“WE WILL GIVE OUR BLOOD, BUT NOT OUR LAND!”—REPERTOIRES OF RESISTANCE AND STATE-ORGANIZED LAND-GRABBING AT A BANGLADESHI TEA PLANTATION

: Land-grabbing is an international issue closely associated with conflict and violence, as communities confront, through prolonged struggles, powerful elite networks involved in the illicit transformation of space. Resistance to land confiscations can be a life-and-death struggle especially for poor rural and urban communities whose liveli-hoods are tied to the targeted land. Because these struggles are often marked by corruption, state violence, and the persecution of already marginalized populations, they have become an area of emerging interest for state crime and state-corporate crime scholars. However, there is only introductory data mapping how communities resist land-grabs engineered through illegitimate state-corporate activity. Against this backdrop the following paper analyses a case of community resistance to land-grabs in Bangladesh using a contentious politics framework and the concept of land-laundering. The structure and activity of this resistance has been mapped through interviews with stakeholders involved in this struggle, complemented by documentary research.


Introduction
Land-grabbing and associated abuses, such as forced eviction and home demolitions, have emerged over the past two decades as a significant international human rights issue and an arena of serious political conflict.The phrase land-grabbing denotes that this process often takes place at the intersection of the licit and illicit.On the one hand vulnerable communities, both rural and urban, frequently hold insecure forms of tenure, which can in turn be legally or illegally extinguished by state-corporate networks, using licit and illicit forms of influence over political and judicial decision makers.
Produced and distributed by Pluto Journals www.plutojournals.com/scj/These dynamics have been accelerated and intensified by a liberalized phase of globalization rooted in the financialization of industrial capital, and the internationalization of production chains, which has presaged a worldwide land rush spearheaded by extremely powerful multinational companies that use their market position to extract monopoly rents from supply chains (Borras et al. 2011;Hall 2011).Given that the acquisition of land from vulnerable occupants/landowners frequently involves such things as the abuse of power by senior state officials, corrupt state-corporate interactions, fraud, and state-corporate violence, landgrabbing has become a specific focus for inquiry by state crime and state-corporate crime scholars (Green and Smith 2016;Lasslett 2018;Rhoads 2018).Green and Smith (2016), for example, examine how urban planning and housing laws have been weaponized by the Israeli state to displace Palestinian communities.Rhoads (2018) has documented a process of colonial and closely tied post-colonial dispossession in Myanmar, which has been deployed as a mechanism for population control and self-enrichment of regime figures.In Papua New Guinea, Lasslett (2018) documents how customary and state-owned land is violently expropriated by corrupt networks of senior state officials and corporate actors, looking to cheaply extract natural resources (e.g.illegal logging) and realize monopoly rents from urban real-estate developments.These studies have demonstrated not only the illicit dimensions of land-grabs, they also point to systematic forms of resistance mounted by local communities.This ties into the wider scholarship on land-grabbing.Indeed, not only does the land-grab literature identify the role played by elite actors-corporate, state, and individual actors who are actively involved in grabbing lands worldwide-it also documents the resistance mounted by less powerful actors in the social structure (Cochrane 2011;Rocheleau 2015;Hall et al. 2015;Borras and Franco 2013;McAllister 2015).
For example, the land-grabbing literature has documented cases of economically marginalized communities, such as wage labourers, marginal peasants, sharecroppers, agricultural labourers, migrant labourers, petty commodity producers, minority, and indigenous communities, involved in resisting a wide range of large-scale projects such as hydropower projects, special economic zones (SEZ), agribusiness, and commercial shrimp cultivation implemented by state agencies and powerful corporate actors (Chowdhury 2014;Bedi 2015;McAllister 2015;Sampat 2015;Adnan 2013).
The resistance process in an episode of land contention is not arbitrary in nature.It follows a structured pathway through which the "contenders" resisting the grab create opportunities at multiple scales, to advance their interests in the terrain of a claim-making process (Tilly 1995).However, as Hall et al. (2015: 471) observe, "social groups that were expelled or threatened with expulsion by land deals, or whose livelihoods are threatened more generally, do not automatically get State Crime 12.1 2023 organized and mount resistance".The resistance process seems to be influenced profoundly by localized cultural contexts and traditions of activism (Moreda 2015).
This paper intends to document local trajectories of successful resistance to "land acquisition" (albeit referring to this process as "land-grabbing") undertaken by tea plantation workers in Bangladesh.This paper explores the trajectories of a claim-making process that involves state actors and a marginalized rural community, the emphasis, however, is on understanding resistance as a process that unfolds iteratively.In order to understand the resistance trajectories to land-grabbing initiated by tea plantation workers in Bangladesh, this paper conceptualizes the resistance process employing the contentious politics framework developed by Charles Tilly (Tilly 1978(Tilly , 1995)).By applying this framework, the paper aims to analyze the empirical data to discern features of the resistance struggle that enabled the community to elevate and effect its claims, bringing about a favourable resolution.
To better understand how and why resistance may succeed with respect to landgrabs, we introduce the concept of land-laundering.Land-laundering conceptually captures a process whereby land acquired illegitimately is then cleaned by the state through a range of techniques and then reintegrated into the market economy with assistance from benefiting corporate investors, unless that is, the process is materially and symbolically disrupted through resistance campaigns.It is used here as an analytical mechanism to think about how state-corporate interests converge in regions impacted by systemic land-grabbing.
To begin this paper will outline the methodology underpinning this case study.Attention will then turn to outlining the key actors involved in this episode of contention.The events which triggered the contention will then be traced, before analysis is conducted of the subsequent resistance process, teasing out critical features which allowed the tea labourer community to successfully disrupt the land confiscation effort organized by the state.

