in the Mendhar valley. C. Christine Fair notes that this was the beginning of Pakistan using irregular forces and "asymmetric warfare" to ensure plausible deniability, which has continued ever since. On 1 November 1947, Mountbatten flew to Lahore for a conference with Jinnah, proposing that, in all the princely States where the ruler did not accede to a Dominion corresponding to the majority population (which would have included Junagadh, Hyderabad as well as Kashmir), the accession should be decided by an "impartial reference to the will of the people". Jinnah rejected the offer. According to Indian scholar A. G. Noorani, Jinnah ended up squandering his leverage. Pakistani soldiers and tribesman captured Rajouri on 7 November 1947, which began the Rajouri Massacres of 30,000+ Hindus and Sikhs, locals and refugees from Partition. The massacres would only end with the Indian Army recapturing Rajouri in April 1948. On 25 November, the Pakistani tribesmen and soldiers attacked and took over Mirpur, and began the Mirpur Massacre of Hindus and Sikhs in the area. An estimated 20,000+ Hindus and Sikhs were killed overall. Rapes and other crimes were also committed during the aftermath. According to Jinnah, India acquired the accession through "fraud and violence". A plebiscite was unnecessary and states should accede according to their majority population. He was willing to urge Junagadh to accede to India in return for Kashmir. For a plebiscite, Jinnah demanded simultaneous troop withdrawal for he felt that 'the average Muslim would never have the courage to vote for Pakistan' in the presence of Indian troops and with Sheikh Abdullah in power. When Mountbatten countered that the plebiscite could be conducted by the United Nations, Jinnah, hoping that the invasion would succeed and Pakistan might lose a plebiscite, again rejected the proposal, stating that the Governors Generals should conduct it instead. Mountbatten noted that it was untenable given his constitutional position and India did not accept Jinnah's demand of removing Sheikh Abdullah. Prime Ministers Nehru and Liaquat Ali Khan met again in December, when Nehru informed Khan of India's intention to refer the dispute to the United Nations under article 35 of the UN Charter, which allows the member states to bring to the Security Council attention situations 'likely to endanger the maintenance of international peace'. Nehru and other Indian leaders were afraid since 1947 that the "temporary" accession to India might act as an irritant to the bulk