MANIPUR- AN ETHNIC VIOLENCE BY - HARSHITHA. S
MANIPUR- AN ETHNIC VIOLENCE
AUTHORED BY
- HARSHITHA. S
ABSTRACT
Manipur a north-eastern state in India
was embroiled in an ethnic violence due to a clash between valley-dwelling Meiteis
and the hill-based Kukis. The primary reason for the issue is the demand for
Scheduled Tribe status by the Meiteis because the current legislation in
Manipur prevents Meiteis from purchasing land in the hilly region whereas the Kukis
who were already granted the status of Scheduled Tribe can purchase land in the
valley region. This essay briefly explains the demands made by both Meiteis and
Kukis regarding tribal status by analysing the existing constitutional
provisions. It further delves into the reasons behind the violence by examining
the triggers such as illegal immigration, eviction drive and the high court’s
order that led to the breakout of this violence. This paper further analyses
the legal provisions that have been violated and the constitutional rights that
were restricted during the violence. It also generally examines other factors
such as the Government’s intervention, media coverage, and all other actions
taken towards resolving the conflict. It proposes possible solutions to resolve
the ongoing issue. This article concludes by stressing that the government must
take effective steps to prevent future conflicts in our country.
Keywords: Meiteis, Kukis, eviction
drive, violence, tribal status, illegal immigration.
I. INTRODUCTION
Manipur, a state in India, is
currently facing ethnic violence due to a clash between the tribal Kukis and
the Meiteis. The conflict is primarily between the valley-based Meiteis and the
hill-based Kukis, which arose from the Meiteis' demand for scheduled tribe
status but there were al other factors that triggered the violence as well.
This essay will examine the reasons for the violence and analyse the general
and legal aspects of the issue and propose some possible solutions to be sought
out by the government to resolve the conflict in Manipur and restore peace in
our nation.
II. MANIPUR-
A BRIEF HISTORY
A. Geography of Manipur:
The north-eastern Indian state of
Manipur is situated between Myanmar to the east, Assam to the west, Nagaland to
the north, and Mizoram to the south.[1]
The state has a population estimated at 3.3 million.[2]
The area of Manipur is predominantly hilly, forming up to 90 per cent of the
region, while the remaining 10 per cent consists of a valley. The majority of
the population, around two-thirds, is located in the valley region.[3]
B. Ethnic Groups in Manipur:
The three primary tribes residing in
Manipur are the Meitei, Kuki, and Nagas. Approximately, the Meitei community
makes up 56% of the state, while the Kuki tribal community makes up 28% of the
population and the Nagas and other communities constitute the remaining 16%.[4]
The Meiteis, who are primarily Hindus, dominate the Imphal valley (plain
region) whereas the Kukis and other tribes, who are mostly Christians, dominate
the hilly region; other religions are also present among them and the Meiteis were
granted the status of Other Backward Class (OBC) and Scheduled Caste (SC),
while the Kukis, Nagas, and other hill tribes were determined as Scheduled
Tribes (ST).[5]
C. Kuki Migration:
History depicts that the Meiteis are
indigenous people of Manipur whereas the Kukis have migrated to the state over
time. In the 18th century, the ruling king of Manipur faced recurring conflicts
due to raids from neighbouring Naga territories and so in order to create a
demographic buffer, he resettled the Kukis in the hilly regions of Manipur.[6] In
1819, the Burmese kingdom (now Myanmar) invaded Manipur and caused destruction
and to fight against them, Emperor Gambir Singh agreed with the British, to grant
them control over the state administration in exchange for their assistance.[7]
This agreement led to the Anglo-Burmese War, which was won by Britain and to
prevent future invasions, Kuki tribes from Chin, Tripura, and Mizoram were
relocated to the hilly regions of the state.[8]
D. Annexation with India:
In 1947, the Maharaja signed the
Instrument of Annexation in 1949, ceding defence, external affairs, and
communication to India and as a result, Manipur was listed in the C category of
Schedule I of the Indian Constitution.[9]
Until 1947, Manipur was a princely state and in 1956, the 17th Amendment of the
Constitution declared Manipur a Union Territory, and it was later declared as a
state under the 27th Amendment in 1972.[10]
E. Special provision:
Article 371C of the Indian
Constitution empowers the President to order a Legislative Assembly consisting
of members elected from the hill area, and the Governor must make regular
reports on the condition of the Hill areas.[11]
III. SCHEDULED TRIBE STATUS FOR KUKIS
Before the 1949 agreement, Meiteis,
Kukis, and other communities of Manipur were recognized as tribes but after the
said agreement, the tribal status granted to the Meiteis was withdrawn while
the status of the Kukis and Nagas remained the same.[12]
The Kukis were recognized as Scheduled
Tribes as per the Constitution (Scheduled Tribes) Order
of 1950 and the Meiteis also claim the recognition of their community as a
scheduled Tribe.[13]
IV. BREAKOUT OF THE VIOLENCE
On 3 May 2023, ethnic violence broke
out in Manipur between the Meitei and Kuki communities.[14]
The All-Tribal Student Union Manipur (ATSUM) organized a "Tribal
solidarity march" in all hill districts of Manipur.[15]
An uncontrollable outbreak of violence ensued, resulting in stone pelting, vandalism,
and arson.
