Introduction

The Kuki-Meitei conflict, which resulted from protests by the Kukis against the Demand for ST Status being made by the Meiteis, turned into large-scale violence starting on 3 May 2023 and is still ongoing. The conflict led to large-scale violence and even led to the resignation of N. Biren Singh as the CM of Manipur. After receiving a report from Governor Ajay Kumar Bhalla, a proclamation was issued by President Droupadi Murmu, under Article 356 of the Constitution, leading to the imposition of the president’s rule on the state. This marked the 11^th time when Manipur was placed under a President Rule.

The conflict between Kukis and Meiteis has been going on for a long period in the State and the large scale of the conflict due to a result of demands for ST status by the Meitei people, is seen as one of the reasons why Kukis feared that the ST status would allow Meiteis to purchase the tribal land, due to which Kukis feared loss of lands. The fact that N. Biren Singh was part of the Meitei community and the perception of inherent bias in the mind of the CM and his remarks fueled the fire leading to the conflict.

This blog will talk about the recent imposition of the State emergency in Manipur and will see through the imposition of the emergency process while understanding the provisions of Article 356 and a historical overview of the conflict and its various ambits which led to the escalation of the situation which finally led to the resignation of the CM and the current scenario.

Overview of Article 356

The inclusion of emergency powers in the Indian Constitution was the subject of extensive debate within the Constituent Assembly, primarily due to concerns about their potential threat to the country’s federal structure.

The evolution of emergency provisions in the Indian constitutional framework can be traced to two key historical influences:

• The Government of India Act, 1935, introduced a federal system with the Governor as the head of each province, reinforcing the principle of power division. Section 93 of the Act granted the Governor-General and the Governors sweeping emergency powers under extraordinary circumstances, enabling them to take control of provincial administration. This was largely driven by the colonial government’s mistrust of Indian political parties, many of which were wary of participating in the legislative bodies formed under the Act.
• The Role of Dr. B.R. Ambedkar – On August 29, 1947, the Constituent Assembly established a Drafting Committee led by Dr. B.R. Ambedkar to draft the Constitution of India. Although Article 356 was modeled on the controversial Section 93 of the Government of India Act, 1935—with the President replacing the Governor—it was still deemed necessary given the challenges the Indian republic was expected to face after independence. When the Drafting Committee proposed granting the President similar emergency powers, several members opposed it, arguing that it mirrored colonial-era authoritarianism. Dr. Ambedkar defended its inclusion, asserting that no constitutional provision is immune from misuse and that the mere possibility of abuse should not justify its exclusion.

The provisions in the Indian Constitution allow the government to exercise special powers during emergencies. The State Emergency is defined under Article 356 of the Indian Constitution as follows:

If the President receives a report from the Governor of a state or otherwise determines that the government of the state cannot function according to the Constitution, the President may: 

• Assume all or any functions of the state government and the powers of the Governor, excluding the legislature. 

• Declare that the legislative powers of the state will be exercised by or under the authority of Parliament. 

• Issue any incidental and consequential provisions necessary to implement the Proclamation. 

However, the President cannot assume the powers of a High Court or suspend any constitutional provisions related to High Courts. Both Houses of Parliament must approve the Proclamation within two months; failing which, it will cease to operate. If the House of the People is dissolved when the Proclamation is issued, it will expire 30 days after the House is reconstituted unless it is ratified within that period. 

An approved Proclamation remains valid for six months, but it can be extended for further six-month periods with parliamentary approval, subject to a maximum of three years. 

It is read with Article 355 of the Indian constitution which defines the duty of the Union to protect every state from external aggression and internal disturbance and to ensure that the governance of each state is conducted according to constitutional provisions. 

Manipur’s Landscape

Pre-independence

Manipur is one of the North-Eastern states known as the 7 sisters. The conflict between the Kukis and Meiteis could be said to have begun even before the Independence of India as a country. The kingdom of Manipur was an independent kingdom which was ruled by Meitei Dynasty. After the Angelo Manipur War in 1891, Manipur became a princely state in the British Raj.

The conflict between Kuki and Meitei could be observed from the time when the British, after the Angelo-Manipur war in 1991, the administration of the state, which was the valley part, went into the hands of the British who ruled the state through a Darbar, the highest executive authority of the state. However, the exclusive control over the forest areas was in the hands of the Britishers, where the tea capitalists were in power to make use of that land, which enraged the Kuki tribe as it led to the loss of their ‘hunting grounds’.[i]

One of the major features of this administration that could be observed was that while the hill administration was completely separated from the rest of the administration, the foreign missionaries were allowed to operate in the hill areas.[ii] These could be seen as one of the first points the differences between the Meitei and Kuki people started to appear. The increase in the number of Kuki people becoming Christian, led to a gap between Kukis and Meiteis of the valley, being Hindus.

