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Mainstream, VOL LVII No 30 New Delhi July 13, 2019

Open Letter to the Election Commission of India

Saturday 13 July 2019

Shri Sunil Arora, Chief Election Commissioner

Shri Ashok Lavasa, Election Commissioner

Shri Sushil Chandra, Election Commissioner

Election Commission of India

Nirvachan Sadan

New Delhi

India

Sirs,

Serious Irregularities in the Conduct of General Elections, 2019

 

1. We are a group of former civil servants that takes up, from time to time, matters of exceptional national interest, seeking to remind our cherished democratic institutions of their responsibility to uphold the lofty ideals of the Constitution. We write to you today to draw your attention to the several very troubling and still unexplained issues pertaining to the conduct of the General Elections, 2019, by the Election Commission of India (ECI).

2. From time to time, the media has reported on various irregularities in the conduct of the 2019 General Elections. While we accept that not every media report is accurate or true, the ECI’s non-rebuttal of an untrue or inaccurate story leaves the public to draw its own conclusion: that the ECI has no valid explanation to offer. The mere dismissal of the allegations as baseless, without an explanation as to why they should be so considered, is unsatisfactory. As the custodian of the most precious commodity in a democracy—the people’s mandate—it is your duty to be transparent, and accountable to the Constitution and the people of India.

3. The 2019 General Elections appear to have been one of the least free and fair elections that the country has had in the past three decades or so. In the past, despite the efforts of criminal elements, musclemen, and unscrupulous politicians, the persons who graced the ECI did their best to ensure that elections were conducted as freely and fairly as possible. In these General Elections, however, an impression has gathered ground that our democratic process is being subverted and undermined by the very constitutional authority empowered to safeguard its sanctity. It was rare in the past for any serious doubts to be raised about the impartiality, integrity and competence of the ECI. Unfortunately, the same cannot be said about the present ECI and the way it has conducted the General Elections of 2019. So blatant have been the acts of omission and commission by the ECI that even former Elections Commissioners and CECs have been compelled, albeit reluctantly, to question the decisions of their successors in office.

4. The bias of the Election Commission towards one particular party became evident from the date of announcement of the elections. The announcements of the 2004, 2009 and 2014 Lok Sabha Elections were made by the ECI on February 29, March 1 and March 5 respectively of those years. The announce-ments of State Assembly elections, due in April-May, also used to be made between March 1 and March 5. But this convention was not followed for the 2019 Lok Sabha Elections and the announcement was delayed, without any explanation or justification, till March 10, 2019. This led to the reasonable doubt that the ECI deliberately delayed the announcement to enable Prime Minister Narendra Modi to complete the inauguration blitz of a slew of projects (157 of them) that he had scheduled between February 8 and March 9. Instead of the government adjusting the dates of its inaugural functions to the ECI’s (well known) schedule for announcement of elections, we have here a case of the ECI adjusting itself to the government’s schedule, thereby raising questions about its independence and impartiality.

5. The election schedule raised many eyebrows. It was the longest election in the country’s history, and gave room for suspicion that it had openly and unabashedly favoured the ruling party at the Centre. There was no apparent rationale to the number of polling days fixed for different States. In States like Tamil Nadu (39 seats), Kerala (20), Andhra Pradesh (25) and Telangana (17), where the BJP is weak and had no likelihood of winning, the polling was held in a single phase. In States with comparable or fewer Lok Sabha constituencies such as Karnataka (28), Madhya Pradesh (29), Rajasthan (25) and Odisha (21), where the BJP faced tough competition or was likely to gain ground, the polling was scheduled in multiple phases, possibly to give the Prime Minister more time for campaigning. The polling for the Varanasi constituency from where the Prime Minister contested was conveniently slotted in the last phase of polling on May 19, 2019.

6. Several reports were published in the media of large scale voter exclusion, with some reports suggesting that voters from certain minority groups were the most affected. While we do not believe that these charges were necessarily true, it was incumbent upon the ECI to investigate them and respond promptly. Many voters who had exercised their mandates in earlier elections found their names missing. The ECI’s failure to effectively answer these allegations further tarnished its reputation.

