaking effort at monitoring outcomes and pushing for accountability from government for monies spent. The report is based on a study of 575 rural districts in India and covered 16,291 villages, 338,027 households and 6,91,734 children. The annual survey found that while 96% of children in rural India in the age group of 6-14 years are now enrolled in school, the quality of education is still quite poor with just 69% of Class I students in rural areas being able to recognize numbers between 1 and 9. The report also points to the rise in private tuitions across the country. From 2007-2009, the percentage of children taking tuition classes in every class in government and private schools. To know more about the report and its findings click on the news links below:

Money for Nothing

Yamini Aiyar and Anit Mukherjee

Elementary education policy in India is, as economist Lant Pritchett characterizes it, in a ‘Big Stuck’. Stuck because despite money being poured in to the system – funding for elementary education has had a five-fold increase since the launch of the Sarva Shiksha Abhiyaan (SSA) in 2001 - outcomes remain poor. As the Annual Survey of Education Report reminds us year after year, about half of India’s children in standard five cannot read a standard two level text book and far fewer can do basic mathematics. Getting out of this morass requires a system overhaul that creates a performance based, accountable delivery system.

How can this be achieved? A crucial step towards creating an accountable system is to ensure accountability in financing. With the imminent implementation of the Right to Education Act (RTE) which is set to significantly expand education finance –the RTE will cost the exchequer Rs. 43600 crores - ensuring accountability is critical.

First principles of public accountability require that expenditures must adequately reflect citizens’ interests and priorities. When it comes to basic services, citizens’ interests are best captured locally at the point where services are delivered. This means greater local autonomy and discretion, particularly in resource allocation.

The current system of education financing allows little room for autonomy. Schools have no discretion over funds that arrive tied to rigid norms determined by the center and states. These norms also determine the quantum of funds schools receive resulting in a mismatch between school needs and funds received. For example, a school with 1000 students receives just about two and a half times more money than a school that has 100 students. And if a school wants to spend more on teacher materials than painting walls – the norms simply won’t allow it.

Autonomy apart, accountability also requires transparency and predictability in fund flows. After all, you need to know how much money is due and when it willarrive in order to make plans and hold the system to account. This is one of SSA’s greatest weaknesses. Between October and December 2009, an army of 25,000 Indian citizens joined the Annual Survey of Education Report to ask over 12,000 schools how much money arrived, when it arrived and how much was spent. The survey found that by October – half way through the financial year - more than 50 percent of the schools surveyed reported not receiving SSA funds. These findings are also reflected in macro level data- 63 percent of SSA funds in 2008-09 were spent in the second half of the financial year.

Delays are due to many reasons – delays in releases from the state governments, delays in process as the funds travel through the different administrative layers. And often they are a result of administrative lethargy. Here’s an interesting story - in some schools in Sehore, Madhya Pradesh, funds had not reached till mid-November. The reason, the State government was converting to an electronic system so that funds could be transferred at the click of a button and delays avoided. A noble cause that took an inadvertent amount of time to implement because local banks had capacity for 4 digit electronic transfers and this particular transfer required 10 digits. No interim measures were put in place to ensure money reached while these kinks were being sorted out and the schools suffered.

Whatever the cause, delays proliferate because of the lack of transparency in the system. ASER data indicates that in many schools even the head master is not aware of the different grant components, when they should arrive and what they ought to be spent on. In the absence of information, schools, parents and children are disempowered as they lack the tools to make plans and demand accountability for delayed and unpredictable fund flows.

Resolving these problems and ensuring accountability in educational finance requires systemic reforms in the way educational delivery systems are designed. Crucially, the system will need to ensure genuine local autonomy. One way of doing this is to move away from ‘tied’, norm based funding to the provision of block grants calculated on the basis of the number of children enrolled and attending schools. Local autonomy must be accompanied with a process for collection and dissemination of real time information on fund flows and expenditures. This will ensure greater transparency and enable citizens to monitor processes and demand accountability.