The arrangement of separate administration of hills and valleys continued till 1947 before the introduction of the Manipur State Constitution Act, 1947. However, the division between the valley and land areas was good enough to create a rift between the Kukis and the Meiteis.

Post Independence-

After Independence, Manipur through The Manipur Merger Agreement of 1949, became a part of India. The Kukis by the order in the Constitution (Scheduled Tribes) Order, 1950, became a part of the Scheduled Tribes as per Article 342 of the Indian Constitution. This planted one of the seeds of dispute post-independence where Meiteis were not considered as a part of the STs.

The Meiteis not being considered as STs acted as one of the reasons for division between the communities. If we look at the land area in Manipur, the division could be seen in the form of hill areas and valley areas, where the valley is a total of 10 percent of the land of Manipur while the valley is 90 percent. The valley is majorly inhabited by Meiteis, while the hills are under the Kukis. The demand for including the Meiteis in the STs was considered twice in 1982 and 2001 but was rejected since the Meiteis did not have the characteristics of becoming a part of the STs.

The Meiteis constitute the highest density of population in Manipur being 53% but they still are mostly restricted to a small area of the valley and the grant of ST status would allow them to purchase forest lands, allowing them to meet the needs of their ever-growing population. This however triggered the conflict against the Kukis where they got concerned that the lands they own in the forests might be taken away.

The Start of Conflict

On 3 May 2023, the members of the tribes residing in hill areas of Manipur were protesting, by conducting a “Tribal Solidarity March” against the recommendation of the Manipur HC to provide reservations to Meitei communities in the ST, and the protest soon turned violent which led to various casualties. The union government claimed that the involvement of Meiteis was majorly due to a counter-response against the protest. An order for shoot-on-sight was issued by the government as a reault of rising violence.

The incidents like taking 14 days to register a Zero FIR of the two Kuki women who were paraded naked showed a sorry state of affairs for Manipur as a state. The incident of CM’s voice matching with the audio tapes submitted by a Kuki Civil Body showed a dire state of affairs for Manipur, eventually leading to Singh’s resignation before the NO-confidence motion could have been passed by the opposing party. This showed a severe breakdown of State machinery where the state wasn’t able to function and keep its people safe.

After the resignation of N. Biren, the President’s rule was imposed on 9^th February, 2025 whereby the Government took the administration of the state. The dire state of conflict in the state, which till now has claimed more than 200 lives led to an urgency where president’s rule became a necessity.

Requirements Under Article 356

As per the Case of S.R. Bommai vs Union Of India[iii], the federal character of the Indian Constitution carries an implication where the process under Article 356 can only be carried out when there is a complete breakdown of the constitutional machinery and administration of the state, and should be used only as a last resort when all the means of preventing the breakdown have failed. There was an expression of “cannot be carried on” which means that there is a stalemate that cannot help in following the provisions of the constitution and governance of the state.

In this instant case, we observe that the violence was of such a large scale that the actions by the government of Manipur were proving to be insufficient and the death toll, which kept increasing was a sign that the state was not able to function properly and there was an administrative failure in the machinery from where we observe that the imposition of state emergency became a necessity and the report by the governor led to the president Murmu declaring the state emergency as per the provisions of Article 356.

We observe in the Bommai case that there was a provision of warning to be issued to the errant State in the situation when the state is not functioning as per the Constitution, which was not followed in this instant case. But we observe that the situation in Manipur was dire where the machinery of administration wasn’t functioning and killings at a large scale went on, which led to the declaration of emergency. The Bommai case gave an exception where the Union had the power to take immediate action, where in cases the inaction by the state might lead to disaster for the state.

State Emergency and Federalism

The case of SR Bommai along with the case of the State of Rajasthan vs UOI[iv] show that the power under Article 356 must be used only as a last resort while emphasizing the importance of federalism. The precedents in these judgments prevent the arbitrary misuse of power by the Union Government against the State Governments and ensure that such step by the Union government isn’t taken where the emergency is declared only because the ideology of the union doesn’t match with the ideology of the state government.

