On February 13, 2025, the Indian government imposed President’s Rule in Manipur following a proclamation citing a constitutional breakdown in the state’s administration. This decision was based on a report from the state governor highlighting the ongoing ethnic violence and the inability of the state machinery to function effectively. This is the 11th time that President’s Rule has been imposed in Manipur, the highest in any State.
The ongoing conflict between the Meitei and tribal communities i.e., Kukis and Nagas in Manipur is a reflection of the broader hills-versus-plains divide prevalent across the Northeast. While the Kukis and Nagas primarily inhabit the hilly regions, the Meitei community resides in the Imphal Valley. The violence between these groups stems from long-standing issues such as land rights, economic disparities, and political representation. Tribal communities argue that development initiatives are largely concentrated in the Meitei-dominated Imphal Valley, leaving the hills neglected. Additionally, they highlight the political imbalance, noting that despite comprising only about half of the state’s population, Meitei’s holds a significant majority of the 40 assembly constituencies out of 60. Tensions escalated when the Manipur High Court, acting on a petition filed by the Meitei community, directed the state government to recommend their inclusion in the Scheduled Tribes (ST) category to the Centre. This move was met with strong opposition from Kukis and Nagas, who feared that granting ST status to the already politically and economically influential Meiteis would further marginalize tribal communities. The Meiteis, on the other hand, supported the demand, asserting that ST status would grant them the right to purchase land in the hilly regions. The ensuing violence led to over 250 deaths and the displacement of thousands. The situation gained international attention in July 2023 when a viral video surfaced, showing two women being paraded naked by a mob, triggering widespread outrage. Although large-scale clashes have subsided, tensions persist with sporadic incidents of violence. The state government struggled to manage the crisis, leading to increasing demands from the Kuki community for Chief Minister N. Biren Singh’s resignation, accusing him of bias toward the Meitei community. As the unrest continued, Biren Singh resigned on February 9, 2025. With the state administration in turmoil and facing a constitutional crisis, the central government intervened by imposing President’s Rule in Manipur to restore law and order.
President’s Rule, also known as a state emergency, is imposed when a state’s constitutional machinery collapses. The state governor reports the situation to the president, enabling the central government to take over its administration. The provisions governing President’s Rule are outlined in Part XVII (Articles 355-357) and Part XIX (Article 365) of the Indian Constitution. There are two key grounds for its imposition. First, as per Article 356, it can be invoked when a state’s constitutional machinery breaks down. Second, under Article 365, it applies when a state government fails to comply with directives issued by the central government. Additionally, Article 355 mandates the central government to ensure that every state functions in accordance with constitutional provisions, justifying intervention when deviations occur. The President enforces this rule through a proclamation, which must receive approval from both Houses of Parliament within two months. Initially, it can be imposed for six months but may be extended up to a maximum of three years with parliamentary approval. The rule can also be revoked through a subsequent proclamation. During its enforcement, the President assumes extensive powers, including taking over the state government’s responsibilities, enabling Parliament to legislate on state matters, and even suspending constitutional provisions related to state authorities if necessary.
Article 356 of the Indian Constitution has remained one of its most debated and criticized provisions. Since its enactment in 1950, President’s Rule has been invoked over 125 times, often under controversial circumstances. In several instances, it has been imposed arbitrarily, driven by political motives or personal interests rather than genuine constitutional crises. Over the years, nearly every Indian state has experienced President’s Rule at least once, with some states facing it multiple times. Currently, Manipur is under state emergency due to the ongoing conflict and constitutional breakdown. The last time President’s Rule was imposed in Manipur was in June 2001, following political instability and it remained in effect until March 2002.
The 38th Constitutional Amendment Act of 1975 made the President’s satisfaction in invoking Article 356 final and beyond judicial scrutiny, effectively making the proclamation of President’s Rule immune from judicial review. However, this provision was later removed by the 44th Constitutional Amendment Act of 1978, restoring the scope for judicial review in such cases. The landmark S.R. Bommai vs. Union of India case (1994) further clarified the constitutional limitations on the imposition of President’s Rule. The Supreme Court ruled that the proclamation of President’s Rule is subject to judicial review and must be based on relevant material; any decision based on irrelevant grounds can be struck down. The burden lies on the Central government to justify the proclamation, although the court will not assess the correctness of the material, only its relevance. If the proclamation is deemed unconstitutional, the court has the authority to reinstate the dismissed State Government and revive the State Legislative Assembly. Furthermore, the assembly should not be dissolved until Parliament approves the proclamation, and if Parliament fails to do so, the assembly must be restored. The ruling also emphasized that secularism is a fundamental feature of the Constitution, meaning any State government acting against secular principles can be subject to action under Article 356. Additionally, a loss of confidence in the State Government should be determined on the floor of the House, not arbitrarily. The ruling also prevents a newly elected Central government from dismissing State governments of opposing parties purely on political grounds. Importantly, the Supreme Court stressed that Article 356 should only be used as an exceptional measure in extraordinary circumstances to maintain constitutional governance.
President’s Rule serves as a crucial mechanism to ensure governance continuity when a State government fails to function as per constitutional provisions. It helps restore constitutional order, manage crises, and protect national interests by allowing Central intervention during political instability or security threats. This provision prevents administrative breakdowns and ensures stability in governance. However, its misuse for political motives remains a major concern. The ruling party at the Centre can exploit it to dismiss opposition-led State governments, undermining federalism and disrupting the democratic process. The lack of clear criteria for its imposition raises concerns about arbitrary use, while the suspension of the State Legislature centralizes power, weakening State autonomy. Additionally, prolonged President’s Rule can hinder development by causing policy delays and uncertainty. While necessary in exceptional circumstances, its application must be balanced to uphold democracy and federal principles.
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