Make a critical appraisal of Niyamgiri movement against mining-induced displacement. (Answer in 250 words)

- Make a critical appraisal of Niyamgiri movement against mining-induced displacement. (Answer in 250 words)
Introduction
Niyamgiri is the one Indian case in which a community stopped a mine. It did so through a procedure the Supreme Court invented, and the precedent has proved narrower than the victory suggested.

Body
1. The context: the Dongria Kondh, a particularly vulnerable group, and the Kutia Kondh live on the Niyamgiri range in southern Odisha, cultivating the slopes and holding the hill to be the abode of Niyam Raja. Vedanta's alumina refinery at Lanjigarh, with a captive bauxite mine in joint venture with the Odisha Mining Corporation, required over six hundred hectares of forest.
2. The resistance: the Niyamgiri Suraksha Samiti organised locally and allied with national campaigns, while an international shareholder campaign forced divestment by the Church of England. The Saxena Committee reported violations of forest and forest rights law, and clearance was withdrawn.
3. The outcome and the procedure: in Orissa Mining Corporation v. Union of India (2013) the Court held that the religious and cultural rights of the Dongria under the Forest Rights Act and PESA had to be decided by the gram sabha, and referred the question to twelve palli sabhas. All twelve voted against mining, and clearance was refused in 2014.
4. The appraisal: it made community and habitat rights operational and is cited worldwide as consent in practice. But the executive chose the twelve villages out of more than a hundred affected; the veto rested on religious rights, a ground not open to communities without a sacred hill; and clearances elsewhere have proceeded without any such referral.

Conclusion
Niyamgiri established that consent can be justiciable, not that it is routinely required. The refinery still stands, and recent dilution of forest clearance requirements has moved the law the other way.