Representing Indigenous Sacred Land: The Case of the Niyamgiri Movement in India

ABSTRACT This paper analyses the representations of the religiosity of the indigenous Dongaria Kondh community in India by international and domestic activists. The Dongaria Kondhs live on and worship the Niyamgiri Mountain on top of which a bauxite mining project was planned. The community’s religiosity became the primary focus of what became known as the Niyamgiri Movement. Activists at local and international scales employed different representations of the Dongaria Kondhs’ religious relation with their land, which facilitated different groups’ identification with the Dongarias’ religiosity, and consequently enhanced the support for the Niyamgiri Movement, which was ultimately successful. The paper uses Spivak’s theorisation of subalternity and Baudrillard’s theory of enchanted simulacra to conduct its analysis. It finds that the representational strategies of the Niyamgiri Movement created space for the Dongarias to voice themselves—in opposition to oppressive power structures and beyond the strategic narratives delineated by the activists who represented them.


Introduction
There have been several documented instances of indigenous peoples entering into conflicts with mining companies for reasons stemming from a disconnect in the values they ascribe to land (Hilson 2002). In such conflicts, indigenous peoples have at times successfully advanced the claim, with the help of supporters, that the land to be mined is sacred to them and that mining would result in its desecration (Ballard and Banks 2003). For example, in the struggle of the Columbian U'Wa tribes-peoples against Occidental Petroleum's attempt to mine oil that lay under their territory, an important aspect of the protest discourse was assertions that oil was the blood of the Earth that the U'Wa tribes-peoples held sacred, and mining it amounted to an attack on their religious sentiments. The U'Wa sustained a successful protest against the mining company, and also won a great deal of international support (Martinez-Alier 2004, 253-254;Arenas 2007). Another pertinent example of a successful discourse of sacred land used to protest against a mining project would be the case of the Australian Mirrar aboriginal people's protest against the Jabiluka uranium mine in Kakadu National Park on the grounds that it would threaten their sacred natural site (Pockley 1999;Aplin 2004). The Mirrar people won the support of several international organisations (O'Faircheallaigh 2012). The study of the representation of indigenous peoples in the context of activism surrounding their relationship to land is an important and under-researched topic (see Radcliffe 2014). This paper aims to contribute to furthering insights in this area by taking a critical look at how strategic representations of indigenous peoples' relationship with land may result in successful struggles against mining. It pays particular attention to the question of if and how far the "romantic imaging" (Banerjee 2016, 132) that is often involved in the representation of indigenous cultures can support the empowerment of indigenous peoples. Furthermore, in regard to indigenous peoples' multifaceted relation to land, it is argued that the very concept of land must be reimagined as ecology rather than land per se, that is, as inclusive of forest, field, minerals, water and animals on the one hand and of specific modes of habitation of and relation to such land on the other. (Banerjee 2016, 144) How would such a relation to land be represented? The paper will employ concepts from two scholars who have dealt extensively with representation: Gayatri Spivak and Jean Baudrillard. The empirical focus of this paper is a case study of a social movement to prevent bauxite extraction on the Niyamgiri Mountain in India which is claimed as sacred by an "indigenous," 1 or Adivasi, group known as the Dongaria Kondhs. 2 Almost 90 percent of the 660-hectare mining lease area is argued to be Sal (Shorea robusta) forest, maintained by a community taboo on cutting trees on Niyamgiri's summit (Padel and Das 2010). The Niyamgiri Movement was successful and prevented the mining project, which, in addition to safeguarding the cultural and natural heritage of the Dongaria Kondhs, resulted in the conservation of the forest on the mountain's summit as well as the regional ecosystem that is ecologically dependent upon it.