Education policy in India today is at a crossroads. There is a clear consensus that improved education holds the key to India’s future and the passage of the RTE stands testimony to this. Now as bureaucrats take to their drawing boards to develop rules and guidelines for the implementation of the RTE, the focus must shift to getting the design right. Only then can we begin to unstuck the ‘Big Stuck’.

(Yamini Aiyar is with Accountability Initiative, Centre for Policy Research. Anit Mukherjee is with National Institute of Public Finance Policy. Both institutes work in partnership with ASER to strengthen accountability in education finance through a project called PAISA)

Friday, 15 January 2010

Video Recordings of the Accountability Initiative consultation on Civil Society and Accountability, December 2-3, 2009

Accountability Initiative held a consultation entitled Civil Society and Accountability on December 2nd and 3rd, 2009. The overall objective of the consultation was to debate the nature and effectiveness of civil society’s engagement with the state for accountability. In particular, it aimed to address the following key issues:

* Taking stock of existing experiments, understanding strengths and limitations

* Debating challenges of sustainability, institutionalization and effectiveness

* Identifying potential for replicability and scale

All of this was discussed in the context of whether and to what extent civil society’s engagement for accountability might contribute to strengthening substantive democracy in India.

The Consultation was attended by about 35 participants on each day. Participants included practitioners, policymakers and academics working on issues of accountability from around the country.

Some of the video recordings from the Consultation can be accessed below. More videos will be uploaded on our website soon.

Amitabh Behar, National Centre for Advocacy Studies

Shekhar Singh, National Campaign for People's Right to Information

Wednesday, 13 January 2010

Right to Information: Need for an Enforcement Strategy

Alasdair Roberts

The right to information is only meaningful if the law is properly enforced. We know this from common sense. Government officials who dislike the law will be tempted to ignore it if they believe that there will not be any consequences. Citizens will not make requests if they do not believe there is a quick remedy against stubborn bureaucrats.

The findings of some recent evaluations of the Right to Information Act are therefore worrisome. The report completed by the RTI Assessment and Analysis Group finds that information commissions received 86,000 appeals in the first two and half years of the law's operation, but issued only 50,000 decisions. Inflow exceeds outflow, and the result is a growing inventory of cases within some commissions, and delays in handling individual investigations. The special committee that reported to the Fourth National Conference on RTI last October found a "huge pendency in disposal of appeals and complaints" in some places. The PriceWaterhouseCoopers study on RTIA said that rapid growth in number of appeals is "creating a grave situation which requires urgent intervention."

India is not the only country to have encountered this problem. For example, the UK information commissioner also struggled with a backlog of appeals after the adoption of the Freedom of Information Act in January 2005. The advocacy group Campaign for Freedom of Information reported in June 2009 that one-third of appeals sat in the commissioner's office for at least two years. The Campaign warns that these delays could threaten the law's effectiveness. Citizens may become frustrated, and officials may exploit the fact that they can "safely withhold information for several years before the Commissioner compels disclosure."Canada's information commissioner also acquired a backlog of appeals in the late 1990s. Government departments were cutting their budgets and taking information requests less seriously. The inflow of appeals to the information commissioner rose, and the time required to resolve cases grew longer. Requesters became restless, and commission staff became demoralized.

Backlogs can develop for several reasons. One is a simple shortage of resources for resolving appeals. Another is lack of experience in handling a large number of appeals. In addition, the first cases received after adoption of a law may require more attention because they set important precedents. However, there is also a difficulty that is built into the design of every right to information law. Every law assumes that the main way to assure compliance is by resolving individual complaints and appeals. But if a commission cannot resolve cases quickly, bureaucratic incentives to comply with the law become weaker, yielding even more complaints and appeals. Under the right set of circumstances, the weakness of the enforcement process could become self-reinforcing.

The challenge is to find ways of breaking out of this cycle. One approach is to streamline investigations so that they can be completed more quickly. For example, the new UK information commissioner recently told his staff that they do not need to achieve a "gold standard" in decisionmaking in every case. This may mean less detailed investigations, less consultation with parties, or decisions that are less carefully reasoned. This approach is defensible, within bounds, but may provoke resistance from citizens or bureaucrats who believe that their concerns have been given short shrift.