The timeline of events is as follows,[16]
March 27- the Manipur High Court
ordered the state government to consider granting ST status to the Meiteis in
response to a petition filed by the Manipur Tribes Union.[17]
April 28- Tribal bodies (Nagas and
Kukis) expressed their displeasure against their eviction from the hilly region
due to suspicion of poppy cultivation. Section 144 of CrPC was imposed along
with a 5-day internet shutdown.
May 3- More than 60000 people turned to
a solidarity march in the districts of hilly areas.
May 4- More brutal violence such as
mob lynching, sexual assault, and burning of houses were reported. The Rapid
Action Force was deployed along with the Army, CRPF, Assam Rifles, and government-issued
shoot-at-sight orders in extreme situations.
May 6- Residents were displaced to
Mizoram and Assam for shelter. More Vigilance in Indo-Myanmar border.
May 17- The Supreme Court said that
the order passed by Manipur High Court is invalid.[18]
May 30- The Internal Affairs minister
of India visited Manipur and announced the creation of a Judicial committee.
July 19- Two women being paraded
naked and molested by a mob of Meitei men surfaced on the internet and sparked
National outrage.[19]
July 20- The Supreme Court took Suo
motu cognizance of the offense and asked the Centre and state government to
take action.[20]
August 8- The Supreme Court appointed
an all-women panel to oversee the investigation to be conducted by 5 officers
of DSP rank from other states.[21]
September 23- Protest over the killing
of two students. The Armed Forces (Special Powers) Act was extended for 6
months in Manipur.[22]
October 7- Mobile internet service ban extended till
October 11.[23]
November 14 - The Internet ban was extended
till November 18.[24]
November 28- The SC panel submitted a
report on the death of 166 victims of violence.[25]
V. REASONS FOR THE ISSUE
A. Meiteis’ Demand:
The Scheduled Tribe Demand Committee
of Manipur (STDCM) began demanding the ST status for the Meitei community in
2023 and the reason behind the demand being said by the Meiteis is that the
granting of ST status would help preserve their ancestral land.[26] Since
only 10 per cent of the state is made of the valley region, the Meiteis are
afraid that their culture and heritage might be influenced by the other tribes
if they start living among them and they may lose their identity.[27] Moreover,
The Manipur Land Revenue and Land Reforms Act, of 1960 prohibits
the transfer of tribal lands to non-tribal except under special permission
thereby preventing Meitei from buying land in hill districts whereas, the
people of the hilly region can purchase land in the valley region.[28]
B. Kukis’ contention:
The Kukis predominantly reside in the
hilly region and oppose the demand of Meiteis. Since the Meiteis predominantly reside
in the valley region of Manipur, they are comparatively more well-developed
socially and economically than the people of the hills.[29]
Moreover, they contend that the people of the Meitei community come under the OBC
and SC categories and they were given fair opportunities already and they also believe
that ST status and special provisions regarding land transfer of the Kukis make
them feel protected against the Meiteis because the majority of the population
are Meiteis.[30]
Moreover, the political representation of Kukis is inadequate which is yet another
reason to oppose Meiteis’ demand.[31]
VI. TRIGGERS FOR THE VIOLENCE
There has always a disagreement
between the Maitais and Kukis since 2012 but it erupted into violence due to
the three following triggers[32],
1. Illegal immigration from neighbouring
countries[33].