Methodology
Contentious politics emerges where and when ordinary people are engaged in confrontation with powerful actors-elites, authorities, and opponents-in order to make claims that help to advance their shared interests (Tilly 1978;Tarrow and Tilly 2007).The study of contentious politics, therefore, focuses on the collective political struggles of challengers to a political decision.It analyses how these contenders create opportunity in an episode of contention by using collective actions, social networking, and activist repertoires.As in-depth empirical studies of resistance to state crime begin to emerge within the field (Green and Ward 2019;Lasslett 2014), informed by important initiating interventions (see e.g.Stanley and Produced and distributed by Pluto Journals www.plutojournals.com/scj/McCulloch 2013), contentious politics offers a developed conceptual framework for designing and implementing such research.It offers, in other words, a set of orienting concepts for analytically breaking down resistance to state crime into its core constituting features, both on an intra-case basis and comparatively.
Against that backdrop this study has employed a contentious politics framework to systematically inquire into cases of resistance to land-grabbing in Bangladesh, marked by evidence of illegitimate state-corporate activity.Fieldwork took place during 2018 and involved evidence gathering from a number of different contentious land-grabbing struggles, including the Santals in Gaibandha, indigenous communities in Chittagong Hill Tracts, the Baptist community in Barisal, and plantation workers from the Chandpur Tea Estate situated in the Sylhet region.Empirical evidence was gathered through semi-structured interviews, which were triangulated with documentary sources such as archival records, the reports of civil society organizations, and media accounts.While communities struggling to prosecute their land claim welcome interest from researchers, traversing complex terrains to access marginalized communities is a delicate process in Bangladesh.Drawing on one of the author's previous professional experiences working with marginalized communities in Bangladesh in the notfor-profit sector, attention was paid to accessing communities in observance with local community norms.Familiarity with the political context, the socio-linguistic nuances of different regions, and having past experience supporting grassroots movements, allowed for intimate and engaging interviews with activists and community leaders.Ethical approval for this work was obtained from Ulster University.
This paper focuses on the specific case study of the Chandpur Tea Estate workers.Given that they were successful in repelling a state campaign of persecution and fraud, this case offers important insights into the social components of effective resistance to state crime.Data collection in the tea plantation case consisted of 25 semi-structured interviews conducted over two months.Participants were selected on the basis of their roles and activities in the land contention and resistance processes.For example, members of the affected community were identified using multiple methods, including identifying individuals who spoke for the community in the media, worked as liaisons with NGOs, led on activist campaigns, led on legal campaigns, acted as plaintiffs and witnesses for court cases, or who have been clearly identified as community leaders by local NGOs and media.Also, the study needed to gain access to gatekeepers within the resistance movement, including NGOs, community groups, journalists, and researchers, who also constituted actors in the struggle.Interviews were supplemented by a review of case documents, such as the relevant laws, government reports, legal records pertaining to the land acquisition process, alongside the secondary literature, including NGO publications and journalistic accounts.Triangulated data were then thematically analyzed using a deductive approach informed by the categories of contentious politics theory.

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Pseudonyms have been used for direct quotes from respondent interviews.This is in line with the ethical protocol of the study, approved by the university ethics committee.