Another approach is to apply heavy legal sanctions for non-compliance -- so that officials are less tempted to take the "de facto time extension" that is provided because of backlogs within commissions. Of course, section 20 of the RTIA provides the authority to do this, even though commissioners have been reluctant to use the power, especially against lower-level staff. In the late 1990s, the Canadian commissioner's approach was to use his formal investigative powers to take evidence from senior officials who could be held accountable for "systemic" problems. This caught their attention, although many officials were upset by what they saw as heavy-handed tactics.

There is also a third approach: a deliberate effort to identify and deal with parts of government that generate a disproportionately large proportion of a commission's caseload. Rather than resolving a specific appeal, a commission can push a department to cooperate in a study of internal administrative practices that seem to produce a large number of appeals. Again, the RTIA gives commissioners unusual authority (in section 19(8)) to follow this path. But this sometimes requires a different skill set, with more emphasis on management policies and less on quasi-judicial resolution of cases.

Indian commissioners, like their counterparts around the world, must develop enforcement strategies to cope with two enduring realities: limited resources and an ambitious mandate. As we can see, there is no easy path: every tactic has potential benefits but also potential difficulties. Fortunately the RTIA gives ample opportunity for experimentation and learning. This is a critically important part of the RTI project. As Laura Neuman has recently observed in World Bank report, "if there is a widespread belief that the access to law will not be enforced, the right to information becomes meaningless."

Alasdair Roberts is a professor of law and public policy at Suffolk University Law School in Boston, USA. He is a specialist on access to information law. His web address is

Thursday, 7 January 2010

RTI Briefs series

The Accountability Initiative has recently launched a policy brief series on the right to information. The Right to Information Act (RTI Act) was passed in 2005. The RTI Briefs series examines issues relevant to the debate on right to information in India, highlighting international best practices with a view to inform policy debates.The first brief in this series looks at Section 4 or proactive disclosure of information under the RTI Act and highlights best practices in proactive disclosure of information from Mexico. For more on this brief, click here.

Wednesday, 6 January 2010

State Size, State Capacity and Decentralisation

Mandakini Devasher Surie

The current political deadlock over the creation of Telangana and subsequent demands for new states has raised interesting questions about the relationship between state size and good governance. The big question is does size matter? Are smaller states better and more easily governed? In a recent article, Mani Shankar Aiyar, Former Minister for Panchayati Raj, argues that the question of whether small or big states are better governed is largely irrelevant and that “...both large and small states will continue to be badly governed until there is effective devolution of funds, functions and functionaries to local authorities” through decentralisation. In another article, Pratap Bhanu Mehta argues that “the success of a state depends on state capacity rather than state size” and that “state building” rather than state creation is of key importance. I think that these arguments are interlinked and need to be looked at more closely.

The issue of state capacity is crucial when we talk about the ability of states to govern effectively. State capacity is in part linked to how well states decentralise or devolve powers to lower levels of government. The 73rd and 74th Constitutional Amendments have made provisions for the decentralisation of administrative and fiscal powers to rural and urban local bodies. In basic terms, decentralisation involves the assignment of responsibilities (functions) at each level of government, backed by sufficient resources (funds) and staff (functionaries) needed to carry out the duties assigned. The 3F’s are basically the backbone of any decentralised form of government and if implemented well can pave the way towards better service delivery and greater accountability in government.

