A/HRC/10/8/Add.3 page 12 para. 179). In 2008, an independent research study commissioned by the National Commission for Minorities found that there is a strong case for offering Muslims and Christians of Dalit origin the same constitutional safeguards already available to Hindu, Sikh and Buddhist Dalits. The report by the National Commission for Religious and Linguistic Minorities, headed by Justice Renganath Misra, recommended to delete paragraph 3 of the Constitution (Scheduled Castes) Order 1950 - which originally restricted the Scheduled Caste net to the Hindus and later opened it to Sikhs and Buddhists - and to make the Scheduled Castes net fully religion-neutral like that of the Scheduled Tribes. (d) Atheistic and non-theistic believers 29. Humanists, rationalists and other atheistic or non-theistic believers voiced their concerns about the stifling effect of criminal provisions on offences related to religion. Especially the provision against deliberate and malicious acts intended to outrage religious feelings of any class by insulting its religion or religious belief (section 295A of the Indian Penal Code) had allegedly been invoked by the administration to harass writers and activists who were criticizing religious bigotry and superstition or who were trying to expose cheating of the gullible. In this regard, the Special Rapporteur would like to refer to her report to the 62nd session of the General Assembly, where she discussed the situation of persons with atheistic or non-theistic beliefs in greater detail (A/62/280, paras. 64-79). 2. Justice for victims and survivors of communal violence 30. The Special Rapporteur is seriously concerned at the extended timeframe of investigations in cases involving communal riots, violence and massacres such as those which occurred after “Operation Blue Star” in 1984, after the destruction of Babri Masjid in 1992 and after the Godhra train burning incident in 2002. All of these incidents continue to haunt the people affected by them and the system of impunity emboldens forces of intolerance. It is important to draw appropriate lessons from these events in order to prevent the recurrence communal violence. 31. The Special Rapporteur fully agrees with the analysis by the National Commission for Minorities that communal violence is not merely a “law and order” problem but has a serious socio-economic basis and ramifications. Sectarian riots are most likely to occur when the following elements are present: (i) severe long-standing antagonism on religious lines in particular villages and urban localities; (ii) an emotional response of members of religious communities to a precipitating event; (iii) a feeling in the minds of rioters and the larger religious group to which they belong that sectarian violence is justifiable; and (iv) the assessment by the rioters that the reaction from the police to sectarian violence will be either absent or partisan or ineffective. (a) Communal violence after “Operation Blue Star” (1984) 32. Many of the Special Rapporteur’s interlocutors referred to the anti-Sikh riots after the attack by the Indian army on the Golden Temple in Amritsar (“Operation Blue Star”) in June 1984 and subsequent to the tragic assassination of Ms. Indira Gandhi on 31 October 1984. During the following four days, nearly 3,000 Sikhs were reported to have been killed. Two commissions and eight committees were set up from 1984 to 2005 in order to identify those