The political history of Darjeeling District dating back to the period of its establishment in 1866/67 as an administrative unit in British (India?) which require to be deeply studied if at all any question of the District’s merger with the State of Sikkim is ever considered. Needless to reiterate the importance that the District was established as a composite from the ceded areas of the former Kingdom of Sikkim and Bhutan. The time space of Sikkim’s secession comprised Darjeeling (Deed of Grant-1835), Siliguri (Terai-1850) and Kurseong (Tumlong, Capital of Sikkim -1861); and similar secessions from Bhutan comprised Assam Duars (1828-41 from Tongsa Penlop) and Bengal Duars (1864-65 from Paro Penlop) vide the Treaty of Sinchula 1865.
Important aspects of the secessions are to be considered in formulating the chronological order of the successive powers to which the lands remained transferred, de facto on an ad hoc basis for final implementation to de jure in time. This complicated issue requires understanding the administrative policy of British India and which constitution are documented in the volumes of Acts, laws, regulations, etc; of the government at the Centre and the Provinces. In understanding and interpreting these documents lies the secret formula on basis of which the East India Company (EIC) ruled till 1857 (The Sepoy Mutiny) and after which date the Crown eventually took over the reins of the government wherein the post of the Governor General of the Company was replaced by the Viceroy – representing the Crown. The transfer of power entailed a complete overhaul where the Crown became the suzerain of British India and the Company simply a corporation of England. Besides the transfer of all Company land to British India (Crown) included all previous treaties signed by the predecessor which automatically were incorporated within the function of the Crown. An important example is the Deed of Darjeeling Grant (1835) which happened to be transferred to the Crown. This particular aspect will be recalled in time in asserting Darjeeling District which at the moment of time is held as a special administrative unit ,under the Constitution of India, within the provisions of the Fifth Schedule, without being a Scheduled Area !
The reason Darjeeling District was provided a constitutional safeguard happens to be the chief reason why its merger with the State of Sikkim seems somewhat unviable as per the constitutional writ and the story of which dates back to the earliest time of its history ,when the District was established as an administrative unit. The interesting part of the administrative unit is the fact, which does not explain clearly, whether this unit ever formed part of British India, legally speaking, as the two treaties does not mention it so. On the contrary, it is the British government and the Crown which happens to be the recipient of the acceded territories. This implication is not normally perceived unless one studies seriously the chronological history of this area. Throughout the British rule ending in 1947 (Independence of India) and continuing till 1950-52 (inception of parliamentary government in India under the Constitution), the history of the District remained statusquo as far as its administration was concerned. A fact which is unknown to many readers, is that the administration for the District was distinctly different from the general administration of British India. This elucidates an interesting observation that the District, like many such territories in India, did not form the territorial parts of British India and remained excluded in the name of the legal recipient – the Crown.
There were many such territories which were absorbed in British India but for all practical purposes their administration remained outside the purview both the Centre and the Provincial governments. Such areas were referred as Non- Regulated areas in consonance with the Regulation Act of 1773 passed by the British Parliament for the primary purpose of introducing administrative reforms within the territories occupied by the East India Company. In effect, the Non-Regulated areas were outside the reforms program. Instead they were administered directly by the Lt. Governors of the Provinces on behalf of the Governor General reporting to the Home Secretary in Parliament representing the Crown.
In the early period of history, such Non-Regulated areas for simplicity were initially referred as ‘backward areas’ for convenient display without conveying any regard to the actual implication, to any ordinary mind, that the ‘backward areas’ were administered unlike the other regulated territories of British India for which the general administrative reforms were programmed from time to time. During the various reforms process, the ‘backward areas’ was rephrased distinctly as Backward Tracts in 1870-74; thereafter it was covered by the Scheduled Districts Act of 1874; in 1919 it was reverted back to Backward Tracts; till the advent of the Simon Commission 1930 on the recommendation of which the Backward Tracts, the administration of which areas were to be totally ‘excluded’ from the general reforms process of British India. The substance of which was formalised by the enactment of the Govt. of India Act 1935 implying the contents of the Excluded and Partially Excluded Areas (E&PEA). The Act was further clarified by the Order of 1936 determining the territories covered by the phrase Excluded and Partially Excluded Areas.