The Sarkaria Commission, headed by Justice R.S. Sarkaria, was appointed in 1983 to examine Centre-State relations. The Commission recommended that Article 356 should be used only in rare and extreme cases where there is a genuine breakdown of constitutional machinery in a state. It cautioned against treating every minor breach of constitutional provisions as grounds for imposing President’s Rule. 

The declaration of a State emergency in Manipur is a unique situation in terms where the Governments at both the Center and state were the same, and yet the emergency was declared. The case of Manipur presents a picture where the CM of Manipur resigned and the State Emergency was declared, where the motive might be to prevent a no-confidence motion from the opposition party. This was confirmed by the post on X by Congress leader Jairam Ramesh, who said that INC was ready to move the no-confidence motion, but the CM resigned.

The situation in this case could be seen as a violation of federalism where the act was done by the ruling party just to retain its power and control over the state, by not letting the democratic processes being followed. The case of Kesavananda Bharati vs State of Kerala[v] declared Federalism as an important part of the basic structure of the Indian Constitution.

The case of Government of NCT of Delhi v. Union of India[vi] talked about the importance of Federalism and the fact that an important character of Indian Federalism is to place the Country under the control of the Union Government and the state or regional units exercise their powers within their legislative spheres and there is a spirit of cooperation between the Union and the State. It interpreted that the Union cannot take any step which invalidates the spirit of federalism.

Free Movement and Continuing Crises

After a high-level meeting chaired by Amit Shah, free movement was restored in Manipur from March 8, 2025, leading to people having free movement on roads. It was also declared that actions must be taken against those who try to create obstructions in the free movement of the people.

However, the Free Movement declaration did not exactly serve its purpose where one more death and 20 more injuries were added to the toll, just a day after its declaration on 9^th March, 2025. As the violence continues, it presents a sorry state of affairs for humanity where the seeds of conflict planted during British Rule continue to grow into a tree of violence that continues to affect the State of Manipur even today.

Analysis

The declaration of emergency in Manipur presents a unique case where the declaration of emergency in a State has happened for the first time ever where the government at the Union and the state is same, i.e. the BJP. This situation presents a unique scenario where the action was done when the party found out that the CM is losing support of his own party members and the assembly itself and the declaration of emergency in this case aligns with the same, where the emergency has been declared to prevent losing its position from the state.

The reasons of the declaration of emergency may be unknown. Still, the case presents a similar scenario where the Emergency was declared to further political motives, just like in the case of Jammu and Kashmir when the ally between BJP and PDP was broken leaving PDP in the minority. There was no CM in the state, and the president declared emergency after receiving the report from the governor. This move was critical as it paved the way of abrogation of Article 370 from Indian Constitution.

The motive of the declaration seems to be mixed and the fact that the same party is there at the center and the state, shows that the emergency declaration has more to show than what is visible at face value. Only time will tell what happens later.

Conclusion

The declaration of emergency due to the breakdown of constitutional machinery in Manipur, stemming from the conflict between the Kukis and Meiteis, presents a unique scenario where, for the first time in Indian history, an emergency has been declared with the same parties in control at both the central and state levels. The violence in Manipur paints a grim picture, where conflicts instigated by the British continue to haunt India today.

The rift between the Kuki and Meitei communities, originating during that period, persists, unity between them seems like a far-fetched idea. The spirit of fraternity outlined in the preamble of the Indian Constitution appears to be dying a painful death since the onset of the conflict. Additionally, the actions of the Central Government raise questions about the spirit of federalism, as the use of these provisions seems like a last resort to maintain control over Manipur.

The Manipur situation has shown a new ambit where the actions in critical scenarios like imposition of Emergency, the discretion must be followed with due caution and this declaration of emergency poses a question about the federalism and future implications where the declaration of emergency might be done at the whims and fancies of the State to further its objectives.

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This article is authored by Suyash Shukla and Abhishek Bhatt.

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[i] Jangkhomang Guite, Colonialism and Its Unruly? —The Colonial State and Kuki Raids in Nineteenth Century Northeast India, 48 MODERN ASIAN STUD. 1188, 1190 (2014).

[ii] RAJENDRA KSHETRI, DISTRICT COUNCILS IN MANIPUR: FORMATION AND FUNCTIONING (New Delhi: Center for Manipur Studies and Kansha Publishing House 2006).

[iii] S.R. Bommai v. Union of India, (1994) 2 SCR 644.

[iv] State of Rajasthan v. Union of India, AIR 1977 SC 1361.

[v] Keshavananda Bharti v. State of Kerala, (1973) 4 SCC 225.

[vi] Government of NCT of Delhi v. Union of India, (2018) 8 SCC 501.