7. The blatant flouting of the Model Code of Conduct (MCC) by many candidates, in particular the making of hate speeches and communally loaded statements by candidates, primarily of the BJP, was, initially, blithely ignored by the ECI on the plea that it had no powers to take action. For example, Mr Amit Shah was reported to have said that illegal immigrants would be thrown into the Bay of Bengal, a statement which clearly invited action under the Indian Penal Code (IPC) and the Representation of People Act. Only when pulled up by the Supreme Court did the ECI suddenly discover its powers, even then exercising them selectively on the small fry and ignoring the more egregious cases of violation by the Prime Minister and the BJP Party President. Even the strongest action that it took, viz. the curtailing of the campaigning in the last phase in West Bengal, was done in a manner so that the PM’s campaign could be completed before the ban came into effect. Its partisanship confirmed, the approach of the ECI further emboldened the Prime Minister, Mr Amit Shah and other party represen-tatives.

8. The Prime Minister’s blatant misuse of the Pulwama and Balakot issues to whip up nationalistic, or more correctly, jingoistic fervour and channel it in favour of the BJP was another shocking violation of the MCC. The Election Commission strangely did not even issue a show cause notice to the PM for these repeated violations though the incidents were reported by the State Election Commissioners and there was a divide within the ECI itself on whether or not there was a breach of the MCC. The ECI ignored the difference of opinion and merely dismissed the incidents. The dissenting opinions of Commissioner Ashok Lavasa should have been published as is done in the case of the judiciary. In our opinion, Article 19 of the Constitution and the citizens’ right to information have been violated.

9. The bias of the ECI was glaringly apparent in the case relating to Mr Mohammed Mohsin, the IAS officer who was sent to Odisha as a special election observer. Mr Mohsin was suspended for checking the PM’s helicopter for any non-permissible cargo. According to the ECI, the official had not acted in conformity with the ECI’s instructions of not checking SPG-protected persons. Constitutional obligations were trumped by administrative instructions. It was pointed out, even at that time, that similar checks had been carried out on the helicopters of the Odisha CM, Mr Naveen Patnaik, and the then Petroleum Minister, Mr Dharmendra Pradhan, with no objections from the dignitaries concerned. However, the ECI could not and did not explain its double standards.

10. A serious matter in which the ECI exonerated the government of wrongdoing was the misuse of official machinery. The Niti Aayog had officially written to the various UTs and some districts in the country to provide local information about the area since the PM was likely to visit these places. This was done so that the information could be used in the Prime Minister’s election campaigns. Even though this was a blatant violation of the MCC, the EC merely dismissed the complaint. Why did the ECI treat the MCC in such a cavalier fashion and apply it in so obviously discriminatory a manner? Action was also called for under the Representation of People Act.

11. The refusal of the ECI to take note of the many media violations—particularly by the ruling party—caused a great deal of concern to the public. The most blatant violation of this was the opening of a new channel called Namo TV which continuously telecast speeches and events about the Prime Minister Narendra Modi. Namo TV had, strangely, neither obtained permission from the Information and Broadcasting Ministry to go on air nor had it complied with the many regulations necessary to start a new channel. Even though the ECI ordered the channel to be closed, Namo TV continued to telecast almost until the end of the elections. Procrastination, silence and inaction charac-terised the ECI’s responses in so many matters. There were other violations as well: a programme anchored by the actor, Akshay Kumar, centred on the PM’s unofficial persona, which was telecast by several TV channels while the elections were underway, giving the PM’s campaign an undue edge over those of others; the media attention given to the PM’s meditation in a cave in Kedarnath, even while the last phase of the polling was going on, was another such instance. As far as we are aware, none of these expenses have been added to the PM’s electoral expenses.

12. In terms of transparency of electoral funding, this election was the most opaque ever, both because of the widespread use of electoral bonds, and also because of the enormous amounts of cash, gold and drugs, amounting to Rs 3456 crores, which were seized during the polls. While the ECI acted strongly in the matter of the seizure of cash in Tamilnadu, cancelling the polling in one parliamentary constituency, it has not acted as strongly in other cases. Though Rs 1.8 crore was recovered from the Arunachal CM’s convoy, there is no information of what action was taken by the ECI on this clear violation of rule and norm. Where, one might ask, was the level playing field?