The Order listed eight Excluded Areas and twenty eight Partially Excluded Areas in various provinces of India (viz. Madras, Bengal, The Punjab, Assam, The North West Frontier Province, Bombay, The United Provinces, Bihar, Central Provinces and Berar, Orissa). The areas covered by the definition of E&PEA consisted of large as well as small parts of the states mentioned, comprising areas of many districts, subdivisions, towns, villages etc. In the Province of Bengal there were two such areas listed.1 The Chittagong Hill Tracts was Excluded and 2. Darjeeling District was Partially Excluded. Without delving into the list of these areas in other states it is only pertinent to recognise the ground reality and interpret its meaning. The Excluded Areas specifically applied to the Province of Assam where the density and contiguity of Tribes formed the majority (60%+) population of the territories. In a similar fashion the Partially Excluded Areas where the populations of Tribes were marginally less as compared to the concentration in Assam, these locations were distributed throughout India excluding Assam. The Excluded Areas lying with the Partially Excluded Areas were located in The Punjab (Lahaul and Spiti in the Kangra District) and North West Frontier Provinces (Upper Tanawal in the Hazara District).
The Act of 1935 is believed to be a landmark in the history of British India. It was the precursor for determining what India is today primarily because the foundation of the draft Constitution of India is explicitly based on it. Without delving to the other topics contained therein it is only profitable at this stage to deliberate only on the issue of the proceedings dealing with the process of how the fathers of the Constitution dealt with the program of preserving the features of E&PEA intact while drafting the Constitution which are well preserved in documents under the heading Constituent Assembly debates. It is impeccably necessary to recall the E&PEA were separately dealt by two Sub Committees of the Advisory Committee (Constituent Assembly of India). The North East Frontier Tribal Areas and Assam Excluded and Partially Excluded Areas Sub Committee was chaired by Gopinath Bardoloi and the Excluded and Partially Excluded Areas (Other than Assam) Sub Committee by A.V.Thakkar.
Evidently the E&PEA were exclusively determined parts within British India which required specific safeguard measures directed to preserve the distinct ethnic and anthropological characteristics of the inhabitants which were fundamental in determining their future stations in life. In brief it concerns the fundamental rights of the inhabitants as indigenous people of the region guaranteed by the Constitution as well as international understanding to aspire for self-determination within the specific territories as an integral part in the Union of India. This is also an extension of the human rights value declared in the international forum. This clarification is made simply to indicate the critical quotient that is implied by the sense of the meaning of E&PEA. Since this article is specific to Darjeeling District and which happens to be a Partially Excluded Area, the Thakkar Sub Committee has dealt with the topic with utmost care while ensuring the safeguard provided for the people of the area and transferring the same safeguard measures in various parts of the Constitution (Articles therein). To precisely clarify this, it is simply conveyed that the Partially Excluded Area safeguard measure, that is, to establish a special administrative unit (outside the absorbing State) which specific guideline was provided for Darjeeling District within the provisions of the Fifth Schedule primarily applied on basis of the Scheduled Tribes content only. The second and more important safeguard measure of the Fifth Schedule [Article 244 (1)] is the determination of the people inhabiting within a Scheduled Area (gauged as a contiguous density of Scheduled Tribes population). The Scheduled Area criterion forms the very fundamental basis, as legality for democratically demanding a right to form a new state or in common parlance simply means the democratic integration of E&PEA territories into the Union of India.
The above program is intended to be routed through the provisions of the Fifth and Sixth [Article 244(2) &275(1)]Schedules which are the legal components transferred into the Constitution by the Thakkar and Bardoloi Sub- Committees reports to the Advisory Committee while drafting the Constitution between 1946-48. Already related earlier the Thakkar Sub-Committee deliberated basically on the substance of Partially Excluded Areas and the Bardoloi Sub-Committee concentrated on the Excluded Areas. The outcome of the final reports of these Sub-Committees eventually formed the provisions of the Fifth and Sixth Schedule respectively. No doubt Article 395 repealed the Act of 1935, The Independence Act of 1947 etc. but the basic features of the 1935 Act doctrinaires was transcribed into the various Articles and relevant Schedules of the Constitution. The safeguard of the E&PEA provided by a ‘separate administrative unit’ forms the fundamental basis of the provisions of the Fifth and Sixth Schedules.