2. Forceful eviction due to poppy cultivation
on the hill.
3. Manipur High Court’s order favouring
the Meiteis.
1. Illegal Immigration:
Manipur shares most of its border
with the country Myanmar which experienced a coup in February 2021 and since
then the refugees from the war-torn country started immigrating to Manipur,
Nagaland, Mizoram, etc, it was contended by the Meiteis that the Kukis of the
hill districts are aiding these refugees to illegally immigrate to Manipur.[34]
In 2022, The state government started an eviction drive in the reserved forest
region to remove the encroachers.[35]
Earlier in 2023, when the eviction drive reached Cherachandpur, disagreement
between the forest dwellers and the authorities arose and acted as one of the
triggers for this violence.[36]
2. Eviction drive in hill districts:
As per data released on May 16 2023
by K. Megachandra Singh, Superintendent of Police of Narcotics and Affairs of
Border, about 15,496 acres are used for poppy cultivation among which 13,121
acres were in the area dwelled by the Kukis.[37] Thus,
the State government started the eviction drive to control such poppy
cultivation in the hilly region of Manipur.[38]
The Kukis felt that they were being targeted by the government and expressed
their disagreements which acted as a trigger for the violence.
3. Manipur High Court’s Order:
The Meitei Tribe Union members filed
a writ petition in the High Court and the court gave an order on March 27 2023
stating that “the government should consider including meiteis as tribes under
St category”.[39] Though
the Supreme Court clearly stated that the High Court has no power to give
directions regarding the inclusions in the ST category and it is wholly upon
the Parliament to decide, the said order acted as a trigger for the violence.[40]
VII. LEGAL
ANALYSIS
A. Scheduled Tribe under the
Constitution:
Article 366(25) of the constitution
defines scheduled Tribes as “such tribes or tribal communities or parts of or
groups within such tribes or tribal communities as are deemed under article 342
to be Scheduled Tribes.”[41]
Article 342 states that “the president with respect to any state, may by
notification, specify the tribe to be a scheduled Tribe with the consultation
of the governor. The Parliament may by law include or exclude the tribe from
the ST category.”[42]
As per Article 342 of the Constitution, the Parliament and the President on the
advice of the Governor alone have the power to enact a law regarding the
inclusion and exclusion of groups in the Scheduled Tribes list.[43] A
High Court does not have any power regarding this matter.
B. Process for Inclusion of Tribes:
The criteria to recognise a community
as a Scheduled Tribe are : (i) indications of primitive traits, (ii)
distinctive culture, (iii) geographical isolation, and (iv) shyness of contact
with the community at large.[44]
Any state or union territory’s
government must initiate the proposal for inclusion of a tribe to the scheduled
Tribe list by submitting it to the Union Tribal Affairs Ministry and the Office
of Regional General of India (ORGI).[45]
If the ORGI approves the proposal then it is sent to seek the approval of the National
Commission for Scheduled Tribes. After receiving their assent, the said
proposal is directed to the cabinet for making an Amendment to the Constitution
(Scheduled Tribes) Order, 1950.[46]
C. Laws Violated During the Violence:
Article 19(1)(b) of the constitution
gives the right to form an assembly provided that it should be unarmed and
peaceful and it is subject to restriction under Article 19(3) if it tends to
cause harm to the people.[47]
(i) Indian Penal Code:[48]
In India, there is no special
legislation for communal or ethnic violence, but section 146 of the Indian
Penal Code punishes the offence of ‘rioting’. Several acts of violence had
occurred which are punishable under this code.
·
Section
141-An assembly of five or more member if their common object is to resist any
law, commit mischief, assault, etc, constitute an “Unlawful Assembly”.
·
Section
146- Whenever force or violence is used by unlawful assembly or by any of its members,
they are guilty of ‘Rioting’ and punished with imprisonment for two years under
section 147.
·
Section
153 A- the offence of promoting enmity between different groups on the grounds
of religion, place of birth, residence, language, etc, is punished with
imprisonment for up to 3 years.