Methodology
This paper is based on empirical material consisting of qualitative fieldwork data, official reports, governmental communications and media reportage on the Niyamgiri Movement. Most of the fieldwork data presented below has been paraphrased. The fieldwork for the paper was conducted in May 2011, August 2011, December 2012 and February-March 2013. Nineteen interviews were conducted with activists-most were oral history interviews (Thomson 1998) and the others were semi-structured interviews. Since the Niyamgiri Movement consisted of groups and individuals who were loosely coordinated and in many cases acting unilaterally (see Marshall and Balaton-Chrimes 2016), an effort was made to contact all the key players, as well as representatives of as many of the various organisations who were involved. 3 Interviewees were selected through snowball sampling (see Noy 2008). Even though this did limit access, the movement was ongoing when the bulk of the fieldwork for this paper was conducted and the author who conducted the fieldwork did not experience the flexibility of speaking to groups who may not have wanted each other's voices to be heard. This does not mean that interviewees were seen to be homogenous; expressions of conflict and disagreement between movement participants were clearly discernible for the interviewing author. Many of the interviews were conducted in Bhawanipatna, the district capital of Kalahandi, where the Niyamgiri Mountain is located. A few of the interviews were also conducted in Bhubaneshwar, the capital of Odisha, and Delhi, where some of the activists who were prominent in the Niyamgiri Movement were based. In addition to this, participant observation-based fieldwork was also conducted in Dongaria villages with the view to observe the Dongaria Kondhs' relationship with their land and also to gather the myths and stories they possessed in relation to it. There were several distinct entry points to the sampling. The first was via a prominent Odiya activist who is based out of Bhubaneshwar and who was a key player in the Niyamgiri Movement (introduced to the author who had conducted the fieldwork by a personal contact they had in common). The second entry point was via an academic colleague who had previously done fieldwork in Odisha and who was acquainted with activists and academics in the region. The third was via an international environmental network of which one of the authors is part. Participant observation was also conducted at several protest rallies. Alongside the participant observation-based fieldwork, several conversations were conducted with activists connected with the Niyamgiri Movement or otherwise knowledgeable about it. The fieldwork was conducted in Hindi, English or Odiya, depending upon the preference of the interviewees and the appropriateness of the language to the fieldwork situation. Official reports and bureaucratic documents relevant to the aims of the paper were gathered from institutional websites. Some of these were also procured upon request as scanned copies of official documents collected by activists. Media reportage on the Niyamgiri Movement was also collated and used to elucidate the major developments associated with the Niyamgiri Movement. One interview was also conducted in October 2017 with a film-maker who had been working for Survival International. To ensure the anonymity of the interviewees, no information beyond what pertains to their role in the Niyamgiri Movement is provided.

Background
The Dongaria Kondhs trace their ancestry to Niyamraja, a mythical god-king who is believed to have created the Niyamgiri range of hills and to have charged his descendants with their stewardship. The Niyamgiri range of hills is understood to be the mythical kingdom of Niyamraja that extends across 115 square kilometres (Jena et al. 2002). Niyamraja is understood to be the chief of the gods (of which there are several) of the small hillocks (2002,191). However, the religious practice of the Dongarias consists chiefly of (often animal) sacrifices (Hardenberg 2005) to the Earth Goddess whom they refer to as Dharani Penu, and whose husband is identified with Niyamraja. A shrine is dedicated to her in each village.
In 2002, the UK-based mining company Vedanta Resources started acquiring land for the construction of an Aluminium refinery at the foot of the Niyamgiri Mountain, for which it had signed a memorandum of understanding with the Odisha state government in 1997 (Kumar 2014;Kraemer, Whiteman, and Banerjee 2013). Protests against Vedanta Resources started immediately, and initially, local activist-minded citizens led the protests, including some professional activists who were opposed to the project, and Kutia Kondhs, who, like the Dongaria Kondhs, are part of the larger Kondh group. 4 When it later became known that Vedanta Resources was also planning to acquire and mine the Niyamgiri Mountain, which was estimated to contain approximately 75 million tonnes of bauxite (see Temper and Martinez-Alier 2013), the Dongaria Kondhs, who lived on the mountain and worshipped it, were inducted into the protest movement against the company, and the movement shifted its focus to concentrate on an opposition to the mining project on Niyamgiri. The media reported about the Niyamgiri movement, which caught the attention of the South Asia Amnesty International representative who involved Amnesty International (Interviews, August 2011). Subsequently, other trans-national advocacy organisations such as Survival International and ActionAid began to support the Niyamgiri Movement. These trans-national advocacy organisations staged protests that attracted the attention of the international media which had a domino effect on Indian media coverage of the Niyamgiri Movement.
