a label to be "unconstitutional" because modern legislation prefers Scheduled Castes; however, some sources say that Dalit has encompassed more communities than the official term of Scheduled Castes and is sometimes used to refer to all of India's oppressed peoples. A similar all-encompassing situation prevails in Nepal. In 1932, the British Raj recommended separate electorates to select leaders for Dalits in the Communal Award. This was favoured by Ambedkar but when Mahatma Gandhi opposed the proposal it resulted in the Poona Pact. That in turn influenced the Government of India Act, 1935, which introduced the reservation of seats for the Depressed Classes, now renamed as Scheduled Castes. From soon after its independence in 1947, India introduced a reservation system to enhance the ability of Dalits to have political representation and to obtain government jobs and education. In 1997, India elected its first Dalit President, K. R. Narayanan. Many social organisations have promoted better conditions for Dalits through education, healthcare and employment. Nonetheless, while caste-based discrimination was prohibited and untouchability abolished by the Constitution of India, such practices are still widespread. To prevent harassment, assault, discrimination and similar acts against these groups, the Government of India enacted the Prevention of Atrocities Act, also called the SC/ST Act, on 31 March 1995. In accordance with the order of the Bombay High Court, the Information and Broadcasting Ministry (I&B Ministry) of the Government of India issued an advisory to all media channels in September 2018, asking them to use "Scheduled Castes" instead of the word "Dalit". George Kunnath claims that there "is and has been an internal hierarchy between the various Dalit castes". According to Kunnath, the Dusadhs are considered the highest while the Musahars are considered the lowest within the Dalit groups. Occupations In the past, they were believed to be so impure that upper caste Hindus considered their presence to be polluting. The "impure status" was related to their historic hereditary occupations that caste Hindus considered to be "polluting" or debased, such as working with leather, disposing of dead animals, manual scavenging, or sanitation work. Forced by the circumstance of their birth and poverty, Dalits in India continue to work as sanitation workers: manual scavengers, cleaners of drains, garbage collectors, and sweepers of roads. As of 2019, an estimated 40 to 60 per cent of the 6 million Dalit households are engaged in sanitation work. The most common Dalit caste performing