During the violence, the people of Hill region
who are considered to be mostly Christians were attacked and in extension to
that many churches were destroyed.[49]
·
Section
295- Injury or defiling a place of worship with intent to insult any religion
is punished with imprisonment for 2 years or with a fine or with both.
During the violence, women were
molested and sexually assaulted. Two women were brutally molested and paraded
naked in the street by a mob of men from the Meitei community, and that video
was spread widely and sparked outrage among people throughout India.[50]
·
Section
376 punishes the offence of ‘Rape’ with life imprisonment or with 10 years and
also a fine.
·
Section
376D punishes Gang rape with life imprisonment till a person’s natural life.
(ii) Curfew Imposed:
Section 144 of the Criminal Procedure
Code confers power to the senior Magistrates to issue orders in urgent cases of
nuisance or apprehend danger to abstain any individual or persons residing in a
particular place from doing certain acts.[51]
The order issued under this section imposes restrictions on people from moving
from one place to another and thus it was issued during the violence in order
to prevent further destruction.[52]
(iii) Constitutional Rights
Restricted:
1. Movement restricted:
Article 19(1)(d)[53]
of the Indian constitution ensures freedom of movement to all citizens but a
curfew under section 144 of the Criminal Procedure Code was imposed thereby
restricting the movement of the people.[54]
2. Internet Ban:
In 2020, the Supreme Court declared that ‘access
to the internet’ is a fundamental right under Article 19(1)(a) of the
constitution[55] which
guarantees freedom of speech and expression. This right was restricted to the
people by banning the internet throughout the state.[56]
3. Right to education:
Many schools and educational
institutions throughout Manipur were closed due to the violence[57]
and thus the right to education under Articles 21[58]
and 21A[59]
of the constitution was affected.
4. Right to life:
The right to life ensured under
Article 21 of the Constitution also implies liberty and the right to live with
dignity. But, assaults on innocent people, sexual assaults on women, loss of
lives[60], and
causing injury to someone, all these acts violate the above said right.
Moreover, the state government issued a ‘shoot at sight order’ in extreme cases
also violates this right.[61]
5. Sexual violence:
Though the reason for the violence is
due to differences of opinion between two ethnic groups, women were made
victims of sexual assaults during the violence thereby violating the right to
life of women.[62].
6. Cultural Rights:
Article 29(1) guarantees all the
citizens ‘having distinct language, script or culture of its own shall have the
right to conserve the same’.[63] Thus,
when one community does any act to disrespect another community it is
considered to be violative of the said right.
VIII. GENERAL
ANALYSIS
A demand for Scheduled Tribe status
by an ethnic group resulted in uncontrollable brutal violence despite the
presence of the army, Assam Rifles, CRPF and State police. Let us analyse the
steps taken by the Government and the judiciary regarding the violence, the
role of media, and also some possible solutions.
A. False information:
One of the reasons for the violence
to be triggered is the order passed by the Manipur High Court in favour of the
Meiteis. Since the Supreme Court declared that the High Court does not have
jurisdiction over the matter of inclusion or exclusion of tribes, the High
Court has to make it clear to the public. However, the illegality of the order
was not made known to the public and the only news about the order in favour of
the Meiteis was widely circulated, which was a major reason for the violence.
B. State’s negligence:
Each state has an intelligence
department to foresee any danger to the state. They submit reports regarding
the status of a particular state to the Chief Minister of that state. If a
state’s intelligence department was functioning properly, the state government
would have known about the possibility of a riot. So, it was either the
negligence of the government or the failure of the state’s intelligence that
led to the violence.
C. Government’s intervention:
Since the state government failed to
bring the situation under control, the central government was the people’s only
hope to take measures to dissolve the issue. Though the Central government
attempted to form a peace committee comprising representatives of both
communities and the representatives of the government, it failed because the
representatives of both communities refused to join the committee and initiate
peace talks.[64] The
government was also reluctant regarding this matter and did not proceed further
to establish the committee.
D. Addressing the issue:
Though the Prime Minister of India
addressed to the press that the perpetrators of sexual assault against two Kuki
women would be punished[65],
he failed to address the root cause of the issue.