It is important to note, that at the beginning of the Niyamgiri Movement, opposition on ecological grounds to the bauxite mining project was disregarded by the Indian Supreme Court, and it has been argued that the foregrounding of indigenous concerns within the Niyamgiri Movement came about after this decision (see Krishnan and Naga 2017). It was, in fact, the sacredness of Niyamgiri for the Dongaria Kondhs that was understood to be the key stake in the entire movement by the Indian Supreme Court. It passed a verdict that the Dongaria Kondhs would have the opportunity to decide in their village councils consisting of all adult members of the community as to whether Niyamgiri was sacred to them and whether they were against the mining project. The Dongaria Kondhs emphatically voiced their opposition to Vedanta Resources' mining project on Niyamgiri in twelve village-level referendums. This entire process by which local stakeholders were empowered to make decisions regarding the kind of development they would allow on lands they depended upon was termed India's first "green referendum" (Sharma 2013). Following this, the Indian Ministry of Environment and Forest banned the mining project in 2014.
Most anti-mining movements in India achieve at best a stalemate, with the government and companies waiting out the protestors. The question arises, then, of what made the Niyamgiri Movement successful. Since the sacredness of Niyamgiri for the Dongaria Kondhs was understood to be the key stake in the entire movement, this article will try to answer this question by looking at representations of the Dongaria Kondhs' religiosity at various scales and how these may have facilitated the Niyamgiri Movement's success.

Theoretical Framework
Representation has been a key concern within academic theorising (Andersen and Harrison 2010;Castree and MacMillan 2004). This paper will employ the theories of two prominent theorists of representation-Gayatri Spivak and Jean Baudrillard. Both have combined their analyses of representation with critiques of capitalism, and solutions to its hegemony, but their conceptualisations have not been previously employed in combination to shed light on the problems of representing indigenous peoples' struggles. Gayatri Spivak criticises the activist practice of representing, i.e. speaking for and about marginalised individuals and groups-these are referred to as subalterns by postcolonial theorists. She argues that activism is necessarily implicated in a Western/Northern epistemology (even if it is enacted by activists from the same geographical locale as the people they represent) and that activists can't help but impose this epistemology upon the consciousness of subalterns while representing them (Spivak 2004). Thus, representing marginalised non-western individuals and groups would not necessarily free them from domination. Nevertheless, refraining from representing subalterns for the reason that such representations may not be accurate has also been criticised by Spivak (Kapoor 2004) as well as by other scholars (Alcoff 1991). It has also been argued that it is possible to mediate the consciousness of subalterns through a process of translation (Maggio 2007), despite the fact that this may only "'capture' an aspect of the original" (437). According to Maggio (432), "a translation can actually 'elevate' the original, and the task of the translator is to 'echo' the original in a way that helps illuminate the intended meaning." It is important to mention, that though the translation of the subaltern's consciousness implies mechanisms that would render it more mainstream, this is not the same as saying that the translation must necessarily occur in Westernised terms. The translation of the subaltern into an icon termed the subaltern-popular, which has been discussed as possessing appeal for mainstream Indian society (Ghosh 2005), is also of relevance to this paper. It can be understood as the result of the construction/translation of the subaltern into a figure in popular culture, by means of a process involving collective, participatory consumption, and by the evocation of realities that have resonance for its consumers/creators (Ghosh 2005).
Similar to Spivak's critique of the marginalisation of the subaltern, the theorist Jean Baudrillard notes that capitalistic discourse marginalises a mythic consciousness, which he describes pre-literate societies as possessing (Baudrillard 1975). He refers to capitalistic discourse as "the code," i.e. the discourse of contemporary times, which in his understanding is an interrelationship of signs, or simulacra, that is created by capitalism in order to consolidate its hold on people's imagination. The Baudrillardian solution to capitalism's semiotic stranglehold is to "seduce" a reversal of capitalism by "enchanted" simulacra (Merrin 2010) that allow for the imagination of a different, non-capitalistic reality. Baudrillard defines seduction as involving "a mastering of the realm of appearances" (1988, 62;quoted in Merrin 2010, 98) in "a game of signs creating a symbolic relationship" (Merrin 2010, 98). Using "enchanted simulacra," as theorised by Baudrillard, is argued by scholars of communication to be one of the strategies of two other significant examples of environmental communication-Rachel Carson's "Silent Spring" and Al Gore's documentary "An Inconvenient Truth" (Cramer and Foss 2009).
By "enchanted" simulacra Baudrillard means simulacra of a fantasy or a myth capable of stirring emotions, which, in order to counter the code, would have to come from outside it. However, could an enchanted representation of indigenous people who embody the antithesis to the code prove to be both effective at challenging the code (Baudrillard) as well as empowering for the indigenous people (Spivak) who are thus represented?