Actors in the claim-making process
The Chandpur Tea Estate was established in 1890 and is situated in the Sylhet region of Bangladesh.It comprises the Begum Khan, Jualbhanga, and Ramgonga tea fields.The gardens occupy 3,951.14acres of land, of which 2,053.74 acres of land is for tea plantation, 116.14 acres is for rubber plantation, 985.33 acres is for growing crops (of which 512 acres have been cultivated by tea plantation workers), 467.65 acres is for the plantation company's infrastructure, 254.15 acres is for growing timber, grass, bamboo, and a large portion of this land was also covered by natural forest (Gain 2016).The workforce in the garden comprises approximately 2,130 people, who work primarily as tea plantation workers.
The process of resistance in the tea plantation case began when the Bangladesh Economic Zones Authority (BEZA) acquired a total of 512 acres of land from the tea garden area, which tea plantation workers had used to grow crops for over 150 years.The initial attempt involved physical acquisition, but this was aborted after government agents encountered significant community opposition.Three principal actors became involved in the subsequent contentious political process, namely BEZA, Duncan Brothers (Bangladesh) Limited, and tea plantation workers.
BEZA-an affiliated organ of the Prime Minister's Office-came into existence on 9 November 2010, through the BEZA Act 2010.The legislation states that, in order to accelerate economic growth in Bangladesh, the newly formed BEZA intends to establish "Economic Zones" (SEZs), known as specialized economic corridors, across the country.BEZA has targeted for acquisition approximately 74,131.61acres of land where 100 SEZs will be established by 2030 (Bangladesh Economic Zones Authority no date).The objective of this model is to attract individual investors, both foreign and domestic, who will set up industries in the SEZs.This is achieved by providing financial incentives and benefits such as the exemption from income tax, value-added tax, and custom and excise duty.It is, moreover, anticipated that employment opportunities-an estimated 10 million jobs-will be generated through the endeavour, according to the architects of this model (Bangladesh Economic Zones Authority 2016).
Speaking at a general level, the creation of SEZs has become a popular device internationally, especially in the Global South, ostensibly to prime economic growth and developmental goals.The creation of SEZs commonly includes various kinds of infrastructure, including airfields, ports, manufacturing industries, agroindustry, car parking facilities, and roads/highways, which leads to mass Produced and distributed by Pluto Journals www.plutojournals.com/scj/acquisition of land (Zoomers 2010).This frequently involves instances of force, corruption, and fraud, designed to displace residents and communities (Lasslett 2018).Zoomers (2010: 437) observes, "at an increasing number of places, efforts towards economic growth and the attraction of foreign investments are accompanied by the forced displacement of the local population, under what is known as 'development-induced displacement'".This has been observed in China, India, Thailand, and Cambodia, where local communities have been evicted by governments to set up SEZs for a range of purposes.China and India are the highest ranked countries in the world in terms of setting up SEZs in their landscapes (Cowaloosur 2014;Zoomers 2010).Not only has China set up SEZs locally, but it also has exported the SEZ model to many African countries, including Nigeria, Ethiopia, Egypt, Zambia, and Mauritius (Cowaloosur 2014).Countries such as Bangladesh are attempting to emulate this example.
SEZs can, in this sense, become a device for what we call in this article landlaundering (Ballvé 2014), drawing from the concept of money laundering with its associated processes of layering and reintegration (Platt 2015).Like money, land can become "dirty" when it is acquired or transferred through illegitimate means that violates established rights and norms.How "dirty" this process appears to be in the eyes of social audiences will be mediated by the social significance of the rights and norms violated, the capacity of different communities to visibly sanction the violation, and the positionality of the witnessing audience (Green and Ward 2000).The state is in a position, however, to clean "dirt" from the land generated by dispossession, through a layering process, that draws from its sovereign resources.Governments can pass laws, authorities can issue decisions and make administrative determinations expropriating land, coercive powers can be used to eject occupants or to cow them into signing compensation agreements.These efforts, in effect, layer over the material and symbolic claims made by the existing owners to give the ostensible appearance of a legitimate process taking place.Cleaning land through this layering process, it should be said, can itself be a dirty process involving, for instance, state organized fraud and illegitimate applications of violence.
Rights violations, and subsequent frauds and abuses, when contested by impacted communities, can be further cleaned by judiciaries who issue edicts validating state efforts, which symbolically trump claims of unlawfulness made from below by the dispossessed.Through these different licit and illicit conduits the illegitimate acquisition of land is cleaned of its illicit origins.The state can now issue "legitimate" tenure to investors, who unlike the banks in receipt of suitcases of dirty money, are generally under no legal obligation to conduct due diligence on the landed wealth they will now reintegrate into the market economy through capital investment.In effect the laundering process creates a regime of permission, where corporate investors can acquire illegitimately transferred land, because the state has used its superior symbolic and coercive arms to clean the title (Whyte 2014).The state on the other hand can improperly use its executive, judicial, and coercive powers to expropriate the land and launder it, because corporate investors are able to acquire and reintegrate it without conducting due diligence checks.Resistance in this respect is about using resources from below to disrupt, impede, and prevent the laundering process, to ensure the illegitimately acquired land remains dirty so it cannot be incorporated back into the legitimate market economy.
In the case examined in this article, the target of expropriation for BEZA was land surrounding a tea plantation operated by Duncan Brothers (Bangladesh) Limited.Duncan Brothers (Bangladesh) Ltd is currently owned by the UK public limited company, Camellia PLC.Camellia PLC is an international plantation company with interests in India, Bangladesh, and East Africa (Camellia PLC 2020).Its principal shareholder is Gordon Fox, a Canadian investor based in Switzerland.Duncan Brothers (Bangladesh) Limited, owns a total of 16 tea gardens in Bangladesh, including the Chandpur Tea Estate, where the episode of land contention emerged.
The origins of the labouring community occupying this land lie in the region's colonial plantation history.When the tea cultivation in the Bengal region of the Indian subcontinent started in 1840-now the Sylhet and Chittagong regions in Bangladesh-tea plantation workers were brought from the different provinces of India.To do this, a distinct class of broker, known as Aarkanthi or "free contractors", was employed to procure tea plantation workers.This form of activity opened up opportunities for brokers to make a considerable profit, but it also involved the use of deceptive means or "shrewd mechanisms" (Sengupta 2009;Rozario 2015;Arif 2018;Ibrahim 2016).Brokers targeted poverty-stricken regions in the Indian subcontinent for labourers, who were brought to the tea plantations with promises of a "golden crop" (Rozario 2015;Gain 2016;Sengupta 2009).
Duncan Brothers transported tea plantation workers from different regions of India, including Assam, Nagaland, Orissa, Bihar, and Madras (Interview: Rajon 2018; Interview: Laskar 2018).In order to set up tea gardens, the company targeted poorer communities, especially indigenous and lower-caste communities of India.Primarily, the tea company involved them in cleaning the jungles of hills and valleys of these regions, where tea gardens were then set up.This process turned them into bonded labour, they were tied to the land and employed for tea cultivation (Gain 2016).In turn, the company provided them with meagre daily wages and basic accommodation in the labour line of the tea garden, where plantation workers lived with their families (Arif 2018;Deshwara 2019;Ibrahim 2016).
Now the workforce at Chandpur Tea Estate comprises approximately 2,130 people, who work as tea plantation workers in this garden.These workers consist of 38 small ethno-religious groups (Gain 2016).Of this total workforce, 1,670 Produced and distributed by Pluto Journals www.plutojournals.com/scj/people are employed on a permanent basis, while 460 people were part-time workers.The total population of the garden-including the family members of tea plantation workers-has been estimated at approximately 6,000 (Gain 2016;Rozario 2015).
Before we look at the trigger for this episode of landed contention, which involved the state and resisting plantation workers, it is important to also draw attention to the vested interests implicated in this case.Mega-projects, as has been noted elsewhere in the literature (Lasslett 2018;Noria 2018), are frequently pushed through with questionable public justification, because vested interests stand to profit from their implementation, whether it be financiers, construction firms, or political facilitators looking for kick-backs and party donations.They by nature pit resisting communities against a confluence of powerful interests.
In the tea plantation case it was local political leaders, especially the ruling party leaders who emerged as a vested interest, with a direct financial stake in the government's acquisition of the land.A vast stretch of land-around the acquired land of the tea garden-was owned by the locally elected Bengali political elite.The creation of an economic zone on adjacent land would increase the market value of their property, as the land also will be considered for commercial enterprise (Interview: Tuhin 2018).Reflecting the complex constellations of interests that can emerge during episodes of land contention, Borras andFranco (2013: 1730) note, "in a community it is common to see mobilisations against a land deal parallel to counter-mobilisations in favour of the same deal".
The Bengali political elite could draw on ethnic alliances with the wider Bengali population, who tended to have better academic backgrounds, professional skills, and social networks compared to the tea plantation workers in this locality (Interview: Zunta 2018).According to Shohag from the tea plantation workers' community: The leaders of local political parties-right-wing parties-wanted to set up an SEZ on the land because local Bengali people will get jobs in the industries of the proposed SEZ.They will get tenders to construct buildings for the SEZ.This zone requires highly skilled people who will be employed.On the other hand, tea labourers did not have experience and skills except plucking leaves from the tea plants.The tea labourers can be considered as "day labourers" of the proposed SEZ.(Interview: Shohag 2018) We thus see here the potential for an intersectional alliance which can bring about a pro-economic zone coalition in the Bengali community based on the perceived shared interests of the Bengali bourgeoisie, petit-bourgeoise, and workers.This formed the social basis of a coalition which would form to oppose the resistance movement.

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Attention will now turn to a brief history of the land which formed the focus for the struggle between Chandpur Tea Estate workers and BEZA, before we then turn to the 2015 trigger for contention.

