Large-scale ethnic violence erupted in the state of Manipur on 3 May 2023, following a Tribal Solidarity March organised in hill districts to protest the Manipur High Court's direction to the state government to consider granting Scheduled Tribe status to the Meitei community. The clashes between the majority Meitei community and tribal Kuki-Zomi groups rapidly escalated into widespread arson, displacement, and loss of life across the state.
Background
The violence was triggered by a direction from the Manipur High Court asking the state government to submit a recommendation to the Centre for including the Meitei community in the Scheduled Tribe list. Tribal communities in Manipur's hill districts viewed this as a direct threat to their protected status under the Sixth Schedule and Article 244 of the Constitution, which provides special protections for tribal areas including restrictions on land ownership by non-tribals.
The Meitei community, which constitutes approximately 53 percent of Manipur's population and predominantly occupies the Imphal Valley, had historically sought Scheduled Tribe classification citing threats to their culture and demographic pressures. Kuki-Zomi tribes, who constitute about 40 percent of the population and inhabit the hill areas, argued that extending ST status to the already dominant Meitei community would dilute protections designed for historically disadvantaged groups.
Key Developments
The situation developed rapidly along the following lines:
Scale of displacement: Tens of thousands of residents were displaced from their homes within the first week of violence, with communities on both sides fleeing across the ethnic divide. An effective geographical bifurcation of the state emerged, with security forces struggling to maintain order.
Armed Forces deployment: The Central Government deployed additional battalions of the Indian Army and Assam Rifles under the existing Armed Forces (Special Powers) Act framework. An internet shutdown was imposed across the state, lasting several months.
Curfew and Section 144: Indefinite curfew was imposed across all districts of Manipur. The state government invoked Section 144 of the Code of Criminal Procedure, 1973 to prohibit assembly.
Article 355 invocation: Questions arose regarding the Centre's obligations under Article 355 of the Constitution, which mandates the Union to protect states against internal disturbance and to ensure that governance is carried on in accordance with constitutional provisions.
Judicial interventions: Multiple petitions were filed before the Supreme Court seeking intervention. The apex court began taking cognizance of the deteriorating situation, setting the stage for more extensive judicial oversight in subsequent months.
Implications for Practitioners
The Manipur crisis raises significant constitutional law questions that practitioners must track. The threshold for Central intervention under Article 355, distinct from the more drastic Article 356 (President's Rule), remains poorly defined in Indian constitutional jurisprudence. The events test whether Article 355 creates a justiciable duty for the Centre to act when a state government demonstrably fails to protect citizens.
For practitioners in tribal rights and Sixth Schedule litigation, the underlying High Court direction on Meitei ST status raises fundamental questions about the constitutional architecture of tribal protections. The political ramifications of extending scheduled status to a numerically dominant community would effectively undermine the protective framework designed for vulnerable groups.
The prolonged internet shutdown and indefinite curfew also raise Articles 19 and 21 concerns that will likely be adjudicated in the months ahead.