Mostly, as popular perceptions go, the aam aadmi in India thinks that democracies such as ours are intrinsically different from totalitarian regimes, such as communist China. Yes, there is no doubt over that intrinsic systemic difference. But surprisingly, if you skim China?s surface, a lot of the issues that the aam aadmi in India struggles with or is at least conversant with, are fairly similar to those which rankle China?s lao baixing. Today, land-related issues in both countries have emerged as a hotbed of contention. No surprises, if we in India hear of rampant corruption, the emergence of a class of diwang (kingly land acquirers), land acquisition by the party-state, forcible eviction and peasant relocation are heard of in China?ringing a familiar bell.

The issue is becoming increasingly coloured with blood and gore. In China, the recent public furore over the ?accidental? death of 53-year-old peasant-protester Qian Yunhui (hit by a truck) of Yueqing, Wenzhou City, Zhejiang province, on Christmas day (2010) is a case in point. Zhejiang is a fast-growing eastern coastal province, which stands in close proximity to Shanghai (municipality). The bone of contention here was land acquisition?Qian?s village, Zhai Qiao, had been identified as the site of a power plant, necessitating the eviction of an estimated 3,700 people from an estimated 14,600 acres. The related issue, naturally, was compensation, which was falling short of collective demands. The picture of Qian?s severed head posted online within hours of the accident is a tragic reminder that if anything, in both China and India, if one were to be brutally honest, human lives come cheap. We, in India, are not new to controversy or such human tragedies.

Speaking of India, the abandoned Tata project and its well-publicised exit from West Bengal, as well as controversies over other large projects in other states in India, have brought into sharp focus the increasingly contentious issue of land. The spate of violence in Orissa [Kalinganagar (Tata Steel); Puri (Vedanta)], Jharkhand and Chhattisgarh (Arcelor Mittal Steel)] show that issues of land acquisition and compensation are not isolated incidents. Now that Korean conglomerate Posco?s project?India?s single largest FDI of $12 billion?has been cleared, it is public knowledge that Posco produced little else but controversy since it signed the MoU with the Orissa government in 2005, partly because of Posco?s appetite for land?a whopping 6,000 acres, or 60 times the size of Tiananmen Square or less than half the size of Qian?s village.

Land disputes have emerged as China?s most volatile social problem. According to the Chinese Academy of Social Sciences (CASS) Blue Book 2011, 73% of petitions and complaints filed by farmers, and an estimated 65% of rural conflicts are related to land?acquisition, eviction, meagre compensation and resettlement. CASS researcher Yu Jianrong mentions that 6.67 million hectares of land have been seized in the past two decades, and the discrepancy between compensation and market price is an estimated 2 trillion yuan ($294 billion). Independent studies say that up to 3 million farmers in China relocate each year and the number of farmers who have lost their land in the last decade is between 40 and 50 million. However, this does not indicate how many have been suitably compensated and how many have been left in the lurch.

The 2007 law in China recognises the right to private property, but as a right bestowed by the state, and not as a natural right. Given that China is socialist in theory, land in China is publicly owned. In urban areas, the land is owned by the state; in rural areas, it is owned by rural collectives, which can requisition the land for public projects. The basis of sub-contracting land was legally permitted in 2008. As economist Robert Ash points out?farmers were allowed to ?transfer the right to operate on contracted land in the form of sub-contracting, leasing out, swap, transfer, share-holder corporation, etc?. This codified an open secret of the decade. User land rights vary, for residential purpose these are usually deemed at 70 years, and for commercial and industrial use, between 40 and 50 years.

Why has land become much sought after by the local government? Land-sourced fiscal revenue (tudi caizheng) is what local governments are after. Profit lies in the difference between the cost of land acquisition and land leasing?and thus for cash-strapped local governments, a viable and easy revenue generating proposition. The mechanisms for leasing out land are tenders and public auctions. And as in India, there are ways and means to get around them.

According to a scholar, Su Fubing (2010), land-related revenues could possibly account for up to 60% of local government income, between 30% and 50% for all sub-provincial governments and around 50-60% for city level local governments. The income from land sales was 2.7 trillion yuan ($400 billion), an increase of 70% year-on-year, with an estimated 53,000 cases of offence against laws on the use of land.

Thus, while local governments are flush with cash, typically, farmers receive a token amount. The amount is woefully inadequate because besides loss of livelihood, with pay-as-you-go in place, farmers have to pay a hefty sum for social security and save for future medical care.

The central government diktat of limiting land for commercial use has been bent by cross-region purchase of land, which means geographically contiguous cities buy land from neighbouring regions for commercial purposes.

According to the revised Land Administration Law (1998), local governments can acquire land from rural collectives on the basis of ?public interest?. As is the case in India, what constitutes ?public interest? is enmeshed in controversy. In 2009, in an infamous slip of tongue on national TV, Lu Jun, the chief of the planning bureau of Zhengzhou, when answering the question as to why land that had been acquired for public housing was instead used to build expensive private villas, answered: ?Are you speaking for the Party, or are you speaking for the masses??

Under India?s 1894 Land Acquisition Act, the government can declare certain pockets of land as targets for compulsory land acquisition. This was originally intended for projects of ?public interest? (highways, rail lines) for the masses, but in the recent decades has been misused by the classes. Landowners have to sell at the average price fixed at the time of notification. Land prices go up once there is corporate interest and thus landowners protest against both acquisition and low prices.

In China, the party-state is taking measured steps towards transparency?from establishing a National Land Supervision System in 2006 to setting up a ?red? line in 2007, to reserve 120 million hectares of arable land deemed necessary to guarantee grain safety. Tax reforms to ease local government coffers are on the cards.

Informally speaking, a few fortunate victims of land seizures (because of Internet activism and media interest) are now being treated to, besides the proverbial goody bag, a free trip overseas.

The author is a Singapore-based sinologist and is currently visiting fellow, Institute of Chinese Studies, Delhi. These are her personal views