Land tenure and the Chandpur tea estate
Duncan Brothers (Bangladesh) Limited's tenure over the 3,951.14acres of land was acquired from the Land Ministry of Bangladesh.While the lease over this land was initiated during the British colonial period in the 1840s, the latest lease was renewed in 2013 by Duncan Brothers for 40 years.The tea plantation labourers have been entitled to cultivate a total of 512 acres of land within the larger plot, which were unsuitable for tea plantation (Deshwara 2019).They then turned the non-farming or infertile land into agricultural land.These lands were used by tea plantation labourers to grow crops, such as paddy, maize, lentils, flour, and seasonal vegetables, which provides the basis of a subsistence livelihood.
The tea company was happy to allow workers to grow these crops on the unused land of the tea garden, as Duncan Brothers was prioritizing well-drained, undulating terrains and slope lands for their crops.Ancestors of those who initially cleared and cultivated the land look back at the effort with pride: During the British regime, the owner of the company gave the land to our ancestors for cultivation, as the land was not suitable for tea planation.This area was surrounded by numerous valleys and jungles.Our ancestors developed the lands, by clearing jungles and weeds, for cultivating crops during the British regime.They fought with wild animals like tigers and lions to develop the land.(Interview: Zunta 2018) Over time land won from the elements through labour became the essential other of the tea labourers, that is an organic and inorganic resource their social existence had become intrinsically wedded to.As poor rural workers, cultivation of the land is critical to subsistence and wage-earning strategies.Furthermore, because of their marginalized status, land is not fungible, loss of one parcel cannot be replaced by an easily accessible alternative.Loss of land for marginalized rural workers becomes an existential crisis that threatens their social reproduction.This is further reinforced for the tea community by the integration of its spiritual and cultural life with the land.As one respondent observed: Our funeral ceremonies take place on the land.The land does not only provide crops that are required to survive, but it also is used for religious rituals.Therefore, our life cycle depends on the land-from birth to death . . .If the SEZ wants to Produced and distributed by Pluto Journals www.plutojournals.com/scj/grab the land, we will sacrifice our lives: "shoot us and seize the land".(Interview: Fakir 2018) While the tea labourers or tea plantation workers have no legal land deeds or land registry documents to claim the land formally, a local customary land tenure system has emerged that allows community members to claim and manage the land.According to one interviewee, "the community has rights to make claims on the lands because they have been cultivating the land for generations, 150 years.This process created the customary land tenure system used among the members of the community" (Interview: Fakir 2018).Under this customary system, members of the community have the right to inherit property through kinship networks.The land cannot be transferred to non-relatives or to individuals outside of the community.Only family members can have access to the cropland that is inherited from ancestors, who were the original tea labourers.
This is an example of two parallel systems of land tenure emerging, with sympathetic and antagonistic features.On one hand, there is the state-sanctioned grant of land to Duncan Brothers governed by national laws, on the other there is an informal system of tenure that has emerged among tea plantation workers with the acquiescence of the company and state.This acquiescence represents a tactical accommodation, which in this case allowed low-paid workers to generate significant profits for the company, by subsidizing their wage with smallholder agriculture overseen by the family household.However, because this informal tenure was dependent on arbitrary state-corporate acquiescence, it was also vulnerable to removal at any moment, a challenge faced much more widely by poor, marginalized communities living in informal settlements with state-corporate acquiescence.The communities claim to legitimacy lies in personal stories of long connection, their collective cultural heritage, the hard work of successive generations, and the informal understandings reached with the company and state.The state's claim, on the other hand, lies in its authority to reallocate land as a sovereign, the symbolic supremacy of formalized procedure over informal understandings, and its developmental agenda to attract investment through concessional frameworks such as SEZs.

The trigger for contention
The trigger for contention, as noted above, has its origins in the Bangladeshi government's policy to implement a mega-project, setting up 100 SEZs by 2030.As part of the land seizure process in Bangaldesh BEZA sent a proposal to the District Commissioner, who is the chief executive in the district of the proposed SEZ.In order to establish the proposed economic zone, the District Commissioner then State Crime 12.1 2023 instructed local land officials to initiate the land acquisition process which occurred opaquely during 2015.On 21 September 2015, the local land registry office in Chunarughat Sub-District (Sylhet Division) completed the land acquisition process, and subsequently on 21 November 2015, the land was handed over to BEZA for setting up the economic zone (Arif 2018;Ibrahim 2016;Rozario 2015;Interview: Rajon 2018).
In order to execute this "land acquisition" process, the government appears to have deployed a deceptive land categorisation method process that facilitated the cancellation of the lease agreement with the tea company.Land classification refers to the status of the particular piece of land, whether it is "arable land" or "barren land".According to Deshwara (2019): BEZA mentioned that the land was taken under Acquisition and Requisition of Immovable Ordinance 1982 and Non-agriculture Khas Land Management and Settlement Policy 1995 . . .Supreme Court lawyer Hasnat Quaiyum . . .[claims] "the local government office termed it barren land and this is false.This is punishable under articles 167 and 409 of the penal code".
The law, which was clarified in the Agricultural Land Protection Act 2016, states "agricultural land" refers to "arable land" where various crops are cultivated around the year, such as, food grains, tea, animal food processing, biofuel processing, natural forestation, private forestation, fish farming, orcharding, and botanical garden for herbal medicine.Agricultural land is exclusively restricted for agroeconomy practices (Rahman 2017).According to the directive of BEZA's executive director, only barren or uncultivated land should therefore be considered for industrialization via economic zones (BEZA 2015).Indeed, establishing industries on agricultural land is strictly prohibited now according to the Agricultural Land Protection Act 2016.This was an important issue for the community facing displacement: Government officials cancelled the lease agreements, declaring the land as a barren/fallow land or khas [state owned land], but the reality is that tea labourers have been cultivating the land for generations.Local government officials and local government administrative officers, who gave false information to the SEZ authority about the land, categorized the land as barren or fallow land.However, the prime minster asked the SEZ authority to set up SEZ only on the fallow land or uncultivated land.(Interview: Nurul 2018) As noted by the respondent, Bangladesh's Prime Minister had indeed instructed officials of BEZA to conserve agricultural land in a speech on 22 October 2015 (Ibrahim 2016).This set the context for credible claims that authorities had employed fraud to improperly categorize the land as barren, in order to facilitate the acquisition: The government officials, after the liberation of Bangladesh, might not have reviewed the status or condition of the acquired land [the 512 acres].During the British period, this land was categorized as "barren land" because this area was a remote area of Bangladesh, where agricultural might not be a popular profession.Using the documents of the colonial government, the local government officials characterized the land as "barren land".(Interview: Lalu 2018) This colonial process, it is important to note, is not unique to Bangladesh.It was part of a wider colonial trend to treat, often falsely, land as barren or uncultivated, as a prerequisite for acquiring the land, and incorporating it into the market economy, so it could be reconstituted as a site for capital accumulation and taxation (Ferguson 2014).The colonial armoury of political-legal technologies, in turn, is then appropriated by a post-colonial elite to augment their agency powers, put in service of new strategies regarding capital accumulation that can ironically be cloaked in the discourse of national empowerment (Rhoads 2018).This is a reminder of how technologies of colonial power become absorbed into postcolonial states, creating a dispossessive continuum that bridges political transitions (Rhoads 2018).In the current case, it meant the tea labourer community were resisting a categorization made by the colonial authorities, and a technology of colonial power bequeathed to the Bangladeshi elite.They could now use it to launder the land acquisition's illegitimate underpinning, so that it could be cleanly integrated into the SEZ and wider market economy.
Evidently as part of this misleading categorisation process, the concerned official produced a land survey report which classed the garden land as "uncultivated" or "barren land" (Interview: Laskar 2018).According to community members, the authorities eschewed conducting a field study where the voice of the community could be heard: Before implementing a SEZ, the government should undertake a feasibility study.On the other hand, the SEZ authority did not consult with the tea labourers before cancelling the lease process.The tea workers deserved to have a meeting with government officials, as they have been cultivating the land for 150 years.(Interview: Josna 2018) On the basis of this problematic process, authorities transferred the leased land of the tea company to BEZA on 9 September 2015 (Interview: Kindu 2018).

