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To alleviate discriminatory practices against certain historically oppressed groups, a small number of countries have adopted affirmative action. In the United States, affirmative action is defined as a system of preferential treatment for minorities and women which attempts to compensate them for being denied opportunities of advancement due to past and present discrimination.' Other countries, like India, have adopted affirmative action to deal with the disadvantaged segments of their populations. 2 While it may surprise some scholars that countries other than the United States employ affirmative action, India utilized such preferential treatment well before the United States'. The United States developed affirmative action to fight discrimination against minority groups and women, while India created affirmative action to remedy its history of discrimination against groups, such as the "untouchables," who occupy the lowest rung in the Hindu caste system. Various names have been attributed to Indian affirmative action. For the purposes of this note, the term "compensatory discrimination," as used by such legal scholars as Parmanand Singh and Marc Galanter, will refer to India's affirmative action programs.4 The comparison between the United States and Indian affirmative action systems becomes even more interesting upon observing that blacks

Affirmative Action in India and the United States: the Untouchable and Black Experience