The E&PEA initially originated, related above as ‘backward areas’, is simply phrase but heavily laden with concentrated legal overtones. These ‘separate administrative units’ were generally outside the purview of the British India act, laws and regulations. This in reverse meaning implied although the areas were absorbed within the Provinces but were directly under the administration initially under the Governor General in Council who was represented in the Provinces by the Lt. Governor and/or the Chief Commissionership. Assam was withdrawn from Bengal in 1874 and placed under a Commissioner of Assam as a Chief Commissioner’s Province under the Governor General (Bengal) within the framework of the Scheduled Districts Act of 1874. Preceding which a year before in 1873 the “Assamese” part of the Province of Bengal were divided into two zones demarcated by the so called the Bengal Eastern Frontier Regulation (line system known as the Inner Line). The entry of citizens/foreigners to cross this line required a permit detailing the specific reason for entering the territory.
This Line since then prevailed as the official version of the Inner Line Permit (ILP) regime which is still in vogue in the State of Sikkim and few other North Eastern States (Nagaland, Mizoram, Arunachal Pradesh). Manipur had initially withdrawn it but now the people of the State are clamouring for its re-imposition as the flux of immigrants, after its withdrawal, is said to have destabalised the demography, marginalising the existence of the local populace.
The ILP was also in force in Darjeeling District along with the four other Districts in North Bengal till 1990. It would be of interest for the concerned of the area to enquire for the reasons for its withdrawal. This for the simple reason, as expressed by the people of Manipur, similar sense of marginalisation of local population in stark contrast with the massive influx of outsiders, foreigners both legal and illegal settling in the District is an ominous sign threatening impact on development on every front due to resource scarcity. The picture in the end is a stark result – the ethnic locals and indigenous population are converted into becoming aliens in their birth soil. The withdrawal of the ILP from North Bengal by the last regime in power for over three decades, encouraging immigration of all hues and colour from bordering states and countries, legal and illegal, has profoundly impacted the entire North Bengal and bordering areas to a irreversible continuum. Likewise Manipur demanding reinstatement of ILP there is no solution whatsoever besides for Darjeeling District including North Bengal.
In substance the ILP has a broader meaning than just a simple entry permit restriction. To convey the concept of Inner Line one can recall Arunachal Pradesh (earlier NEFA) was covered by the Outer Line which demarcated the British territory from the bordering states as well as adjacent countries. Therefore the imposition of Inner Line restriction to Assam and North Bengal as a whole has a geopolitical significance underlying the 1935 Act of E&PEA prefixed in the Fifth and Sixth Schedules. As such the territories within the two Schedules are directly in charge of the President of India handed down to his office by the Viceroy of India at the time the Constitution began functioning with the election of the first Parliament (both the Houses) during the period 1950-52 onwards. The Viceroy was handed over charge of these areas by the Crown at the time of independence under The Foreign (Jurisdiction) Act 1947. Meanwhile The Independence Act of 1947 was granted freedom by the British Parliament enabling the country to become a dominion under the Crown for which an interim government was provided by The Indian (Provisional) Constitutional Order 1947. These enactments made the Viceroy a de facto executive provided with all necessary equipments to formalise legally, for immediate and future state formations in accordance with the Act of 1935. At the point of independence there existed eleven (11) Governors Provinces of British India and six (6) Chief Commissioners Provinces under British rule which territories largely comprised of large tracts of areas within the fold of the eight (8) Excluded and twenty eight (28) Partially Excluded Areas. Besides which there were numerous, five hundred sixty two (562) Princely states (Indian states) most of which were under the authority of British political agents under Treaty obligations. Almost all the Princely states acceded to the dominion Indian federation.
The remaining territories, viz. the E&PEA remained absorbed in the Indian federation and the integration remained to be formalised in matter of time. The period targeted for this program was subject to the promulgation, commencement and formation of a federal parliament. This became possible only in 1950-52 when the federal parliament elected the first President of India to which authority was transferred the power to administer the E&PEA under allocation of the Sixth and Fifth Schedules respectively. For the purpose of carrying forward this program i.e. to arrange the legal integration of these excluded areas into the Indian federation, immediately after the elected Parliament became functional in 1952. The Fifth Amendment Bill (1955) inserted a change in Article 3 empowering the President to specify a time bound limit for State Legislatures to convey their views on the proposed Central laws affecting areas, boundaries, etc within the States. In order to enhance carriage of the Fifth Amendment to its directed end, i.e.to provide the legal guidance for the formal integration of the territories of the Fifth and Sixth Schedule democratically into the Indian Union – the Seventh Amendment (1956) purported to give effect to the recommendation to the State Reorganisation Commission (SRC) and the necessary consequential changes. Broadly the existing states and territories were reorganised to have two fold classifications of States and Union Territories. This is to understand the establishment of the SRC was of utmost necessity in processing and defining to a conclusive end the articulations of the Fifth and Sixth Schedules.