The question of representing the indigenous subaltern has a rich trajectory in the field of Adivasi studies, as Banerjee (2016) describes. In fact, as per her understanding, the representation of Adivasis as existing outside capitalist modernity was actually colonially expedient (2016). During colonial times, "to the colonised the 'tribe' would appear as the 'primitive' and precisely therefore, potentially the last location of the pure, if extrarational, moment of resistance to colonial modernity" (Banerjee 2006, 101). In India Adivasis have for long "typified geographical, cultural and economic separateness" (Rycroft and Dasgupta 2011, 4) which allowed them to be distinguished from "the institution of 'caste,' and from organised religions like Hinduism, Islam and Christianity" (2011, 3). From the 1980s onwards the "political imaginery" (Banerjee 2006, 99) of the Adivasi "was emerging as the location of a more fundamental critique of modernity itself" (Banerjee 2006, 108). However, according to Alpa Shah, the representation of indigenous people as opposed to modernity and "as representing the core values of the eco-community" is problematic (Shah 2007(Shah , 1824, as this may not resonate with the lived realities of Adivasis. It is this discourse that this paper will further expand upon.

Representational Strategies in the Niyamgiri Movement
Actors involved in the Niyamgiri Movement were distributed across various spatial scales. The Dongarias constituted the group closest to the geographical site of protest; local grassroots-level activists from the small urban centres surrounding Niyamgiri constituted a second tier of activism. Some trans-national advocacy organisations were also active at this scale. Professional Indian activists at the national scale formed a third tier (however, this will not be discussed in much detail in this paper as these activists played only a marginal role in shaping the discourse of Niyamgiri's sacredness). Finally, the movement was supported at the international scale by transnational advocacy organisations.

Advocacy at the International Scale
It is this paper's contention that internationally, the Dongarias' mythic consciousness or religiosity was represented "enchantedly" and that this underlying strategy was largely responsible for the sympathy that the Niyamgiri Movement attracted. The international advocacy group Survival International represented the Dongaria Kondhs by comparing them to the fictional indigenous tribe in Avatar, a Hollywood blockbuster directed by James Cameron, which depicts a tribe battling a mining company to protect a planet called Pandora which they worship as a Goddess.
The film, and the representation of the Dongaria Kondhs in relation to it, are important for an understanding of the Niyamgiri Movement. As one of the Supreme Court lawyers, who is part of a collective of activism-oriented environmental lawyers and who represented the Dongaria Kondhs, argued, the turning point in the Niyamgiri Movement occurred when Time Magazine published an article on the Dongaria Kondhs being the real-life Avatar tribe. He argued that subsequent to being represented in this way by the international media, Indian government officials started expressing support for the Dongarias and their struggle: What was the turning point … say … when Time Magazine did a story on the Dongaria Kondhs being the modern-day Avatar. (Supreme Court Lawyer, March 2013) Avatar is supposed to have been director James Cameron's dream project, and is an expression of his explicit support for indigenous cultures and nature conservation, with the help of 3D technology (Taylor and Ivakhiv 2010, 386-388). He is quoted as saying that "Avatar asks us all to be warriors for the earth" (Holtmeier 2010, 420), and his political commitment to the film's message is evidenced by his donation of some of its proceeds to reforestation projects in South America (Taylor and Ivakhiv 2010, 389). Following the release of the film to packed cinema theatres, not coincidentally in the same week as the 2009 Copenhagen Climate Summit (Istoft 2010, 401), many indigenous activists from all over the world started expressing praise for its theme. Survival International, which had made a short documentary on the Dongaria Kondhs' struggle, appealed to the director to support the struggle in an advertisement in the entertainment magazine Variety worded as follows: Avatar is fantasy … and real. The Dongria Kondh tribe in India are struggling to defend their land against a mining company hell-bent on destroying their sacred mountain. Please help the Dongria. We've watched your film-now watch ours. (quoted in Thottam 2010) The advertisement was not the only parallel drawn between the Dongarias and the Na'Vi. Survival International activists, painted in blue to resemble the Na'vi, protested in front of Vedanta's offices in London with placards that read "save the real Avatar tribe." This kind of imagery played a major role in sensationalising the movement, attracting the interest of the