13. The use of the Electronic Voting Machines (EVMs) for polling has been a subject of much controversy. Despite the ECI’s repeated statements that the EVMs used in India are tamper-proof, doubts on that score have persisted, particularly because the ECI has not been transparent in its responses to various reports. There were widespread reports of a mismatch in the number of EVMs manufactured by the two authorised PSUs and those in the inventory of the ECI. According to one media report, responses to an RTI query have revealed that as many as 20 lakh EVMs that the manufacturers affirm having delivered to the ECI were apparently not in the ECI’s possession. To queries about this huge discrepancy, the ECI’s response has been a bland denial, leaving no-one any wiser. Complete facts and figures need to be revealed for public scrutiny.

14. People’s confidence in the EVMs would have been greater if the ECI had been more cooperative about using the Voter Verifiable Paper Audit Trails (VVPATs) in a manner that would confirm the results of the EVMs, but from the beginning the ECI was extremely reluctant to match the number of votes recorded in EVMs with the votes in the VVPAT machines on any significant scale, despite representations by different groups, including political parties. The ECI stated that tallying the votes of 50 per cent of the VVPATs with the EVMs would take about six days (even though it is a well-known fact that in the past 100 per cent of paper ballots were counted in 12-18 hours). The ECI insisted that the purpose of verification would be served if such tallying was done in only one EVM per Assembly constituency. On the insistence of the Supreme Court, the ECI agreed to increase this number to five EVMs per constituency The ECI’s refusal to listen to, and accept, globally adopted statistical tools to determine the number of VVPATs that need to be counted to rule out any errors, or to lay down the steps that would have to be taken in case of a mismatch between the EVM and VVPAT counts, has left a cloud of confusion in the mind of the electorate.

15. Between the last day of polling and Counting Day, there were several reports of unexplained movement of EVMs to and from the strong rooms in various States. These movements have not been satisfactorily explained, and the ECI’s bland denial, without explaining exactly which EVMs were being transported, and why, does not inspire trust or confidence.

16. The request by a large number of parties to tally the EVM and VVPAT votes at the beginning of Counting Day was also turned down by the ECI without any specific reason. This was a simple request and would have satisfied many of the political parties. In fact, at every stage the ECI has refused to accommodate any request that could bolster the confidence of the electorate that the elections were conducted freely and fairly. Matching of five VVPATs as mandated by the SC was relegated to the end of the counting process—so that few would remain to watch the outcome. The result of this exercise is not quite clear from the media reports. It appears, though, that the mismatch between the number of votes cast, the numbers recorded by the EVMs, and as reported in the VVPATs has been quite numerous—some media reports put the number affecting more than 370 Lok Sabha constituencies.

17. Reports about the mismatch in EVM, VVPAT and the votes cast numbers are being explained away as being insignificant, since in almost all the cases, the victory margin (almost invariably of candidates put up by the BJP or its allies) is far greater than the discrepancy. During the paper ballot days, discrepancies in counting used to be ignored if they were too small to make a difference to the final result. But that logic does not apply to VVPAT-based audit of EVMs. Here, even a small discrepancy between the EVM count and the VVPAT in the chosen sample of EVMs, and a small discrepancy between the EVM count and the votes polled in a polling booth as reported by the Presiding Officer in Form 17C at the end of the polling day are very serious matters and are symptomatic of a greater malaise. While the Returning Officers and even Counting Agents may be taking it lightly due to deficiency in their understanding of an appropriate statistical sample, surely the ECI knows better. Accepting this argument is akin to an accountant saying that in a balance-sheet of crores, an un-reconciled few hundred rupees do not matter, and the accounts should be accepted. When we are using electronic systems, even a discrepancy of one vote throws the entire election into doubt.

18. A well-known academic recently wrote, “....we can only raise questions on the basis of scattered information available to us. It is not our job as citizens to offer proof of wrong-doing of the highest institutions of the land, when these institutions function in so opaque a manner. It is our job to raise questions about visible anomalies. It is the responsibility of the Election Commission to explain the anomalies.”

19. Our Election Commission used to be the envy of the entire world, including developed countries, for its ability to conduct free and fair elections despite the huge logistical challenges and the hundreds of millions of voters. It is indeed saddening to witness the process of the demise of that legacy. If it continues, it is bound to strike at the very heart of that founding document the people of India proudly gave themselves—the Constitution of India—and the democratic ethos that is the very basis of the Indian Republic.