The Fifth allowed the President as the sole authority in the construction of a new state from areas legally provided safeguards prior to independence accounted for within the precepts of the Chief Commissioners Provinces. After the introduction of the Fifth and the Seventh Amendments, working in tandem could the legal rights of the territories of the Fifth and Sixth Schedules was provided the proper means and ends for the future programs of new state formations. Approximately fifteen (15) new states were gradually established by the Fifth and Seventh Amendments.
One of the important factors describing the legal background of Darjeeling District is the Absorbed Area (Laws) Act 1954 which details Darjeeling District as a Partially Excluded Area transferred to West Bengal for administrative purposes perceivably under the provisions of the Fifth Schedule without the Scheduled Area (second part of Fifth Schedule) aspects simply as Scheduled Tribes (first part of Fifth Schedule). This was an instruction by the President of India on basis of which the Governor of the State instructed the State Government to form a Tribes Advisory Council during the period 1952-56 vide Notification No. 1280 under rule 4 of the Fifth Schedule of the Constitution of India. Such a Council still exists in the State. It is this Fifth Schedule perspective which is seen to have allowed Darjeeling District to form the Darjeeling Hill Council in 1978, Darjeeling Gorkha Hill Council 1988 and Gorkhaland Territorial Administration 2011. It therefore stands to reason that these bodies were various aspects of the Tribes Advisory Council and therefore perceived as tribes based in general context. In support of this confirmation it is realised, there are no reservation of seats for the national minorities inclusively.
Taking the above overview into consideration Darjeeling District is already safeguarded within the constitutional ramparts for demanding a state within the provisions of the Fifth Schedule just like in 2000 AD Jharkhand, Chhattisgarh and Uttarkhand were established under the same provisions however with a difference. The three new states emerged from the Fifth Schedule consideration and legality as Scheduled Areas which is the pivotal criteria in demanding a state. Darjeeling District however at this moment of time is deficit of the Scheduled Area recognition and therefore for the time being is disabled from asserting a right to demand a state. However there is a distinct possibility with the Census identification based on ethnology, as undertaken in Census 1931, it is anticipated when Census 2011 is published, some of the Scheduled Tribes of Census 1941 onwards to Census 2001 delisted on basis of mistaken identity when language (spoken mother tongue) was misconceived by the Census resulting in loss of tribal identity. This great blunder is expected to be amended in the new Census 2011 wherein the identification of the Census is based on ethnology of the population and not on language. The expectation of an additional list of Scheduled Tribes in Census 2011 is considered due acknowledgement of the Census 1941 to Census 2001 mistaken identity. Who will compensate for the six decades of identity deprivation causing immense adverse impact on the concerned is a question put forward to the rulers of India. The damage to Darjeeling District was immense. Had the mistake not occurred at all, with majority tribal population as expected in Census 2001, Darjeeling District since Census 1941 in effect was a Tribal Area befitting the Sixth Schedule composition of the North East States.
The above probability is strongly supported by the Roy Burman Commission for Review of Social and Environmental Sector, Policies, Plans and Programmes (CRESP) Govt. of Sikkim 2008 in which report recommendations have been forwarded to the Centre for the followings to be listed as Scheduled Tribes (ST) (Kirat Khambu Rai, Gurung, Mangar, Sunuwar, Thami and Bhujel). The recommendation is expected to be implemented in the event of the new Census 2011 publication. It is felt the Roy Burman recommendation of the above tribes is but a justification only of the fact that these tribes were already listed in the constellation as the Hill Tribes of the Himalayas in Census 1931 basis of which was not language but ethnology which is the true factor for identification of tribal people.