national and international media, and sensitising the general public to the Dongaria Kondhs' emotional attachment to Niyamgiri. This paper argues that the image of the Dongaria Kondhs as the "real Avatar tribe" functioned as an "enchanted simulacrum." It was a fantastic representation, which elicited strong emotional reactions, as well as reflections, by way of its connection to a film aimed at generating popular support for indigenous peoples' causes and environmental conservation. The film itself can be said to have worked as an "enchanted simulacrum." Viewers of Avatar at times reported that they experienced what has been termed Na'vi sympathy-"the urge to use the film to reflect on, and spur action in, their own earthly world" (Holtmeier 2010, 419). Apparently, several viewers were converted to more ecological ways of living after watching the film (Holtmeier 2010, 421-422). In this way, by being compared to the tribe in Avatar, a film which incited both emotions and a questioning of capitalistic logic, the Dongaria Kondhs were presented as "enchanted," and audiences across the world were perhaps convinced that choosing to side with them was far more appealing than Aluminium production. That the representation of the Dongarias as "enchanted simulacra" was well-received can be seen in the Indian bureaucratic-official response to it. The statement of one of the Supreme Court judges charged with adjudicating on the Niyamgiri case is evocative of the sympathy that the representation of the Dongarias' religious feelings for Niyamgiri had garnered. As quoted in Balaji (2013): Even if nothing is there, you can't destroy the faith of those people. We are not talking about the entire hills but the highest point where the tribals believe their God exists. They believe he is on the hilltop. Can you tell them, "take away your God to another place"? Are you banishing the God? (Supreme Court Judge, February 2013) There were also other representational strategies that "translated" the Dongaria Kondhs' religiosity-one of these was a documentary film on the movement, made by Survival International (2009), the YouTube version of which has received 767,658 views (as of December 15, 2019). Survival International portrayed the Dongarias as worshippers of Niyamgiri, without describing in clear terms what their form of worship entailed. Interviewees mention that the Dongarias performed puja to Niyamgiri. Puja implies ritual sacrifice, but in the English subtitles of the documentary, the word was translated as worship. Hence, it was not specified that the Dongarias' ritual practice consisted chiefly of sacrifices, which, as mentioned earlier, often involved the sacrifice of animals. Furthermore, in the documentary, the Dongarias assert that Niyamgiri was their Devi, meaning Goddess-which, in the film, is translated as God. Also, the religious focus in the documentary is almost entirely on Niyamraja, who is depicted in what could be described as Biblical terms (Survival International 2009).
The fact that politically expedient representational strategies were deployed in the making of the documentary was attested to by the film-maker. In the interview that was conducted with him for this paper, he said that as an activist filmmaker his concern has always been the production of a film that can strike a chord with its intended audience. He expressed that for him accurate representation is sometimes sacrificed in the interests of conveying a message that is simple and familiar. He said that the documentary's Biblical undertones were not an accident-the rationale being that this would allow the audience to relate to the Dongarias. Furthermore, according to him, the Dongarias' religiosity was far more diffuse than its representation in the film (Interview, October 2017). The Survival International film can thus be argued to be a translation which simplified the message of the Dongaria Kondhs' religiosity and which removed the aspects of it that would detract from their worship of Niyamgiri.

Advocacy at the Local Scale
ActionAid, though an international advocacy organisation, played an important role in shaping the discourse of the Dongarias' religiosity at the local scale. In 2008 it started a process of organising/staging mass worship ceremonies on top of the Niyamgiri Mountain (Kraemer, Whiteman, and Banerjee 2013, 838) at a place called Hundaljali. Initially, ActionAid faced criticism from local activists for this interpretation/invention of the Dongarias' religiosity-mass worship being seen as inconsistent with Dongaria Kondh customs. Later on, however, local grassroots-level activists realised what the political potential of the mass worship ceremony that ActionAid had initiated was, and participated in organising their own version of it (Kraemer, Whiteman, and Banerjee 2013, 846). One of the active participants in the Niyamgiri Movement from the Kutia Kondh community described the process by which the ancient reverence for Niyamraja was reinvented as the worship of a deity at a particular site.
