President's Rule in Manipur

INTRODUCTION

The imposition of President’s Rule in Manipur reflects deep-rooted political instability and ethnic divisions that have hindered governance. While it grants the Centre direct control, its effectiveness depends on addressing the underlying conflict rather than merely maintaining administrative authority.

President’s Rule Under Article 356 

• Transfer of Power: The Centre assumes all functions of the state government, while Parliament takes over the state legislature’s role, except for the High Court, which continues to function independently.

• Grounds for Imposition: 

• The Constitution does not explicitly list the circumstances under which President’s Rule can be imposed, leaving it to the President’s discretion based on the Union Council of Ministers' advice.

• The only constitutional criterion is that the President must be “satisfied that a situation has arisen in which the Government of the State cannot be carried on in accordance with the provisions of this Constitution.”

• Proclamation and Initial Duration: The President issues a ‘Proclamation’ imposing President’s Rule, which remains in force for up to two months unless Parliament approves it.

• Parliamentary Approval: The Lok Sabha and Rajya Sabha must pass a resolution approving the proclamation before the two-month period expires; if approved, it extends for six months.

• Maximum Duration: President’s Rule can be extended in six-month intervals, up to a total of three years, subject to parliamentary approval.

• Conditions for Extension Beyond One Year: It can only continue beyond one year if:

• An Emergency has been declared in the country or that particular state

• The Election Commission certifies that elections to the state assembly cannot be conducted due to difficulties.

President’s Rule Through the Years in India

• Total Impositions: Since 1950, President’s Rule has been imposed 135 times in 35 States and Union Territories, including some that no longer exist.

• First Instance in Punjab (1951): When CM Gopi Chand Bhargava resigned due to internal Congress party differences.

• Most Recent Imposition in Puducherry (2021): After the Congress government lost a confidence vote due to defections and internal conflicts.

• Most Frequent Impositions: Manipur (11) ) and Uttar Pradesh (10) have seen the highest number of President’s Rule impositions.

• Longest Duration Under President’s Rule:

• Jammu & Kashmir: Over 12 years (4,668 days), mainly due to militant and separatist activities.

• Punjab: Over 10 years (3,878 days), largely due to law and order issues.

• Puducherry: Over 7 years (2,739 days), mainly due to political instability and government collapses.

• Mass Dismissals of State Governments

• 1977: Morarji Desai’s Janata government dismissed nine Congress-ruled states after the Centre changed.

• 1980: Indira Gandhi retaliated by dismissing nine Janata-ruled states on the same grounds.

• Lok Sabha Secretariat’s 2016 Report: Identified key reasons for imposition, including

• Militancy and law and order issues.

• Defections by MLAs.

• Break-up of coalitions.

• Passing of no-confidence motions.

• Resignations of Chief Ministers.

• Absence of legislatures in newly formed States.

• Public agitations leading to instability.

Landmark judgement on S R Bommai vs Union of India (1994) - BOX

• Background: The case arose after repeated instances of the Centre imposing President’s Rule and dismissing state governments under Article 356.

• Judicial Review of President’s Rule: 

• The nine-judge Bench of the  Supreme Court unanimously held that the President’s decision is subject to judicial review and can be struck down if based on illegality, malafide intent, extraneous considerations, abuse of power, or fraud.

• While the court cannot question the correctness of the President’s decision, it can examine whether the material used to justify the proclamation was relevant.

• Guidelines to Prevent Misuse: The court laid down safeguards to protect state governments, ensuring that Article 356 is not used arbitrarily to dismiss elected governments.

• Even after a valid proclamation, the court held that only the state legislature would be suspended and that the other limbs of the state government would continue to function unless the Lok Sabha and Rajya Sabha approved it within two months. 

• If not approved, the dismissed government is reinstated.

• Justice B P Jeevan Reddy’s Opinion:  He stressed that states are not mere appendages of the Centre, advocating that courts should interpret the Constitution to safeguard state powers.

• Impact on Federalism: The judgment led to a decline in the imposition of President’s Rule in subsequent decades

Comparison of President’s Rule and National Emergency

Analysis

• Political Collapse:

• Chief Minister N. Biren Singh resigned on February 9, 2025, after discussions with BJP’s central leadership, creating a leadership vacuum.

• The BJP, despite holding a majority in the Assembly, failed to agree on a successor, leading to the imposition of President’s Rule.

• Reasons of Resignation

• Loss of Political Support: Singh faced opposition from Kuki-Zo leaders, dissident BJP MLAs, NDA allies like NPP, and declining popularity in the Meitei-majority Imphal Valley, leading to pressure for his removal.

• Erosion of State Legitimacy: Over 21 months of violence led to a breakdown of trust in state institutions, exacerbated by allegations of partisan governance under Biren Singh.

• Allegations of Ethnic Conflict Involvement: A Supreme Court-monitored forensic investigation confirming a 93% match of Singh’s voice in a leaked tape, allegedly implicating him in the violence, raised further doubts about the government’s role.

• Manipur’s Current Status: 

• The Assembly has not been dissolved but placed under suspended animation, meaning it can be revived once President’s Rule is revoked.

• Of 111 cases of President’s Rule till 2015, 53 involved dissolution of the Assembly, while the rest were placed under suspended animation (Lok Sabha Secretariat report).

• Response:

• Opposition Party: Congress opposed the move, calling it proof of BJP’s governance failure over the past 20 months and had planned to bring a no-confidence motion against Biren Singh before his resignation.

• Kuki-Zo groups: They had been demanding President’s Rule, and welcomed the decision, citing deep mistrust in any new Meitei-led government. 

• Coordinating Committee on Manipur Integrity (COCOMI): Being an umbrella body of several Imphal-based civil society organisations, they termed the imposition of the President’s rule in the state as “undemocratic” and “most unfortunate”.

Consequences of President’s Rule in Manipur

• Dissolution of State Government’s Authority: The elected government loses power, and all administrative control shifts to the Centre, reducing state autonomy.

• Legislative Paralysis: With the Assembly under suspended animation, lawmakers lose their role in decision-making, delaying state-specific policies and governance.

• Extended Central Control Over Law and Order: The Union Home Ministry continues its direct oversight of security forces, further marginalising the state’s role in handling internal conflicts.

• Worsening Political Uncertainty: The BJP’s failure to appoint a new CM signals deeper political instability, weakening governance and public confidence in democratic institutions.

• Risk of Centralisation: Using President’s Rule to dissolve sub-State constitutional asymmetry may weaken tribal protections under Article 371C and escalate unrest.

• Risk of Escalating Armed Violence: The unchecked militarisation of civil society, with armed “village volunteers” and insurgents, may persist or worsen in the absence of a strong state-led response.

• Impact on Democratic Process: Delaying fresh elections in an already fractured political landscape may reduce faith in democratic governance, leading to public discontent and possible protests.

• International & Human Rights Concerns: 

• With over 60,000 displaced persons, prolonged bureaucratic control may slow relief measures, worsening trauma, economic distress, and insecurity.

• Continued violence and state inaction could invite scrutiny from international bodies, affecting India’s diplomatic standing.

CONCLUSION