Further it is an expectation after the above recommendation is implemented in Sikkim it is presumed the same yardstick is applied to Darjeeling District, transferring the ST list for identifying to similar people residing herein. The impact of this probability implemented in Darjeeling District will ensure a quantum rise in the ST population expected to raise the percentage from the existing 50% (approx) to as high as 80% of the population in the District. The indication of 80% ST population in the District is expected to change the status of the District in a remarkable way. With this possibility becoming a reality the District qualifies to be determined as a Scheduled Area by the President of India under the recommendation of the Governor of the State. Whenever this formality is expected to be completed thereafter the demand for statehood is considered to be legally completed for the SRC to identify the territorial area for purposes of administration for the new unit. It is a presumption, taking into consideration the historical formation of Darjeeling District as an administrative unit compounded from the acceded territories of Sikkim and Bhutan will itself determine the legal territorial boundaries of the new UT/State.
This is the vision for the future of the District after having taken all the above legal views and perspections into consideration and without any bases for bias or preemptive agenda. Having said so, the possibility of Darjeeling District merger with Sikkim is distinctly an improbability – legally or constitutionally at any point of time. This for the simple reason that the Govt. of Bhutan under the new Indo-Bhutan Treaty of 2007 notably signed the treaty without a word in mention in reference to the annual gratuity of Rs. 5 lakhs which total was a gradual increment from the past since the first time receiving a sum of Rs.10,000.00 under the terms of the Anglo Bhutan Treaty of 1865. This is seen to indicate the Govt. of Bhutan has released its right of the 18 Bhutan Duars (later 11 Bengal Duars and 7 Assam Duars). There is a distinct possibility the 11 Bengal Duars also being determined within the Sixth Schedule in West Bengal, just as the 7 Duars as Bodoland Territorial Council (BTC) included in the Sixth Schedule in Assam.
An interesting observation why the 11 Duars (Jalpaiguri District) require to be put in the Sixth Schedule in West Bengal, at par with its counterpart, 7 Duars in the Sixth Schedule in Assam has immense importance to either of the two states. This for the simple reason the requirement of these tribes is essential in determining the basic foundations of the two states – the requirement of the indigenous people on basis of which only both West Bengal and Assam States are legally formalised. In case this legal argument is not perceivable to the ordinary reader examples are cited here to declare the point.
Unknown to many stakeholders in Sikkim, it is still unrealised that the Sikkim Assembly seats reservation for Bhutia and Lepchas (B &L) [12 +1 = 13 seats] is symbolic in reasoning the legality of the State so formed is primarily concerned of the fact the B &L Scheduled Tribes are identified as the indigenous people. On basis of which population, minority as it maybe, the State of Sikkim is recognised constitutionally for national as well as international understanding.
The premise for new state formation is an international acceptable event however for the world community to accept its relevance require certain norms agreed by the world forum (UNO). In conducting any new state formation, anywhere in the world, the chief criteria required is the fundamental issue – the existence of indigenous people/s who are constitutionally regarded as the national minorities whose basic fundamental right of existence (right to land) is the chief issue for safeguard and thereby protection by law. It is this understanding which forbids transfer of tribal land to non tribals particularly this is applicable to the recognised indigenous people of the State.
Generally it is quite unknown to the ordinary citizen, and this rule is also extended to a wider section of the educated class, and more so the politicians at large, that in national and international arena particularly in the issue related basically to land with the problem related to human rights of the indigenous people, whose definition require to be stated as per the UNO prescription. In fact while broaching the topic of Scheduled Tribes defined and articulated in the range of articles in the Constitution of India, it is still unexplained in acceptable terms the definition of Scheduled Tribes. In matter of legal jurisprudence acceptable to the international community there exist infact two categories of Tribes. The definitions of the two are documented in ILO Convention 169 which India has not signed. The ILO Convention 169 is a follow up action of the United Nations Declaration on Rights of Indigenous Peoples, 2007. India is a signatory member. Quite palpably Bhutan and Bangladesh are two countries out of the eleven (11) abstained from voting. The Declaration voted by 143 member countries. Four first world developed countries (Australia, Canada, New Zealand and United States) voted against. Understandably, the countries comprise large populations of the aboriginal (autochthones) indigenous peoples commonly referred as Tribes. The Declaration is simply an undertaking to protect the Tribes right to their lands and related issues to human rights safeguards.