Two years ago, we made a temple on top of the hill where the bauxite mining was supposed to take place. Soon after we built the temple, the thugs hired by Vedanta broke it. When we protested against this, they did not admit that they had broken the temple. On the 27th of February we performed worship for Niyamraja and made a vow that we will not leave Niyamgiri. We made this vow with rice and blood and promised that we would fight forever. (Local activist from Trilochanpur village, August 2011) The Dongarias, along with members of other Kondh tribes such as the Kutia Kondhs, have been performing ritual worship to Niyamraja at this temple, at a festival which activists have instituted to take place every year. As mentioned earlier, this temple and site (known as Hundaljali) became one of the foci of discussion during the Supreme Court proceedings in February 2013. A second modification to Dongaria Kondhs' religious practices can be seen in the fact that the animals sacrificed during the ceremonies at the newly instituted ritual site were goats-the sacrifice of which is an accepted part of mainstream Hindu culture, unlike the buffaloes which the Dongarias Kondhs usually sacrifice.
The representational role of local activists vis-à-vis the Dongarias' religiosity may have been both strategic, as well as the result of their discursive repertoire only allowing them to perceive and assist the Dongarias in an emphasised expression of their religiosity in the way most in alignment with this repertoire. It can also be seen as an instance of the construction of the Dongarias as the subaltern-popular, i.e. an icon that is constructed in a local context, finds resonance with the lives of its consumers/creators and allows for articulations of "more amorphous desires for identity" (Ghosh 2005, 465). In other words, by organising mass worship ceremonies at which the Dongarias participated and that were resonant with Hindu culture, local activists were able to translate or construct the Dongarias as figures they could relate to. The Dongarias' religiosity was also translated into terms that mainstream Hindu society could identify with and perhaps even aspire to. This translation has been referred to as a "photographable spectacle" by Prakruti Ramesh (2016, 172) in her discussion of the "performance of proof" required of groups like the Dongaria Kondhs to access the rights that the Indian government grants to forest dwellers. Ramesh describes how the Dongaria Kondhs enacted a spectacle that proved their indigeneity, thereby emphasising the legitimacy of their cultural claim to the Niyamgiri hills, which hinged on a "rhetorical and performative apparatus that was instrumental in giving unprecedented visibility to the vulnerability of the Dongria Kondhs and their fragile environs" (2016,172).
Activists' attempts to encourage the Dongarias to worship a specific site, as marking the presence of a deity, was arguably a major reason for the movement's success-a religiosity claiming specific territory finding better purchase within the contemporary legal discourse. Coupled with the romanticised portrayal of the Dongarias' religiosity at the international level, which generated much media coverage and sympathy, the ground was set for the victory of the Dongaria Kondhs' struggle against Vedanta Resources.
However, this representation of the Dongaria Kondhs' religion could have also proven to be restrictive for the movement. For example, both Survival International and ActionAid referred to the Dongarias' worship of the top of the mountain, as well as to the Dongaria Kondhs' "sacred mountain" (Survival International, n.d.; see also ActionAid 2007). In Supreme Court proceedings there were assertions that it was not a question of banning bauxite extraction on "the entire hills but the highest point where the tribals believe their God exists" (Balaji 2013), i.e. the recently established site of the Dongaria Kondhs' worship of Niyamraja. Banning the extraction of one of the world's richest reserves of bauxite-the Niyamgiri range of hills-would be a costly decision for the Indian government, and the attempt to narrow the focus of discussion to one site was arguably an attempt to restrict the scope of potential financial losses associated with siding with the Dongarias.
The representation of the Dongarias as worshipping a specific site did have currency within the Indian juridical framework of religious rights, and it eventually led to the referendums held by the Dongaria Kondhs' communities in which they determined if Niyamgiri was sacred to them. A representation of a general and undefined Earth-based spirituality would have been harder to deploy in the claiming of religious rights over a specific site-though the Dongarias' supporters are unlikely to have objected to deploying it if it promised a similar chance of effectiveness. While the referendums referred to a specific site, they provided the Dongaria Kondhs with the opportunity to represent their religion as they understood it, i.e. they claimed that the whole Niyamgiri range of hills was sacred to them.

Discussion of the Reasons for the Effectiveness of the Movement's Representations
Representations of the Dongaria Kondhs in the context of the Niyamgiri Movement were effective in garnering support for the banning of Vedanta Resources' mining project. As most anti-mining movements in India achieve at best a stalemate, we go on to discuss the effectiveness of the representational strategies in this particular case.
