President’s Rule Alone Can’t Resolve Crisis in Manipur

Restoration of Constitutional Order Requires More Than Just an Election

Commentary, By Vishal Arora
February 14, 2025

A street in Manipur’s Churachandpur district. Photo by Vishal Arora

Manipur’s Governor has imposed President’s Rule days after N. Biren Singh resigned as the Chief Minister – a belated official acknowledgment that the state government could not function according to constitutional provisions. The critical issue now is whether President’s Rule can ensure that Manipur will be able to operate within the constitutional framework within its maximum allowable period of three years.

Before dwelling on the prospects of President’s Rule in Manipur, let’s first briefly explore what it entails, along with its provisions.

Article 356

When President’s Rule is imposed under Article 356 of the Constitution, the state’s governance is taken over by the central government. The legislative assembly is either dissolved or suspended, while the Governor assumes executive powers on behalf of the President. The state’s administration is carried out by the Governor with the help of advisors, often retired bureaucrats and the Parliament takes over the legislative functions of the state.

The President can issue ordinances on state matters, subject to parliamentary approval. There is no elected government during this period, meaning the Chief Minister and Council of Ministers lose their authority.

Initially, President’s Rule lasts for six months but three years is the maximum duration for which it can be extended with approvals every six months from both houses of Parliament. After the first year, the extension requires not just parliamentary approval but also either that a national emergency is in effect under Article 352 of the Constitution, or that the Election Commission must certify that the conduct of elections is not feasible in the state.

The three-year limit on President’s Rule is primarily based on the guidelines set by the 44th Amendment of the Constitution and further reinforced by case law, particularly the Supreme Court’s judgment in the S.R. Bommai vs Union of India case (1994).

President’s Rule is imposed to restore constitutional governance in a state by ensuring law and order and administrative continuity. It can be invoked under several circumstances apart from a political vacuum, such as when there is a severe breakdown of law and order that the state government cannot manage, when governance cannot be carried on in accordance with the provisions of the Constitution, or when internal subversion, rebellion or insurgency threatens the state’s stability.

Legislators

While President’s Rule has been imposed in Manipur due to the state government’s inability to prove a majority in the legislature, lifting it will not only require an election but also the new government's capability to carry out constitutional governance, which fundamentally includes the functioning of the legislature. The legislature can only be said to be functioning effectively when all lawmakers are able to attend assembly sessions without fearing for their lives. This indicates that the essence of President’s Rule was overlooked for nearly two years.

Since May 3, 2023, when ethnic violence broke out with the then state government allegedly supporting one party—the majority Meiteis—in the conflict, none of the 10 legislators from the minority Kuki-Zo tribal community have been able to attend the assembly sessions held subsequently.

Buffer Zones

It’s not just the lawmakers. Until today, no Kuki-Zo individual—not even high officials or police officers—can safely enter areas in the Imphal Valley where the Meiteis reside. Similarly, no Meitei—including high officials—would dare to enter Kuki-Zo hills. Even Kuki-Zo personnel in the central armed forces or the Army dare not enter Meitei-dominant areas.

In fact, it was the central government that rightly established buffer zones, which serve as strict borders, between Kuki-Zo and Meitei areas within the state. These buffer zones, manned by security personnel, remain to this day, and attacks have taken place despite their existence.

The violence has resulted in at least 258 deaths, which is a highly conservative estimate, and has destroyed thousands of homes while displacing tens of thousands of people. About 6,000 weapons were looted from state armouries by extremist groups during the initial days of the violence, and the majority of those arms remain in their possession to this day.

Can we really say that constitutional governance was in effect up until the resignation of Singh as Chief Minister?

Conflict Resolution

Buffer zones can be removed and assembly sessions can proceed with full attendance only once a peace agreement is reached between the Meiteis and the Kuki-Zos. Therefore, the pressing question is whether this conflict can be resolved within three years.

Leaders of the Kuki-Zo community view the establishment of a separate administration, such as a Union territory with a legislature, as the only viable solution, particularly because they have endured what they call a carnage where the role of the state government at the time was questionable. There have been reports that sections of the state police failed to protect them during the initial days of the violence or even accompanied Meitei extremist groups in attacking Kuki-Zo villages thereafter.

Kuki-Zo leaders also point to leaked audio recordings, referred to as the “Manipur Tapes,” in which former Chief Minister Singh is purportedly heard boasting about his alleged role in the ethnic violence. These tapes have been submitted to the Supreme Court, accompanied by a report from an independent forensic examination as prima facie evidence. While the Court has requested a forensic analysis from a government agency, the independent forensic lab, Truth Labs Forensic Services, concluded with over 93% certainty that the voice in the recordings belongs to Singh.

When communities suffer loss of lives and property, particularly when the role of the government is suspected, there must be a tangible sense of justice among the affected individuals. Justice is generally considered to have been served when specific measures are implemented. These include compensation, legal accountability, rehabilitation and support, public recognition of suffering with an apology, and structural reforms. Little progress has been made in this regard. Without the implementation of at least some of these measures, any peace proposal risks being perceived as a zero-sum game.

Until all sufferers feel that justice has been served at least to some extent, the prospects for constitutional governance in Manipur remain bleak. This should now be the main focus of the central government, as well as the Governor and his advisors.