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This is an example of how the licit and illicit become inextricably bound together in complex laundering cases.In this instance through the significant effort of tea plantation labourers, formerly barren land had been converted into arable land.As a result, the land should be excluded from being acquired by BEZA for an economic zone.To circumvent this challenge, a flawed acquisition process was implemented where the land was incorrectly categorized to pass title over to BEZA, drawing on a colonial technology.BEZA could then use the law to "legitimately" evict plantation labourers.This exemplifies how powerful actors can "have their cake and eat it too".On the one hand they abuse legal process to acquire a lawful claim over the land, and then that lawful claim is utilized to evict less powerful communities who are now characterized as the law-breakers.
It is also alleged that during the acquisition process BEZA did not fulfil its tax obligation.In particular, BEZA refrained from paying approximately £100,000 to the local land registry office: The land acquisition process avoided legal procedures . . .For example, when a piece of land is transferred to a new possessor, a fixed amount of money against the land is supposed to be paid as government tax in the local land office.Government officials, who dealt with the issue, did not pay a fixed amount of money, as a government tax, when they transferred the land [512 acres] to the BEZA authority.(Interview: Nasir 2018)

The resistance process
In the case of the Chandpur Tea Estate workers, the trajectories of resistance to land-grabbing included a variety of contentious performances.To protect the cropland of the tea garden, the claimant community-the claim-making groupdeveloped their own "resistance framework", drawing on customary methods, social alliances, and some experimental tactics.This process can be divided into two phases: a "mobilizing phase" and a "repertoire of action" phase.According to Tilly (1978), mobilization constitutes the preparation required to proceed with the claim-making process.Mobilization refers to the process of developing consensus among the members of the claim-maker community, i.e. framing and building a resource base that can sustain action.Repertoire of action constitutes the contentious performances implemented in the resistance process-the ways of raising voices to make claims-once mobilization is completed.

Mobilization
In 2014, the tea plantation labourers became aware their land was the potential target for a land acquisition process after a national newspaper published a report Produced and distributed by Pluto Journals www.plutojournals.com/scj/that: SEZ would be set up on the land of Chandpur Tea Garden.Following the newspaper report, the panchayat committee-a local representative committee of the tea plantation workers of the tea garden-initiated an agenda to consult with the tea plantation labourers, and develop what would be a framework for the resistance process.This preliminary phase can be termed as the mobilizing and framing process of the resistance.
In order to counter the powerful actors buttressing this potential land-grablocal government officials, BEZA, and the law enforcement agency-local leaders from the panchayat committee decided to constitute a separate committee.This committee, launched on 1 December 2015, became known as the Bhumi Rakkha committee (Land Protection Committee of Chandpur Tea Garden) (Sharif 2015).One of the first challenges was framing the struggle in a way that could galvanize the community.
While the tea labourers or tea plantation workers had no legal land deeds or land registry documents to claim the land formally, the customary land tenure system formed one of the bases for framing their legitimate claim.According to one interviewee, "the community has rights to make claims on the lands because they have been cultivating the land for generations, 150 years" (Interview: Josep 2018).According to Perera (2016): This is a conspiracy against the tea workers who have worked on infertile land for more than 150 years and turned it into arable land.Now a group of vested interests wants to take away the workers' only source of livelihood.
In addition to building a frame for the community's demands, the Bhumi Rakkha committee was critical to resourcing the struggle, i.e. mobilizing support to sustain resistance.In particular, the committee began mobilizing resources from the wider tea plantation labourer community, and from the members of the panchayat committees in 23 neighbouring tea gardens (which were owned by different companies).One of its founders recalls: In January 2016, we formed a land protection committee "Bhumi Rakkha committee" which aimed to resist the proposed SEZ on the contested land.Community people are united under the platform of the committee-this committee enables them to raise their voice strongly and spontaneously.The committee members were also selected from neighbouring tea gardensespecially [workers'] leaders of the respective tea gardens, so that they [the committee] could get external supports from neighbouring gardens.Mechanisms like this are required to build consensus and solidarity among the tea labourers in Bangladesh.This process is about harnessing feelings of solidarity.This process As a result of this process of mobilization, not only were the members of the claimant community involved in this resistance struggle, but so were the tea plantation workers of 23 neighbouring tea gardens.This committee drew on these ties to help finance the different resistance activities organized by the claimant group: To organize the resistance movement, we collected money from the tea workers, as we needed to travel to different places for arranging meetings and organizing processions.Sometimes, we organized meetings and seminars in Dhaka, the capital of Bangladesh.Money was required to travel in distant places, including Dhaka.Individual members from the tea garden labourer community contributed voluntarily, depending on their financial conditions.The tea labourers from 23 neighbouring gardens also helped us financially to proceed with the resistance movement.We selected a committee member-a financial manager for this movement-who maintained financial records regarding the travelling, and meeting expenses.(Interview: Mostofa 2018) Obtaining funds and support in kind for the campaign was also critical to sustaining a wide-ranging repertoire of action: During the resistance period, the tea labourers of the adjoining 23 gardens provided meals to the labourers who participated in the strike programme.They even gave money that was used to bear the expenses of the strike and procession.Additionally, they are still willing to pay more money for continuing the resistance movement-if we are required to start the resistance process again for making claims to the land.(Interview: Shakti, 2018) However, not only did the claimant group obtain material support from allied workers, they also rallied symbolical support from them too.On 19 December 2015, for example, the 23 neighbouring tea gardens formally expressed their solidarity with the demands of the tea plantation workers of Chandpur Tea Garden.On this day, workers from the neighbouring gardens attended a mass demonstration led by the victim community.Indeed, the active participation of the members of the neighbouring gardens was visible in the trajectories of contentious performances that will be discussed further below, that is, demonstrations, sit-in programmes, work stoppages, processions, rallies, and cultural events that related to the resistance process.It was emphasized by participants that this was a movement, "without a resistance movement, we would not survive in Bangladesh" (Interview: Parvenn 2018).
By creating a framing for their struggle and engaging in a mobilization process that focused on movement building, the claimant group forged a foundation for then engaging in a repertoire of actions that would enact the claim-making process.Of course, during the resistance processes, mobilization and repertoires of action syncopate in parallel, rather than occurring in a linear manner.Throughout the land struggle, the tea workers would continue to mobilize new arrays of forces.However, it was this initial committee and wider worker movement that formed the initial basis for engaging in contentious politics.