In theory, these reforms ensure that governments at each level have the requisite resources to carry out the duties assigned to them. But in practice, decentralisation reforms have progressed slowly resulting in a gradual undermining of the state’s ability to govern effectively. A quick glance at the Devolution Index 2008-09 shows that decentralisation to rural local bodies or Panchayati Raj Institutions (PRIs) has generally been uneven and incomplete across most States (see Figure 1)

Source: NCAER, 2009

When it comes to the 3Fs the Index reveals that:

  • Functions: Most states have not devolved all the 29 listed functions to PRIs. On average states have only devolved 21.3 out of the 29 functions. The activity mapping of functions has also been poor. Activity mapping involves breaking up activities into smaller units and assigning them to specific tiers within government. On average, States have carried out activity mapping for only 17.6 out of 29 functions
  • Funds: Finances have not followed the assignment of functions. PRIs lack the capacity to raise or collect internal revenues and taxes such that they are largely dependent on grants-in-aid from central and state governments;
  • Functionaries: PRIs lack adequate infrastructure and staff to carry out their duties. As PRIs are unable to hire or fire their own staff, they are reliant on state governments to provide them with functionaries. Inadequate and skeletal staff at local levels is a major hindrance to effective decentralisation.

Without the clear assignment of functions, sufficient funds and staff, PRIs have poorly defined and unfunded mandates. So even as we debate the creation of new states, existing states are still struggling to provide the right kind of capacity support and infrastructure to their local bodies. The whole objective of devolving power to Panchayati Raj Institutions was to activate and create a host of empowered local governing bodies that would determine local development objectives. Sadly, this is not happening as fast or as well as it should. A state is only as effective as its smallest administrative unit. Without effective decentralisation, the capacity of a state (however, big or small) is limited. Yet, we are in a situation today, where in most states, even the smallest units of government lack the basic capacity to implement let alone govern.

In the coming years, as the quantum of government expenditure on centrally sponsored schemes increases with programmes such as the National Rural Employment Guarantee Scheme, Sarva Shiksha Abhiyan and National Rural Health Mission, the pressure on states and local bodies to deliver will continue to increase. New states will face even greater challenges as they get their houses in order. States, old or new, need to get much faster and better at decentralising powers to local bodies. While the debate about small versus big states promises to rage on, I think we can all agree that size will make no difference in the absence of the fundamental instruments of decentralised governance and the basic institutional and human capacity to use these instruments effectively.

For more on the state of decentralisation in India today check out the Accountability Initiative’s Panchayat Briefs series. The first brief in this series examines the ability of decentralisation to promote inclusive governance. The second brief takes a broad look at the state of decentralisation in India.

Mandakini Devasher Surie is a Research Associate with the Accountability Initiative.

Sunday, 3 January 2010

The Right to Education Act: getting the design right for right implementation

Yamini Aiyar

How do we deliver elementary education effectively and accountably to India’s children? This question is becoming increasingly more relevant as India begins work to implement the recently passed Right to Education Act (RTE). See here for an interesting review by Rukmini Banerji of James Tooley’s latest book, The Beautiful Tree. The book is an effort to address one critical question: “If public education is so dismal and time-consuming to reform to make it better for poor people...could private schools be a quicker, easier, more effective solution?” The review raises the issue of local ownership as holding the key to effective and accountable delivery. Can better decentralization improve education outcomes? And if so, what is the best design through which this should be done?

The RTE has many provisions for ensuring accountability through decentralization, including the creation of school management committees (SMC) empowered to make plans and monitor school-level expenditures. But as is well known in India, the devil lies in the implementation. How effectively these accountability provisions will work on the ground depends on getting the ‘right’ design that will ensure accountability and transparency in implementation process. How can this be achieved?

If there is one lesson to take home from India’s past experience, particularly with the implementation of the Sarva Shiksha Abhiyan, it is that simply creating decentralized institutions such as the Village Education Committees (VEC) that ‘invite’ local participation in planning does not itself result in effective decentralized delivery – it is now widely accepted that VECs for the most part are defunct. Local institutions need to be nurtured and resourced. They need to be provided with information and capacity, and perhaps most importantly, the system needs to create incentives that make local participation meaningful. How do we ensure this in the RTE? Now as bureaucrats are at the drawing board developing the rules and guidelines for the implementation of the RTE, this issue needs to be seriously debated so that for once we get the ‘implementation design’ right.

Yamini Aiyar is Director of Accountability Initiative