Even a proper discussion regarding the issue
was not made in the Parliament sessions.[66]
E. Possibility of bias:
Since the state legislature of
Manipur is dominated by the members of the Meitei community[67],
there is a possibility that the members of the legislative assembly may have a
bias that restricts them from taking action against the people of the Meitei
community.
F. Media coverage:
Two women’s modesty was sacrificed to
get the attention of the nationwide media to address the violence in Manipur.
Due to the internet shutdown and curfews, misinformation and false rumours were
easily spread and added more fuel to the fire. Even some of the most popular
news television channels failed to address the issue.
G. Suo motu cognisance:
After the video of two women being
sexually assaulted by a mob was widely spread, the Supreme Court took Suo motu
cognisance of that offence and ordered both the state and central government to
take action against the offence.[68]
On August 7, 2023, the Supreme Court appointed an all-women panel of judges to
oversee the investigation carried out in Manipur regarding the 6500 First
Information Reports filed during the violence throughout the state.[69]
IX. TIMELINE
OF COMMUNAL VIOLENCE IN INDIA[70]
1. Nellie massacre of 1983- Bengal-origin
Muslims were massacred in Nellie in central Assam.
2. An anti-Sikh riot of 1984- after
Indira Gandhi was shot dead violence against Sikhs blew up.
3. Babri Masjid demolition of 1992- A Hindu
mob demolished the historical Babri Masjid.
4. Gujarat riots of 2002- Hindu pilgrims
were killed by a Muslim mob and as a result, a huge riot in Gujarat occurred.
Though, history taught us many lessons
we still don’t have any specific legislation for communal violence or mob
violence in India.
X. LEGISLATION FOR COMMUNAL VIOLENCE:
In 2005, the Communal Violence
(Prevention, Control and Rehabilitation of Victim) Bill[71]
was passed in the parliament but it was not enacted in our country and no steps
have been taken to date to pass the bill as an Act.
The Government of Manipur passed an
Ordinance in 2018 called the Manipur Protection from Mob Violence
Ordinance,2018 which was made Act later punishes acts of mob lynching and
other hate crimes and also imposes liability on the police officer who is in
charge. The court can take cognizance without prior sanction of the state
government to prosecute the authorities.[72] Although
Manipur has specific legislation against mob lynching, it does not appear to be
effective. If the legislation had been in full force, the violence could have
been avoided in the early stages.
XI. POSSIBLE SOLUTIONS
By analysing both meiteis and kukis
demand some possible solutions are suggested below.
(i) Permanent lease:
The State government can make
legislation with the provision of permanent leases in land transfer throughout
the state. The people of the valley region may be given the right to take a lease
of the land in the hilly region by way of permanent lease so that if the lessee
dies without legal heirs the land will be restored to the heir of the lessor.
This will be an effective way to safeguard the land of the hilly region as well
as to satisfy Meiteis' demand for land.
(ii) Stringent drug laws:
Parliament or the state legislature should
make strict legislation to control illegal drug cultivation in the hilly region
with severe punishments and appoint separate authorities to supervise it to
make it more effective.
(iii) Increase in vigilance:
Since illegal immigration stands as
an issue for the people of Manipur, more forces should be deported to the
border to prevent illegal immigration from neighbouring countries. The illegal
immigrants if identified should be prosecuted legally.
(iv) Unbiased mediator:
A committee with members representing
various communities and ethnicities of Manipur should be formed along with
members who take a neutral stance i.e., members not belonging to any of the
communities existing in the state, should be formed. All demands made by each
community should be scrutinized and an effective solution must be suggested in
an unbiased manner. Such suggestions should also be submitted to the state
government.
XII. RELEVANCY
OF PRESIDENT RULE:
Article 356 of the Constitution says
that in case of failure of constitutional machinery in the state, the President
may proclaim an emergency in the state and take over all the functions of the
state government and the law-making authority will vest in the Parliament.[73]
Under Article 355 of the constitution,
the Centre has the duty to protect the state from external aggression, Internal
disturbance and war[74].