Repertoires of action and demobilization
While challengers perform repertoires of contention and attempt to involve allies in a claim-making process, the powerful actors engage in a demobilization process, which aims to deactivate the resistance.For example, governments can apply coercive mechanisms, deploying law enforcement agencies, including the military, police, the courts, prisons, and the like in order to control contention (Tilly 1978: 100).As Tilly observes, there are "police for crowd control, troops to back them, spies and informers for infiltration, licensing to keep potential actors visible and tame" (Tilly 1978: 101).This section, accordingly, will consider both Chandpur tea plantation workers' contentious performances and the efforts marshalled by the state to demobilize this emerging movement.
As resources were gradually mobilized during 2015, a set of sporadic contentious performances began, including processions and rallies.For example, on 4 August 2015, the claimant group arranged a rally in front of national press club in Dhaka.Then on 29 November 2015, a procession, which is known as Michil, was conducted in the locality of the claimant group.Michil is a local practice in Bangladesh where the claimants march together with claim-making slogans.
In the face of spontaneous resistance on 12 December 2015, the local executive government officer (Upazila Nirbahi Officer) declared that the targeted land-512 acres of farming lands-was to be taken the following day on 13 December 2015.This represented a sharp effort to abort the movement before it gained momentum.However, while resistance was at this stage sporadic and embryonic in nature, it was anchored in deeper social connections and traditions which buttressed its resilience.
In order to demarcate boundaries of the contested land, using fencing and enclosing the land with pillars, the government agencies in fact appeared on the land a month later on 13 January 2016.By this stage the Bhumi Rakkha committee had been established and began constructing a frame for a more organized repertoire of actions.Accordingly, when the government officials arrived at the contested land along with law enforcement agencies and BEZA officials, the claimant community organized a large demonstration that consisted of approximately State Crime 12.1 2023 12,000 tea plantation labourers who marched, with arrows, bows, sticks, and axes, towards the contested land, to drive away the state officials (Interview: Rahman 2018).Although the community was celebrating religious festivals on that day, they were able to initiate a rapid reaction to the enclosure effort.The community in fact employed the "garden alarm", which is used for routine work and emergency purposes, to rally members into a centralized place.
In order to place pressure on the government officials, a sit-in programme was organized on the contested land, which continued for seven days between 14 January 2016 and 20 January 2016.Participants chanted belligerent anti-SEZ slogans: Amar mati, amar ma, keray netay debo na; Amar morbo, kintu BEZA k jomi debo na; Amra rokto debo, kintu jomi debo na (Our land is of our mother that will not be snatched away; We would die rather than surrender the land to BEZA; We will give blood, but not our land).In addition to the slogans, individual members of the victim community wrapped the Bangladeshi national flag around their chest and forehead to connect the resistance process to a wider sense of worker patriotism: Basically, we set up camp on the contested land to coordinate our strike or sit-in programme.We also engaged in other allied activity: arranging processions, giving speeches against SEZ, and chanting slogans against SEZ.Despite the weather being cold, we stayed on the land at night in order to maintain the resistance.During the sit-in programme, nobody worked at the tea garden.Subsequently, we halted the sit-in performance in consultation with our community leaders.(Interview: Kokun 2018) This episode of contentious performance staged at the contested site vividly conveyed a message to the state actors of the community's resolve.This episode also drew the attention of a wider audience, including national media, political parties, and civil society organizations, who became familiar with the land contention through this event.For example, a left-wing political party, Socialist Party of Bangladesh (SPB), expressed solidarity with the demands of the tea community (Interview: Rotin 2018).The mobilization process thus continued in parallel with this repertoire of activity, in effect scaling up, due to the politically vocal way the tea plantations workers' organized their resistance.
After the "sit-in" programme, a "work stoppage" programme was scheduled to further the community's claim for land justice.This repertoire continued for three consecutive months: We organized processions against the proposed SEZ everyday in the morningbetween 8am and 11am.Local weapons, including arrows, bows and sticks, were Produced and distributed by Pluto Journals www.plutojournals.com/scj/used when we started demonstration against the SEZ, and we had a popular slogan-"our land is our mother that will not be snatched away"-while marching around local areas with processions.We organized processions with bows and arrows, so that local political leaders and government officials might begin to fear these actions and decide against establishing the SEZ.All tea labourers attended processions under the slogan, "we are fighting for our next generations".These kinds of processions continued between 2015 and 2018 . . ."If we stand strong, we can establish rights on the land in the future", this slogan motivated us to resist the government authority (Interview: Jonab 2018).
The entrenched nature of their repertoire of action was an integral part of the resistance.For example, every morning from 8:00 am to 10:00 am, the community observed the "work stoppage programme".This work stoppage was accompanied by processions which started from the workstation and ended up at the contested land, where the local leaders of the community made speeches against the aggressive activities of BEZA.However, importantly this repertoire of action took place with the cooperation of the management of the tea company, who rescheduled working hours to facilitate the protest.The victim community had built a coalition with the officials at the tea company in order to proceed with their claim-making process (the company's motivation for this alliance is explored further below).Had the company been hostile to the workers' aim, a whole manner of employer methods could have been used to disrupt the repertoire of action.However, in this instance capital adjusted its metabolic processes to accommodate workers.
While this work stoppage programme evolved as a mechanism of everyday resistance, the claimant group also used a further array of contentious performances.The claimants submitted petitions to the concerned authorities, including the Prime Minister, the Deputy Commissioner, BEZA, the Commerce Ministry, the Land Ministry, and Local Government Offices.For example, on 21 December 2015, the tea plantation labourers submitted a memorandum or petition to the District Commissioner demanding that the land acquisition be cancelled.On 28 December 2015, a petition was submitted to the Prime Minister.On the same day, the tea plantation labourers of Bangladesh-i.e. all tea gardens of Bangladeshsubmitted petitions to local government offices protesting the proposed SEZ on the cropland of the tea garden, and a protest rally on the contested land was also organized on this day.
However, these efforts did not go unchallenged.Shortly after the mass demonstration on 14 January 2016, local political followers of the ruling party mobilized local people, primarily from the Bengali ethnic group, hinting at the intersectional nature of struggle.With the protection of the local law enforcement agency, they occupied the contested land.According to Perera (2016), "the government has mobilized Awami League members in the Habiganj district to intimidate and terrorize workers, while deploying police to suppress protests and strikes".In response, the claimant community rushed to the land with their arms namely arrows, bows, axes, and sticks.Facing superior numbers, the political leaders, local Awami League supporters and police personnel left the land.
To strengthen the resistance process against rival factions, the Youth-Student Forum of the tea garden-run by children of tea plantation labourers-conducted a "protest rally" in front of BEZA on 21 January 2016.The youth rally in front of BEZA headquarters in Dhaka, obtained support from a local group of cultural activists (artists), Sharbopran Sanskritik Sakti, who arrived at the protest to support the claim-making of the tea plantation workers.
To further the resistance, Sharbopran Sanskritik Sakti organized a cultural event which took place in Dhaka on 7 February 2016.The intent of this event was to disseminate information about precarious livelihood and land rights of the tea plantation workers in Bangladesh, drawing on the cultural power of its members.This episode included a variety of performances: folk music, an art exhibition, staging a drama, and poem recitation.Not only did the tea plantation workers perform in the cultural activities, but renowned artists of Bangladesh also participated in cultural performances.The media coverage highlighting the cultural event allowed the claim-making process to be scaled up to a national level in the public discourse.
In addition to soliciting support from Sharbopran Sanskritik Sakti, the youth protest at BEZA headquarters also helped to build alliances with students in other surrounding tea gardens.As a result, on 4 March 2016, the Youth-Student Forum was formed in 23 neighbouring tea gardens.A left-wing political party, the Socialist Party of Bangladesh (SPB), had advised the panchayat committee of the tea gardens to constitute this forum to draw on the energy and education of students.The newly formed youth committee members organized a day-long seminar where academic and intellectuals attended.The seminar denounced the aggressive role of local leaders from the right-wing political parties along with local government officials, who were facilitating the acquisition of the land for BEZA.
Alongside the Youth-Student Forum, the women of the tea garden community made a significant contribution to the resistance process.International Women's Day, held on 8 March 2016, featured a "rally" in support of the tea plantation workers, which was held in front of the administrative headquarters of the subdistrict.The repertoire of action included a set of staged cultural performances demanding land rights, which included composition of the lyrics of songs focusing on the marginalized lifestyle of the tea community: Produced and distributed by Pluto Journals www.plutojournals.com/scj/Women played great roles in resisting the powerful actors because they thought that land was the last resource of their lives.A male can work outside of the garden, but females depend on the cropland . . .Female workers played an important role in mobilizing the resistance movement; they organized yard meetings regularly during the resistance process.Males wanted to negotiate with the ruling party, but the women disagreed with the views of the male workers.In the context of the tea garden, female workers are empowered, and are capable of resisting powerful actors.(Interview: Tojim 2018) The trajectory of resistance revealed how members of the impacted community made a significant contribution in framing the resistance process drawing on intersections of identity.It also demonstrated how subsections within the claimant community were more wedded to radical tactics because of their greater levels of dependence on the contested land.
To commemorate the resistance movement Sharbopran Sanskritik Sakti and the Land Protection Committee of Chandpur Tea Garden organized a programme: "Celebrating one-year anniversary of the successful resistance movement" on 10 March 2017.Together, the claimant and allied actors, including the tea plantation workers of 23 neighbouring tea gardens and Sharbopran Sanskritik Sakti, celebrated the first-year anniversary of successful resistance to the land-grab.This day-long programme featured a variety of cultural performances; folk song, dance, modern music, and drama related to the resistance process.At the end of this event, a procession rally was organized.Approximately 6,000 people participated to mark the ongoing success of the movement.
When understanding the repertoire of actions employed by the claimant group, the role of the tea company should not be overlooked.As the tea plantation workers were the direct beneficiary of the croplands, there was liaising between leaders of the resistance committee and local managers from the tea company.To help the community resist the land acquisition process, the company used contentious performances, including submitting petitions to government officials and lobbying various government ministries.The company also recruited national and international support from diplomats and influential national political leaders, in a bid to overturn the decision of BEZA.Their support for the movement came at a financial loss, approximately USD 100,000 each day when the labourers observed the work stoppage programme in the garden (Rozario 2015).However, building the SEZ adjacent to the tea estate risked destroying the ecological balance of its surrounding areas, which was critical to the plantation's future.Also, the SEZ would be a competitor bidding for the relatively cheap labour power currently working on the plantation.In short, the SEZ threatened to reduce the profitability of the plantation by reducing the productivity tied to the existing ecological balance, and State Crime 12.1 2023 through constricting the supply of labour, forcing up wages.These factors, which will have discernible adverse impacts on the tea estate, were foundations for this particular cross-class alliance.Now we will turn to the role that this and other alliances played in the resistance process.