20. Viewed in totality, there is no doubt that the mandate of 2019 has been thrown into serious doubt. The concerns raised are too central to the well-being of our democracy for the ECI to leave unexplained. In the interests of ensuring that this never happens again, the ECI needs to pro-actively issue public clarifications in respect of each of these reported irregularities, and put in place steps to prevent such incidents from occurring in future. This is essential to restore the people’s faith in our electoral process.

Yours sincerely,

1. S.P. Ambrose, IAS (Retd.),

Former Additional Secretary, Ministry of Shipping and Transport, GoI

2. Mohinderpal Aulakh, IPS (Retd.),

Former Director General of Police (Jails), Govt. of Punjab

3. G. Balachandhran, IAS (Retd.),

Former Additional Chief Secretary, Govt. of West Bengal

4. Vappala Balachandran, IPS (Retd.),

Former Special Secretary, Cabinet Secretariat, GoI

5. Gopalan Balagopal, IAS (Retd.),

Former Special Secretary, Govt. of West Bengal

6. Chandrashekhar Balakrishnan, IAS (Retd.), Former Secretary, Coal, GoI

7. Sharad Behar, IAS (Retd.),

Former Chief Secretary, Govt. of Madhya Pradesh

8. Madhu Bhaduri, IFS (Retd.),

Former Ambassador to Portugal

9. Pradip Bhattacharya, IAS (Retd.),

Former Additional Chief Secretary, Development and Planning and Administrative Training Institute, Govt. of West Bengal

10. Meeran C. Borwankar, IPS (Retd.),

Former DGP, Bureau of Police Research and Development, GoI

11. Sundar Burra, IAS (Retd.),

Former Secretary, Govt. of Maharashtra

12. Kalyani Chaudhuri, IAS (Retd.),

Former Additional Chief Secretary, Govt. of West Bengal

13. Javid Chowdhury, IAS (Retd.),

Former Health Secretary, GoI

14. Surjit K. Das, IAS (Retd.),

Former Chief Secretary, Government of Uttarakhand

15. P.R. Dasgupta, IAS (Retd.),

Former Chairman, Food Corporation of India, GoI

16. Keshav Desiraju, IAS (Retd.), Former Health Secretary, GoI

17. M.G. Devasahayam, IAS (Retd.),

Former Secretary, Govt. of Haryana

18. K.P. Fabian, IFS (Retd.),

Former Ambassador to Italy

19. Arif Ghauri, IRS (Retd.),

Former Governance Adviser, DFID, Govt. of the United Kingdom (on deputation)