The reasons of absence of Bhutan and Bangladesh from voting is perceptibly understood, concerns the underlying human rights violation issues related to ethnic Nepali Bhutanese and the Chakma Tribes respectively. Both the categories happen to be determined as refugees under UN auspicious. This legal recognition allows the two categories for international allocation, in relocated settlements, airlifting them across international borders for the final rehabilitation. The refugees from Bhutan were airlifted and relocated in the USA whereas the Chakma Tribes too were airlifted and resettled in the State of Arunachal Pradesh in India.
The irony in both the cases is remarkable. In the former case, history speaks the Nepalese Bhutanese immensely credited to the development of Bhutan by way of labour input in converting Bhutan from a pristine mountain forest into an agricultural hinterland.
Based on the UNO Convention 169 and the basic principle of ILO Convention – identification of indigenous and tribal peoples. “The Convention does not define who are indigenous and tribal peoples. It takes a practical approach and only provides criteria for describing the peoples its aims to protect. Self-identification is considered as a fundamental criterion for the identification of indigenous and tribal peoples, along with the criteria outlined below.
I. Elements of tribal peoples include: (a)Traditional life styles (b) Culture and way of life different from the other segments of the national population e.g.in their ways of making a living, language, customs, etc., and (c) Own social organizations and traditional customs and laws
II. Elements of indigenous peoples include: (a). Traditional life styles (b Culture and way of life different from the other segments of the national population e.g.in their ways of making a living, language, customs, etc., (c) Own social organizations and political institutions; and (d) Living in historical continuity in a certain area, or before others, “invaded” or came to the area”.
Immediately preceding independence in 1947 the Province of Bengal did not exist. Bengal was divided into two new provinces of British India perceived on grounds of religious consideration, allocating the division presumably on basis of religious ground – Hindu or Muslim majority inhabitant divide – West Bengal and East Bengal respectively. Literally this is observed to have been seen. But the truth of the matter legally justifying the fragmentation was based really on the 1935 Act. Which had already identified the national minorities for classification as indigenous people based on whose democratic rights the two Provinces were formed in British India. A rhetorical question still remains unanswered. If the Partition of Bengal was truly based on religious divide, the question is why the Chittagong Hill Tracts inhabited by 97% Buddhist Chakma Tribes was included in East Bengal, seems perfectly alright before independence. However after independence East Pakistan was created outside the Dominion of India was the tragedy of the Chakma Tribes of the Excluded Area which right alone was responsible for East Bengal as a separate Province. Following independence in 1947 East Bengal was declared a separate country of East and West Pakistan.
The Act of 1935 is the only legal justification in support of territorial boundaries in new Provinces after independence (1947) and immediately after the commencement of the Constitution in 1950-52 under the Fifth and Seventh Amendment Bills.
The two important areas legally possible for the division of the Province were the Chittagong Hill Tracts (Excluded Area) and Darjeeling District (Partially Excluded Area) on basis of this criteria only the Province was possible to be divided, into East Bengal and West Bengal respectively. Under similar conditions it is presumed West Pakistan was bifurcated from rest of India as in the North West Frontier Province – Upper Tanawal in the Hazara District was an Excluded Area which component had a legal right to form a new Province. Therefore the contention that West Pakistan was formed on the basis of the Muslim majority religion is a misnomer wherein reality the legality was provided by the Excluded Area factor in determining a new State.
In the same light it maybe remarked that the present Telangana demand arises from the fact that the merger of this area to Andhra Pradesh in 1953 was assumed to be on the basis of commonality of language. There is no Article in the Constitution of India stating religion, language, culture, or other paraphernalia citing as reasons for demanding a new state. In other words, the demand for Telangana is based primarily on the fact it was unconstitutionally merged with Andhra Pradesh, citing language as the criteria. This mistake of history probably will be amended when the demand is eventually implemented in time.
The unanimous passing of a Resolution No. 3, 2011 by the State Assembly of the Govt. of Sikkim demanding the Centre to create a State of Gorkhaland out of the District of Darjeeling is an unmistakable gesture that the State of Sikkim too has declared its intention that merger of Darjeeling District with the State is totally ruled out as per articulation in the Resolution. The unanimity of the decision voices the democratic will of the people of Sikkim. Therefore any misadventure in formulating a program for the merger of Darjeeling District with Sikkim is a void issue as far as the legality is concerned. This proves the point of the title, Darjeeling Sikkim merger unwarranted.
2,192,382 total views, 1,464 views today