Alliances and the resistance process
When communities engage in collective performances in order to make claims, one goal is to expand their supporter base in the episode of contention.External support reinforces the claim-making process of the challengers.Challengers can create opportunities in an episode of contention using appropriate allies, forging new collective identities, organizations, and social networks, and innovating on the inherited local repertoires.Tilly (1978: 176) claims that "when collective action does develop, it is around the corporate bodies and voluntary associations whose established positions and real power enables them to gain advantages within the institutional framework of the state".To resist the powerful state actors, the tea plantation workers forged critical alliances with civil society organizations (CSOs) and political parties.The following discussion surveys this side of the resistance process.
At the beginning of contentious episodes, for example, when a "sit-in" programme was performed from 14 January 2016 to 20 January 2016, human rights organizations and cultural activists appeared on the contested land where the community organized their "sit-in" programme.Also, on 19 January 2016, several CSOs, namely the Research and Development Collective (RDC) and Bangladesh Indigenous People Forum (BIPF), attended the resistance performance, which was organized by the claimant community.These CSOs submitted a memorandum to the District Commissioner, highlighting concerns over the opaque land acquisition process.
In addition to this role, demonstrations and conferences led by these stakeholders created new platforms for the claim-making process at a national scale.The claimant community attended the conference, symposium, and cultural programmes, including an art exhibition held at Dhaka relating to the land contention.These events taught the community to raise their voices in wider public forums using arts to connect with people from different backgrounds in Dhaka, who were unaware of the difficult conditions faced by the community.
Progressive political parties were another important ally of the resistance movement.The left-wing political parties-Socialist Party of Bangladesh (SPB), Communist Party of Bangladesh (CPB) and Workers Party of Bangladesh (WPB)-formally endorsed the demands of the tea plantation labourers.The SPB, known as Jatiya Samajtantrik Dal, played a specifically active role in the claimmaking process, by helping the community with framing and mobilization: Produced and distributed by Pluto Journals www.plutojournals.com/scj/This party taught the tea labourers how to chant slogans against the BEZA and helped them to form a committee for claiming the land namely "Land Protection Committee".Moreover, they trained the tea labourers how to write memorandums and press releases, and how to submit these papers to different stakeholders.(Interview: Fakir, 2018) This points to the way in which allies can transmit different forms of capital, in the sense of Bourdieu, such as cultural and technical capital, to the claimants in ways that enhance their agency.
Additionally, when the land contention began in 2015, SPB organized a conference in Dhaka on 28 November 2015 to address the land rights of the tea plantation labourers.On 29 November 2016, SPB and the Land Protection Committee jointly organized a rally that was held on the contested land.Furthermore, a sit-in programme was co-designed, held between 14 December 2016 and 20 December 2016.One SPB activist remarks: The Socialist Party of Bangladesh conceives that the SEZ cannot bring positive change to society, it will not bring economic development to society.The SEZ will only evict marginalised people in the "name" of development.I could give some examples from a neighbouring country, namely India where SEZs have not brought about the positive change to society promised.We are supporting effective development of this country, but this party will not tolerate imperialist aggression in the name of development.This political party is supporting the victim community as part of a social responsibility manifest in the political agenda of this party.(Interview: Nantu 2018) Active assistance was also given by the CPB.To raise the voice of the community, like SPB, the CPB advised them to form different committees: Land Protection Committee, Youth-Student Forum and a Theatre Group.In addition to helping the community develop a diversified campaign, the CPB also provided some finances to the resistance in order to mobilize for different events.
Collectively at the time the fieldwork period ended, this movement had sustained a successful resistance to the acquisition of the land by BEZA.After the fieldwork ended, the tea workers continue to network with political actors and civil society organizations in order to sustain the claim-making process.Not only are they networking with influential actors, but also organizing intermittently different repertoires of actions, including community-level meetings.This mechanism works as a resistance watchdog of sorts, where any further planning related to the BEZA is kept under close-scrutiny, with a preparedness to reanimate the movement if required.