On December 16, 1992, when the Babri masjid was demolished, unrest took place
in many states like Madhya Pradesh, Rajasthan, and Himachal Pradesh and so a state
emergency was proclaimed.[75]
Similarly, the ongoing riots and violence in Manipur also amount to the failure
of constitutional machinery. However, the central Government does not seem to
be interested in dissolving the existing state government. Thus, irrespective
of the rule by either the Central or the state government, the ongoing issue is
expected to be unaffected.
XIII. CONCLUSION
The People of Manipur have faced many
challenges due to the violence and innocent lives were affected as a result.
Though the demands of both communities seem valid, violence will never be the
solution. Rather it is seen as another hurdle to achieve the demand. In order to
restore peace in the violence-driven state the blame game needs to be stopped
and the government should take effective steps towards it.
Violence in Manipur is a complicated
web of historical, ethnic and political causes that continue to persist in the
state. Thus, the government, judiciary and we people must work together to
resolve the issue and restore peace in the state and also take steps to prevent
future conflicts by formulating long-term solutions.
[3] Zou T, ‘Distribution of Ethnic
Groups in Manipur Hills’ (2018) 8 Journal of North East India Studies
[4]Nigombam M (Geographical study
of Manipur)
accessed 23 October 2023.
[5] Admin
M (The people - Manipur Science and Technology Council (MASTEC))
accessed 23 October
2023.
[6] Schoetz A and Das Y, ‘When Did
Kukis Reach Manipur and How the Past Is Shaping the State’s Present’ INDIA
TODAY (4 August 2023) accessed 31 October 2023.
[9] S.M.A.W.
CHISHTI, ‘POLITICAL DEVELOPMENT IN MANIPUR 1919-1949 ’ (dissertation, 1980)
accessed 12 October 2023.
[10] ibid.
[11] The Constitution of India 1950, art
371C (The Constitution).
[12] ‘High Court Judgment and Violence
in Manipur Explained’ (SCC Blog, 12 May 2023)
accessed 13 August 2023.
[13] The Constitution (Scheduled
Tribes) Order 1950.
[14] Kaushik K and Prabhuswamy R,
‘Manipur: Ethnic Violence in the Indian State Explained’ (Reuters, 21
July 2023)
[15] ‘Manipur Violence Explained:
History of Suspicion between Ethnic Groups Escalates Violence’ THE ECONOMIC
TIMES (9 May 2023)
accessed 14 October 2023.
[16] Vallooran G, ‘From Contentious HC
Order To Using Of Women As Instruments Of Violence: A Brief Timeline Of Deadly
Manipur Clashes’ THE FREE PRESS JOURNAL (20 July 2023).
accessed 14 October 2023.
[17] Lakshman A, ‘Manipur High Court
Allows Tribal Bodies to Appeal against Order on ST Status for Meiteis ’ THE
HINDU
accessed 28 October 2023.
[18] ‘Completely
Factually Wrong: SC Slams Manipur HC Order on Meiteis and ST list’ THE WIRE
(17 May 2023)
accessed 12 October 2023.
[19] ‘Women Paraded Naked in Manipur:
CBI Chargesheet against 6, Juvenile’ THE INDIAN EXPRESS
[20] Sharma P, ‘’Deeply Anguished,
Using Women as Instruments of Violence Unacceptable’: Supreme Court Takes Suo
Motu Cognizance of Manipur Video’ (Live Law, 20 July 2023)
accessed 13 October 2023.
[21] Rajagopal K, ‘In Supreme Court’s
“Healing Touch”, an All-Women Committee of Three Former High Court Judges to
Oversee Relief in Manipur’ THE HINDU
accessed 23 October 2023.
[22] ‘AFSPA Extended in Manipur for 6
Months from Oct 1 barring 19 Police Stations of the Valley’ TIMES OF INDIA
(27 September 2023)
accessed 26 October 2023.
[23] Shirin B, ‘Manipur Internet Ban
Extended till October 11 amid Unrest, Violence’ INDIA TODAY (7 October
2023)
accessed 23 October 2023.
[24] Shirin B, ‘Manipur Government
Extends Mobile Internet Ban till November 18’ INDIA TODAY (14 November
2023)
accessed 25 November 2023.
[25] Singh V and Lakshman A, ‘Supreme
Court Panel Submits Report on Manipur Victims’ THE HINDU
accessed 30 November 2023.
