In mineral-rich states like Chhattisgarh, companies and governments say they want to develop untapped resources. The Constitution does not allow non-tribal people to directly acquire land in certain parts of the country, so the government must obtain it and sell it to companies. A 35-page working paper on “Land Acquisition And Transfers For Private Industry" in Raigarh, prepared by the Delhi-based Centre for Equity Studies and Jan Chetna, a non-profit working for the rights of the disadvantaged, in December 2013, states: “A fairly common practice revealed during surveys involved selling land to tribal employees of a company or a tribal broker, thus making the actual sale legal. The use of this land by the company, nonetheless, remains illegal and obtaining this land via its employees is a clear violation of these rules. There generally exists a significant asymmetry of power between land losers and companies, resulting in deals being concluded on terms that are unfavourable or unjust to land losers."