Discussion
When powerful coalitions of actors intend to grab land by means of force, fraud, and state violence, less powerful actors must deploy an inventive array of repertoires appropriate to their situation and resources.This can include more covert and spontaneous strategies, such as shouting, scolding, anonymous acts of sabotage, foot-dragging, and refusal to work (Borras and Franco 2013;Greco 2016;McAllister 2015).But as McAllister (2015) observes it can be organized and strategic.
It can involve organized violence, for example attacking law enforcement agencies, burning and smashing property, and taking possession of the landed property they have been claiming over the years (Greco 2016;Kerkvliet 2009;Rocheleau 2015;Sampat 2015).It can also involve non-violent resistance, including sit-ins, street protests, and press conferences.When these types of repertoires of actions are unable to create opportunities in the claim-making process, resistance efforts can also go down a legal route (Borras and Franco 2013;Bedi 2015;Sampat 2015).Bedi (2015: 597) observes of resistance in India, for example: To diversify their resistance and potentially force accountability, the SEZ opposition turned to the judicial system.In 2007 and 2008 SEZ-affected communities in Goa filed three separate but related public interest legislation (PIL) court cases, based on information acquired from RTI applications.The petitions highlighted the economic and legal inconsistencies associated with the SEZ land transfers and approval processes.
Networking with media, national and global civil society organizations can allow contenders to scale up the resistance process.By using an array of repertoires of actions drawing on these networks, the claimant groups can draw attention from wider audiences, including state actors, civil society organizations, media, and global humanitarian organizations, who can potentially act as "allied actors" in an episode of contention.These organizations can also transmit back to the claimants different forms of social capital, in ways that enhance the agency power of resisting communities.
There are a number of core determinants in this case study that the empirical data suggest were critical to this successful episode in claim-making and resistance (successful in the sense that it secured the community's ongoing possession of the land, from a state organized confiscation effort).First was the local community's sense of cultural legitimacy for laying claim to the land rooted in their shared history, in addition to their dependence on this land for their material subsistence.This weave of culture, history, and livelihood created a powerful Produced and distributed by Pluto Journals www.plutojournals.com/scj/motive force for resistance.Second was the history of solidarity within the tea plantation community, which created a common political language that allowed the affected community to call upon their fellow workers to join rallies, sit-ins, and other events.Critical here was the volume of numbers that could mass at rallies, which gave the community's demands greater political weight.Third, early alliances built with progressive political parties enabled the community to build organizational mechanisms for prosecuting their activity, and for tying their framing process into progressive nationalist narratives.Fourth was the community's ability to build a financial reservoir which could sustain long-term action.Then fifth was the involvement of NGOs, intellectuals, and artists, who supported the community to scale up their claim making using culture and art to reach new audiences and to make new alliances.Sixth was their ability to obtain accommodations from Duncan Brothers, which facilitated an inter-class alliance.
This in its totality created an opportunity structure at a local and national level for sustained and effective activity.From here we can see how the community was able to blend economic, political, and cultural methods to advance their claims.Work stoppages, sit-ins, mass rallies were all used, as were demonstrations with force and numbers.Combined with direct action were political rallies and petitions.The community's claims were given wider credence by their ability to attract popular interests through the arts and supporters with cultural power.Not to be overlooked is armed force.The local community demonstrated it was willing to fight and die in large numbers for their land, which significantly increased the potential loss the state would incur for following through on the BEZA acquisition.
What this demonstrates is that even marginalized communities, only enjoying weak forms of formal tenure, are able in the Bangladeshi context to successfully resist major capitalist initiatives organized by the state via dubious land transactions and force.However, in order to succeed the resisting community needs resources to sustain action over long durations.There must be high levels of motivation among participants, which is essential for taking political risks and providing labour to a movement over a long term.There also need to be multiple scales of networking, drawing on local, regional, and national scales to advance claims.Critically, diversified repertoires are needed that draw off culturally relevant methods appropriate to the scale and audience.
This created a critical mass of sustained force, that disrupted the land-laundering process.BEZA attempted to use the legal and coercive capacities of the state to extract the land under a "legitimate" garb, so it could be effectively integrated into the market economy through the SEZ.This had a symbolic and a material element.The land needed to be "cleaned" of occupants materially, and it needed to be "cleaned" of any stigma that might infect the perceived legitimacy of the tenure being issued by BEZA to investors.The community's resistance disrupted the State Crime 12.1 2023 cleaning process, using their resilience and movement to keep the land expropriation explicitly dirty, in effect thwarting any effort to reintegrate the impacted land into the market economy.Their ongoing vigilance signals a realization that keeping any future attempt to extract the land visibly "dirty" will be essential to frustrating the grab.By retaining this capacity, the community can continue to enjoy the material and spiritual benefits of the land which is now an essential component in intergenerational sustainability strategies, for a community that has been marginalized by the intersectional articulation of capitalist development in Bangladesh.

Conclusion
The emerging literature on state crime more broadly, recognizes justice can be achieved from below (Bryar and Lasslett 2021;Colvin 2018;Green and Ward 2019;Stanley and McCulloch 2013).This study, however, indicates this ability to achieve justice from below depends on volume of numbers, levels of determination mediated by accumulation of political confidence and material dependence, diversity of networks and open social economies that circulate diverse capitals, scales of activity, and a mix of tactics, all of which are relative to the organization, determination, institutional capacity, and the structured impunity of the state and its corporate allies.For example, in the Palestinian case documented by Green and Smith (2016), there are analogous forms of resistance to the Bangladeshi example, except they are matched by a state with high levels of resolve, resourcing, and an ability to organize on multiple scales, through sophisticated military, political, and legal machinery.These same levels of state organization are not apparent in the Bangladesh case, which meant the impacts of community organizing were not neutralized by counter-tactics of the state.In scenarios where there is not sheer asymmetry of forces, the Bangladeshi case suggests modest levels of political force, scales of numbers, and direct political action can target land which is the subject of a laundering process to the point where the state will pause or alter its demands.