20. Gourisankar Ghosh, IAS (Retd.),

Former Mission Director, National Drinking Water Mission, GoI

21. S.K. Guha, IAS (Retd.), Former Joint Secretary, Department of Women & Child Development, GoI

22. Meena Gupta, IAS (Retd.),

Former Secretary, Ministry of Environment & Forests, GoI

23. Wajahat Habibullah, IAS (Retd.),

Former Secretary, GoI and Chief Information Commissioner

24. Sajjad Hassan, IAS (Retd.),

Former Commissioner (Planning), Govt. of Manipur

25. Jagdish Joshi, IAS (Retd.),

Former Additional Chief Secretary (Planning), Govt. of Maharashtra

26. Kamal Jaswal, IAS (Retd.),

Former Secretary, Department of Information Technology, GoI

27. Rahul Khullar, IAS (Retd.),

Former Chairman, Telecom Regulatory Authority of India

28. Ajai Kumar, Indian Forest Service (Retd.), Former Director, Ministry of Agriculture, GoI

29. Arun Kumar, IAS (Retd.),

Former Chairman, National Pharmaceutical Pricing Authority, GoI

30. Sudhir Kumar, IAS (Retd.),

Former Member, Central Administrative Tribunal

31. P.K. Lahiri, IAS (Retd.),

Former Executive Director, Asian Development Bank

32. Subodh Lal, IPoS (Retd.),

Former Deputy Director General, Ministry of Communications, GoI

33. P.M.S. Malik, IFS (Retd.),

Former Ambassador to Myanmar and Special Secretary, MEA, GoI

34. Harsh Mander, IAS (Retd.),

Govt. of Madhya Pradesh

35. Lalit Mathur, IAS (Retd.),

Former Director General, National Institute of Rural Development, GoI

36. Aditi Mehta, IAS (Retd.),

Former Additional Chief Secretary, Govt. of Rajasthan

37. Sonalini Mirchandani, IFS (Resigned), GoI

38. Deb Mukharji, IFS (Retd.),

Former High Commissioner to Bangladesh and former Ambassador to Nepal

39. Shiv Shankar Mukherjee, IFS (Retd.),

Former High Commissioner to the United Kingdom

40. Sobha Nambisan, IAS (Retd.),

Former Principal Secretary (Planning),

Govt. of Karnataka

41. Amitabha Pande, IAS (Retd.),

Former Secretary, Inter-State Council, GoI

42. Alok Perti, IAS (Retd.),

Former Secretary, Ministry of Coal, GoI

43. T.R. Raghunandan, IAS (Retd.),

Former Joint Secretary, Ministry of Panchayati Raj, GoI

44. N.K. Raghupathy, IAS (Retd.),

Former Chairman, Staff Selection Commission, GoI

45. J.P. Rai, IAS (Retd.),

Former Director General, National Skills Develop-ment Agency, GoI

46. V.P. Raja, IAS (Retd.),

Former Chairman, Maharashtra Electricity Regulatory Commission

47. C. Babu Rajeev, IAS (Retd.),

Former Secretary, GoI

48. M.Y. Rao, IAS (Retd.),

Former Chairman and MD of Grid Corporation of Orissa

49. Satwant Reddy, IAS (Retd.),

Former Secretary, Chemicals and Petrochemicals, GoI

50. S.S. Rizvi, IAS (Retd.),

Former Joint Secretary, Ministry of Environment and Forests, GoI

51. Aruna Roy, IAS (Resigned)

52. Deepak Sanan, IAS (Retd.),

Former Principal Adviser (AR) to Chief Minister, Govt. of Himachal Pradesh

53. N.C. Saxena, IAS (Retd.),

Former Secretary, Planning Commission, GoI

54. Abhijit Sengupta, IAS (Retd.),

Former Secretary, Ministry of Culture, GoI

55. Aftab Seth, IFS (Retd.),

Former Ambassador to Japan

56. Ashok Kumar Sharma, IFS (Retd.),

Former Ambassador to Finland and Estonia

57. Navrekha Sharma, IFS (Retd.),

Former Ambassador to Indonesia

58. Raju Sharma, IAS (Retd.),

Former Member, Board of Revenue, Govt. of Uttar Pradesh

59. Rashmi Shukla Sharma, IAS (Retd.),

Former Additional Chief Secretary, Govt. of Madhya Pradesh

60. K. Ashok Vardhan Shetty, IAS (Retd.), Former Vice Chancellor, Indian Maritime University, GoI

61. Jawhar Sircar, IAS (Retd.),

Former Secretary, Ministry of Culture, GoI, and former CEO, Prasar Bharati

62. Parveen Talha, IRS (Retd.),

Former Member, Union Public Service Commission

63. P.S.S. Thomas, IAS (Retd.),

Former Secretary General, National Human Rights Commission

64. Hindal Tyabji, IAS (Retd.),

Former Chief Secretary rank, Govt. of Jammu and Kashmir

Endorsements of the letter written by retired civil servants by veterans of the Armed Forces, academics and concerned citizens