[26] Kipgen L and Kipgen N,
‘Intricacies Of Meiteis’ ST Status Demand And The Hill-Valley Divide In
Manipur’ Outlook (29 May 2023)
accessed 30 October 2023.
[27] ibid; Donthi
P, ‘What’s Behind the Manipur Violence and Why Stopping It Poses a Test for
Modi’ THE WIRE (27 July 2023)
accessed 27 October 2023.
[28] The Manipur Land Revenue and Land
Reforms Act 1960.
[29] Harad T, ‘ST Status for Manipur’s
Meiteis: What Is at Stake?’ the quint (6 May 2023)
accessed 27 October 2023.
[30] Kipgen (n 26).
[31] Rathore S, ‘Navigating the
Kuki-Meitei Conflict in India’s Manipur State’ THE DIPLOMAT (1 August
2023)
[32] Manipur Violence 2023 | Why Law
& Order Is Missing? (YouTube 2023)
accessed 14 October 2023.
[33] Kalita P, ‘Over 2,000 Illegal
Immigrants from Myanmar in Manipur: Govt report’ TIMES OF INDIA (22
June 2023)
accessed 23 October 2023.
[34] Yadav D and Saha B, ‘Refugee
Camps, Border Issues: Understanding Influx of Illegal Immigrants from Myanmar
to Manipur’ INDIA TODAY (4 August 2023)
accessed 24 October 2023.
[35]Levion J, ‘Manipur Govt Intensifies
Eviction Drive against “Illegal Encroachers”’ THE INDIAN EXPRESS (13
June 2023)
[36] Hasnat K and Meitei N, ‘After Kuki
Tribal Bodies’ Call for “Shutdown” over Evictions, Manipur District Sees
Sporadic Violence’ The Print (28 April 2023)
[37] Achom D and Choudary R, ‘15,400
Acres Under Poppy Cultivation in Manipur, 2,500 Arrested In 5 Years: Sources’ NDTV
(16 May 2023)
accessed 20 October 2023.
[38] ‘Manipur
Government Continue to Eradicate Illicit Poppy Cultivation’ The Morung
Express (16 November 2023)
accessed 28 November 2023.
[39] Ohri R, ‘Manipur High Court Order
to Include Meiteis in ST List Wrong:’ The Economic Times (18 May 2023)
accessed 30 October 2023.
[40] The Wire (n 18).
[41] The Constitution, art 366.
[43] ibid.
[44] ‘Change in Criteria for Inclusion
in ST List’
accessed 20 November 2023.
[45] THE HINDU BUREAU, ‘Current
Procedure for Inclusion of Communities in Scheduled Tribes List Adequate,
Centre Tells Rajya Sabha’ (15 March 2023).
[46] ibid.
[47] The Constitution, art 19.
[48] The Indian Penal Code 1860.
[49] ‘Three
Churches Demolished in BJP-Ruled Manipur for “Illegal Construction”: Reports’ The
Wire (12 April 2023)
accessed 12 November 2023.
[50] THE INDIAN EXPRESS (n 19).
[51] The Code of Criminal Procedure
1973.
[52] Laithangbam I, ‘Mobile Internet
Blocked, Section 144 Imposed in Manipur’s Churachandpur District’ THE HINDU
(28 April 2023)
accessed 20 November 2023.
[53] The Constitution, art 19.
[54] ibid.
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[56] Rajvanshi A, ‘How Internet
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[57] Kachroo
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[58] The Constitution, art 21.
[59] The constitution, art 21A.
[60] ‘Police
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[61] Khan K, ‘Manipur Violence: What
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[62]Shekar R, ‘CBI Charges 6 for Rape
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[63] The Constitution, art 29.
[64] Karmakar
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[65]‘Heinous Acts of Violence Committed
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[66] Nair
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[67] Harad (n 29).
[68]Sharma P (n 20).
[69] Ojha S, ‘Manipur: Supreme Court
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[70] ‘Communal Violence & Riots in
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[71] Communal Violence (Prevention,
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[72] Mander H, ‘Showing the Way: On
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[73] The Constitution, art 356.
[74] The Constitution, art 355.
[75] Mehta D, ‘The Ayodhya Dispute: The
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