A common theme running across these representations was a focus on the Dongarias' ecological beliefs and religiosity, rather than a focus on their material vulnerability and related impact from the mining project. In other words, activists successfully focused on the appeal of indigeneity, which is understood to be linked to general perceptions of the ecological morality of indigenous people. Contemporary scholarship on the support for indigeneity (Dove 2006;Kuper 2003;Hames 2007;Barnard 2006) does discuss (and critique) its aesthetic appeal, arguing, for example, that this is derived from celebrations of a primordial Urkultur (Barnard 2006), nostalgia born of dissatisfaction with the delocalisation produced by modernity (Appadurai 1996), or Western quests for native or aboriginal wisdom (Pieck 2006). The growing support for indigeneity at the international institutional level (Merlan 2009;Muehlebach 2001) is reported to acknowledge the "politics of morality" that indigenous peoples are seen to deploy against the ecological failures of modernity (Muehlebach 2001, 424). As mentioned earlier, since the 1980s the trope of the Adivasi was emerging at the national scale in India as a contestation of modernity (Banerjee 2006). At the local scale in Odisha as well, there exists a historical-cultural understanding that casts Adivasis in the role of forest kings (Rousseleau 2009), and this too can be seen as an ecologically romanticising discourse which adds to the appeal of the Dongaria Kondhs' ecological lifestyle as perceived at the local scale.
However, other scholars have argued that an eco-politics that freezes indigenous peoples as ecologically moral, can be potentially disempowering for them (Grande 1999;Conklin 1997). The symbolic politics that characterises this kind of activism can silence indigenous peoples by encouraging them to construct themselves in a way that fits into this discourse (Conklin 1997). A similar strategy of encouraging Native Americans to live in national parks in accordance with their traditional lifestyles (Rashkow 2014), has also been criticised by scholars as being essentialist. It has been argued that discourses such as these offer indigenous peoples ecological rights and agency as incentives for adhering to standards of ecological stewardship that may not, in fact, be theirs (Lindroth and Sinevaara-Niskanen 2013). Nevertheless, scholars argue that these discourses should not be dismissed because they do provide indigenous groups room for manoeuvre, as well as a means for articulating, negotiating and legitimising their concerns (Agrawal 1997;Li 1996).
Spivak advises that strategies such as these be examined very critically. To cite Drucilla Cornell, a noted scholar of Spivak's theories, the other that we hear because he or she speaks to us in our language and through our forms of representation has already been assimilated, and thus appropriated, by the subject who represents him or her. If that representing subject is in the entitled position that this other is denied, then the representation will always be contaminated by that very entitlement. (Cornell 2010, 104) In the case of the Dongaria Kondhs, however, it is seen that they went beyond aligning themselves with the narratives propounded by activists.
While the Dongaria Kondhs started participating in the Niyamgiri Movement in 2004 and were active participants in rallies against Vedanta Resources, their voice was strongest at the end of the Niyamgiri Movement, during the referendums which the Indian Supreme Court had adjudicated should be held. During the village-level referendums, altercations occurred between the judicial observer appointed to moderate the council proceedings and the Dongarias. The Dongarias attempted to assert that they claimed community rights over the entire Niyamgiri range of hills of which the Niyamgiri Mountain is only a part. During the first village council/referendum or palli sabha, articulations such as these were met with sharp retorts and opposition by the judicial observer-he is reported to have insulted the Dongarias and insisted that they could not claim religious rights over the whole Niyamgiri range of hills. However, when the Dongarias remained adamant and continued to insist that the entire Niyamgiri range of hills was sacred to them, he finally capitulated and agreed to mentioning that the Dongarias claimed community rights over the entire Niyamgiri range of hills. In the palli sabhas held later (twelve were scheduled by the state government), villagers rejected the imposition of restrictions on their sites of religious affiliation and made similar claims as in the first palli sabha (Jena 2013). The Dongaria villagers who participated in the referendums all voted against the mining project, in a demonstration of what has been described as "a stunning example of grassroots democracy at work" (Survival International, n.d.). This collective decision was ratified by the Indian Ministry of Environment and Forest in January 2014, with the conclusion that Vedanta Resources was denied the continuation of its mining project on Niyamgiri (Goswami and Mohanty 2014). In legal terms, the Dongarias claimed habitat rights to the Niyamgiri hill range under the Indian Forest Rights Act which was enacted in 2006 (see Ramesh 2016). Under the Forest Rights Act, habitat rights are a form of community tenure over traditional territory that are granted to groups such as the Dongaria Kondhs who are categorised as PVTGs (Particularly Vulnerable Tribal Groups). Ramesh describes habitat rights as a legal concept that environmental activists are in the process of comprehending, and it is not clear whether these rights were, in fact, granted to the Dongaria Kondhs, or whether specifically Vedanta Resources' mining project on Hundaljali was banned. Ramesh also contends that the Dongaria Kondhs' performance of indigeneity, enacted by way of the worship ceremonies on top of the Niyamgiri Movement, was aimed at securing habitat rightshowever, our fieldwork does not indicate that the Dongaria Kondhs and the activists who supported them had this specific goal in mind, and what makes it more unlikely is that the term "habitat rights" became current during later Supreme Court proceedings related to the Movement (and as previously mentioned, it is a term that environmentalists and tribal rights' activists are still trying to understand).