1. Admiral L. Ramdas, PVSM, AVSM, VrC, VSM, ADC

2. Admiral Vishnu Bhagwat, PVSM, AVSM

3. Lt Gen C.A. Barretto, PVSM

4. Lt Gen Vijay Oberoi, PVSM, AVSM, VSM

5. Maj Gen S.G. Vombatkere, VSM

6. Maj Gen T.K. Kaul, PVSM, AVSM VSM

7. Brig V.H.M. Prasad

8. Cdr Satya Prakash Taneja

9. Cdr Rajvir Singh

10. Maj Priyadarshi Chowdhury, SC

11. Lt Gen M.A. Zaki

12. Group Capt M.H.Zaki

13. Colonel Swapan Bhadra

14. S.A. Khader, I.G. BSF

15. Abha Dev Habib, Miranda House, University of Delhi

16. Abhay Kumar Dubey, Centre for the Study of Developing Societies, Delhi

17. Abhijit Roy, Department of Film Studies, Jadavpur University, Kolkata

18. Abir Dasgupta, Independent Journalist, Mumbai

19. Aditya Nigam, Professor, Centre for the Study of Developing Societies, Delhi

20. Anjali Monteiro, Professor, Tata Institute of Social Sciences, Mumbai

21. Areeb Rizvi, Independent Researcher

22. Aruna Rodrigues, Environmentalist, Sunray Harvesters, Mhow, MP

23. Arundhati Ghosh, Arts Professional, Bangalore

24. Ashish Kothari, Environmentalist, Pune

25. Ashoke Ranjan Thakur, Ex-Vice Chancellor West Bengal State University

26. Ayesha Kidwai, Professor, Jawaharlal Nehru University

27. Avinash Kumar, JNU

28. Bishnupriya Dutt, Professor, JNU

29. C. P. Chandrasekhar, Professor, JNU

30. Doyeeta Majumder, Assistant Professor, Jadavpur University, Kolkata

31. G. Arunima, Professor, JNU

32. Ira Bhaskar, Professor, JNU

33. Janaki Nair, Professor, JNU

34. Jayati Ghosh, Professor, JNU

35. K.P. Jayasankar, Professor, Tata Institute of Social Sciences, Mumbai

36. Lakshmi Subramanian, Retired professor, CSSSC, Kolkata

37. Lata Singh, Associate Professor, JNU

38. Madhu Sahni, Professor, Jawaharlal Nehru University

39. Nandita Narain, St. Stephen’s College, Delhi University

40. Nivedita Menon, Professor, JNU

41. Peter R. DeSouza, Professor, CSDS, Delhi

42. Pranab Kanti Basu, Retired Professor, Visva-Bharati Santiniketan

43. Probal Dasgupta, Retired Professor, Indian Statistical Institute, Kolkata

44. Purusottam Bhattacharya, Retired Professor of International Relations, Jadavpur University, Kolkata.

45. Sanjeeb Mukherjee, Former faculty, University of Calcutta

46. S. Prakash, JNU

47. Sukanta Chaudhuri, Professor Emeritus, Jadavpur University, Kolkata

48. Sumit Chakrabarti, Professor of English, Presidency University

49. Sumit Sarkar, Retired Professor, Delhi University

50. Supriya Chaudhuri, Professor (Emerita), Jadavpur University, Kolkata

51. Swapan K. Chakravorty, Kabiguru Rabindranath Tagore Distinguished Chair in the Humanities, Presidency University, Kolkata

52. Tanika Sarkar, Retired Professor, JNU

53. Vikas Bajpai, Assistant Professor, Jawaharlal Nehru University

54. Shilpi Singh Executive Coach, Gurgaon

55. Paranjoy Guha Thakurta, NCR, Journalist, Gurgaon

56. Tara Murali, Architect, Chennai

57. Aruna Rodrigues, Environmentalist, Sunray Harvesters, Mhow

58. Shabnam Hashmi, Social Activist, New Delhi

59. Leela Samson, citizen, Chennai

60. Ayesha Maria Mualla, Delhi

61. Primila Lewis, Social worker (retd)

62. Fatima Zarafshan, Lecturer, Miyapur, Hyderabad, Telangana

63. Dilip Simeon, retd Teacher, Delhi University

64. Ravi Katari, Citizen of India, Chennai

65. Om Prakash Singh, Citizen, Chennai

66. Ravi Nitesh, Social Activist, New Delhi

67. Dr Virendra Vidrohi, Gen Sec, INSAF, Delhi

68. Abha Bhaiya, Jagori Rural, Himachal Pradesh

69. Anita Dighe, Concerned Citizen, NOIDA

70. Niloufer Bhagwat, Vice-President, Indian Association of Lawyers

71. Tripta Wahi, Retd Professor, Delhi University

72. Mandira Kumar

73. Tripta Batra, Delhi, NCR

74. Ram Narayan, Ecologist, Uttarakhand

75. Aquil Hashim, Bengaluru

76. Lakshmi Krishnamurty, Alarippu, Bengaluru

77. Arjun Mahey, Associate Professor, St Stephens College, Delhi University

78. Madhu Ramnath, Adukkam Village, Kodaikanal Taluk, Dindigul District

79. Rani Day Burra, Bengaluru

80. Ashok Nehru, New Delhi

81. Malti Nehru, New Delhi

82. Somi Hazari

83. Lalita Ramdas, Citizen and Educator, Village Bhaimala, Alibag, Raigad

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