Mining the Rat Hole – The Quest for Black Gold – An Analysis from the International Law and Human Rights Perspective

Image Courtesy – Adrian Kendall

Coal, also known as Black Gold is a very valuable commodity in everyday use. It is the most used fuel in Thermal Power generation and has a variety of uses in scenarios where electronics or other canned sources of power or fuel cannot be used. Its cheap cost, as well as its easy availability, have made it ubiquitous with fuel. Thermal power and other combustion-based practices such as Steel manufacture rely on the properties of coal and coal as raw materials in the manufacturing process. India has rich coal deposits in the North-Eastern regions of the country and they mine, transport, and produce nearly all the coal in India. There are various techniques and methods that can be used to mining coal, the most dangerous of which is the Rat Hole method.

In this method, tunnels are dug which are only 3-4 feet in diameter (hence the name, rat hole) and miners are sent into those tunnels with little to no safety equipment to mine coal. The coal is then loaded onto buckets or wheelbarrows and transported to the nearest unmined area for storage and further transport.

History of Rat Hole Mining

Rat Hole mining was and remains one of the most popular methods of mining Coal in the North-Eastern state of Meghalaya. It has been practiced in the region since as early as the 1980s. It involves the digging of holes 100-150 meters deep which are only 3-4 feet in diameter. The miners are sent into these holes and are required to mine, load and bring the mined coal to the surface. They are offered little to no safety equipment and are not monitored or governed by any State authorities at all.

The practice of Rat Hole mining offers the miners a paltry sum of around Rs. 700 per day. It has also been found that the practice of Rat Hole mining encourages child labor and related practices due to their smaller frames. Since they are smaller than most men, they can easily navigate the mine and have a little issue fitting in the narrow tunnels. This practice has been banned in the region of Meghalaya since a 2014 National Green Tribunal (NGT) decision but continues unchecked in Meghalaya and neighbouring regions.

Consequences of Rat Hole Mining


Rat Hole mining is an unscientific method of mining. It has led to various disasters due to the poor quality of tunnels, the general lack of regulation, and the inability of the miners to exit the mine in haste if there is an emergency. Injuries and deaths from Rat Hole mining are common with the Meghalaya government reporting 250+ cases in 2019-2020 alone. Apart from the human cost associated with this type of mining, there are environmental costs as well. The use of unscientific techniques such as Rat Hole mining cause deforestation, and increased pollution of land and other resources and water bodies. Water bodies that are exposed to are in close proximity to such concentrations of coal become acidic and cannot be used for domestic or industrial purposes.

They are also a significant flood risk to the miners when they are in the mine. In addition to water bodies, there is also soil and land pollution caused due to the storage of large volumes of coal on the land. There have been studies that highlight exactly how polluted the water gets through techniques such as Rat Hole mining. “A study by the North-Eastern Hill University, Shillong, says the Kopili river has turned acidic due to the discharge of acidic water from mines and the leaching of heavy metals. Layers of rock above the coal removed during mining contain traces of iron, manganese, and aluminum that get dissolved from mining sites through the acid run-off or are washed into streams as sediment.

Legal Position of Rat Hole Mining

In a 2014 judgment, the NGT declared the practice of Rat Hole mining illegal in Meghalaya and slapped a Rs 100 crore fine on the state government for being ineffective in stopping Rat Hole mining in the state. After a tragic incident in 2019, the state government approached the Supreme Court seeking a revision of the 2014 NGT judgment where the Supreme Court made it legal to mine with a valid license. This however was once again ineffective as the Mining laws of Meghalaya allow mining only on landholding 100 hectares or more but coal deposits are found scattered around hills and in foothills.

This makes it impossible for Rat Hole or any small-scale mining operation to ever take off as the government will not accord licenses for land holdings that do not meet the minimum requirement. Further, miners have to follow a set of requirements to be recognized as licensed miners and work in licensed mines. Most of the miners that work in such small-scale operations are barely literate and usually do not meet the requirements of the Mines and Minerals (Development and Regulation) Act of 1957.

Human Rights?

Miners that work in these mines are rarely given any safety equipment when they are sent down the shafts to work. They are not given fair compensation for their labor. They are not paid damages by the mine owner in case of injury nor are there any benefits of being associated with the mine. The only wage the miners get is the daily wage they earn from entering the mine, picking out the coal, and bringing it back out. There has been a marked 40% drop in the schools of the regions surrounding popular Rat Hole locations. This is indicating that children are also seeing mining as a lucrative option and are dropping out of school to pursue it or are being forced by their parents to attend and help them at the mines.

The local mining sector sustains a significant chunk of Meghalaya’s population and the locals are content with the wages they receive from the mining. A case can be made to legalize the practice of mining and allow the miners to acquire licenses easily provided the mines themselves are regulated and under the control of an accountable authority. The repeal of these mines would be inequitable to the various people working here whose entire livelihood depends on the mines. It would therefore be ideal for mine owners to recognize the need for safety equipment and safe labor practices while the government recognizes these smaller mines and allows them to come under some form of organized labor.

Tragedies in Rat Hole Mines

There have been multiple instances of death in Rat Hole mines that have arisen due to the negligence of the mine owner, the poor working conditions in the mine itself, or other environmental factors. 

  • On 13 December 2018, Meghalaya recorded one of the biggest coal mine tragedies when at least 17 miners died in an illegal coal mine due to flooding from a nearby river in East Jaintia Hill
  • On 31 May, five miners reportedly from Assam and Tripura trapped in a coal mine in East Jaintia Hills District after a dynamite blast led to flooding of water from a nearby water source

These incidents were made available only because they were large incidents and could not be hidden. There are thousands who lose their lives to these Rat Hole mines on a yearly basis but these are not reported due to a lack of public interest, fear of mine owners, or other social constraints. There has been a continuous effort to legalize mining for coal in the North-Eastern region and there have been considerable efforts made to reduce the instances of Rat Hole mining but unless there is active government intervention, it seems unlikely that there will be any change.


There is little to no safety in working in a Rat Hole mine, yet it is considered by many to be a lucrative employment opportunity in the North-Eastern regions of India. Miners have to work in such small mine shafts and place their lives in precarious danger to extract coal out of the many shafts that have been poorly dug into the ground. There are no associated benefits and the wages are very poor but it is a source of livelihood for hundreds of people in regions where this mining practice is followed. While it is inhumane to let them work in such conditions, the solution to the problem of Rat Hole mining is not banning them or having regulations that require difficulty to acquire licenses but liberal regulations that enable them to acquire licenses and have them come under the authority of the State.

This way, there can be some real change to the lives of all those mining in these mines. The mines can be rebuilt to be better and more secure, and facilities can be made available in case of emergencies or other issues that may arise in the mine. These are all issues that can be and should be accounted for. It is only through legislation and legalization that there can be regulation and development and making sure that miners have access to basic rights such as safety equipment and emergency facilities is only possible through firm and equitable regulation.

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