32 excessively small plots of land by smallholders.96 The States should monitor existing inequalities in terms of access to land and, and implement the programs on redistribution of land. In Bangladesh, agrarian reform initiatives have not produced much result as expected as landlessness is increasing. Government should ensure security of tenure and take measures to confer legal security of tenure upon those persons, households and communities currently lacking such protection.97 Government should also respect the needs of special groups. Government should implement the specific rights of indigenous peoples by demarcating their lands and by providing them with specific protection. Government should also avoid development models that lead to evictions, disruptive shifts in land rights and increased land concentration.98 19. Public Interest Litigations (PIL) on the Right to Food PIL cases can play an important role in establishing the right to food for poor and marginalized communities. Many PIL cases have been filed in different countries to establish right to food as enforceable right. In 2001, the Supreme Court of India recognized the right to food in the People’s Union for Civil Liberties (PUCL) case, transforming policy choices into enforceable rights. In this case, one NGO- People’s Union for Civil Liberties filed a case before the Supreme Court claiming that starvation deaths had occurred in drought-affected rural areas while public granaries were overflowing. The Court acknowledged that preventing hunger and starvation was one of the Government’s prime responsibilities and failure to do so would constitute a violation of the right to live with human dignity as well as the State’s duty to raise the level of nutrition and the standard of living of its people under the Constitution. It directed the central and State Governments to implement several existing schemes on food safety to improve the situation. In Nepal, in response to public interest litigation, the Supreme Court issued an interim order in 2008 directing the Government to supply food immediately to 32 districts which were seriously affected by food shortages. The Court observed that the Constitution guaranteed the right to food as a fundamental right and the Government should ensure adequate food supplies for all. In 96 Ibid, para 37. Ibid, para 40 98 Ibid. 97