The use of the national, legislative framework would not have been possible without previous activism at the local level. Here, the Dongaria Kondhs became first actively involved in representing and reshaping their religious practices for an Indian audience, to then use the referendums to voice their very own understanding of their relationship with the Niyamgiri Mountain. We may speak of co-representation, in the sense of "co-construction," as the Dongarias joined in the representational strategies initiated by local activists. With regard to the international, mediatised level, it may not be possible to argue that representation of the Dongarias' religiosity was co-constructed by them and by their supporters. However, it cannot be denied that their fantastic, or "enchanted," representation, as comparable to fictional characters from the film Avatar, was effective. The Dongaria Kondhs' relationship with Niyamgiri was also made familiar and evocative of general sympathy by a reference to Hollywood cinema that would be understood by society. With regard to Survival International's documentary, it can be argued that the Dongarias were represented in a manner that is reminiscent of Baudrillard's description of the fate of a tribe known as the Tasaday (see Baudrillard 1994, 7-9)-i.e. as isolated and as subsisting outside capitalistic modernity, but in the Dongarias' case perhaps this enchanted representation, together with the above-mentioned fantastic representation, had power enough to challenge the code. It helped them gain empathy for livelihoods pursued outside of the capitalist realm and simultaneously threatened by it through, e.g. mining activities.

Conclusion
It has been argued that there is need for more research that looks into how activism employs representation to depict indigenous peoples' relationship to land (see Radcliffe 2014). This paper contributes an empirical case for the analysis of which postcolonial theorists of representation were used that explore issues of subalternity, together with Jean Baudrillard's concept of "simulacra." The paper explored how activists at international and local scales translated the Dongaria Kondhs' religiosity in ways that attempted to capture and condense it for particular audiences, as opposed to delineating its complexities. Some of these representations can be argued to have portrayed the Dongarias as "enchanted simulacra," whereas others rendered the Dongarias' religiosity more familiar in the eyes of mainstream Indian society. Furthermore, it appears that the Dongarias did not feel they needed to contain their religiosity to fit into these representations and indeed used these representations as a platform from which they could finally voice themselves. The activism surrounding their struggle spoke for them up to a point and managed to bring about a change in bureaucratic-legal responses that finally allowed the Dongarias to speak at the referendums ordered by the Indian Supreme Court. And when they did, they did not stake claim to a particular site which would be affected by mining-rather, they claimed that the entire Niyamgiri range is sacred to them and deserving of protection. While their supporters at the local, national and international levels largely supported this claim, it was not an explicit part of the movement's articulations. What remains questionable and is yet to be determined is whether this claim was heard. Mining was banned on top of the Niyamgiri Mountain, at the site known as Hundaljali, which activists had constructed as the locus of the Dongarias' religiosity. The ban does not extend to the entire Niyamgiri range of hills, even though it was claimed as sacred by the Dongarias. Subalternists have argued that subalternity is the condition of incomplete appropriation by the dominant discourse, due to incommensurability (Byrd and Rothberg 2011). But in the case of the Dongaria Kondhs, the possible future denial of their articulations vis-à-vis their religiosity (i.e. their claim that the entire Niyamgiri range of hills is sacred to them and must consequently be protected), will not arise from an inability to hear them, but perhaps from an unwillingness to do so. If so, will this, nevertheless, still be an indication of their subalternity? Temper, Leah, and Joan Martinez-Alier. 2013