Reclaiming Governance in Manipur: Supreme Court’s Delimitation Directive as a Political Lifeline

The Supreme Court's directive to complete the delimitation process in Manipur and three other Northeastern states represents a fragile straw for legislators to cling to in the turbulent political waters. It offers a golden chance, an opportunity to restore a popular government, a necessity since President's Rule was imposed in the state on February 13, 2025.

The Court’s order to finalize the delimitation exercise in Manipur within three months constitutes a critical juncture for the state’s political and administrative framework. Far beyond a mere reorganisation of constituency boundaries, this directive presents an opportunity to bring back the missing governance in a region marked by ethnic diversity, demographic flux, and political instability. For Manipur’s legislators—spanning the ruling Bharatiya Janata Party (BJP), its dissenting factions, and the opposition—this moment demands unity and foresight. Failure to seize this opportunity may precipitate the indefinite imposition of President’s Rule!

Though the Delimitation Commission retains the legal authority to operate under President’s Rule, the presence of an elected government is widely regarded as vital for both pragmatic and democratic reasons. Such a government offers localized expertise, political legitimacy, and an acute awareness of Manipur’s intricate ethnic, geographic, and demographic factors. This is particularly salient given the ethnic tensions between Meitei and Kuki communities, which, since May 2023, have displaced over 70,000 people and claimed more than 250 lives.

The “Suspended Animation” phase in the Presidential rule, which was imposed in the early parts of February 2025, has shown a mix of achievements and challenges.  It has achieved measurable successes in weapon recovery, bunker destruction, and arrests, particularly in the valley, but its effectiveness wanes in the hills, where law enforcement struggles to impose order, free movement falters, and missing persons cases linger.

Amidst the ongoing turmoil in Manipur, the "double engine sarkar" has encountered an unexpected impasse, placing BJP legislators in a precarious position. Many MLAs are expressing concerns about the potential loss of their seats should elections be held at this juncture. With their five-year terms nearing completion, two years have been overshadowed by the conflict. Some legislators fear they have grown disconnected from their constituents. Furthermore, the imposition of President's Rule in the state, following the resignation of N. Biren Singh as Chief Minister, has left several legislators deeply disheartened.

On March 17, the Supreme Court issued a landmark directive, granting the central government a three-month deadline to execute the long-awaited delimitation exercise. This ruling followed a plea by the "Delimitation Demand Committee for the State of Arunachal Pradesh, Assam, Manipur & Nagaland in North East India," which called for the immediate implementation of delimitation in these states. Advocate G. Gangmei, representing the petitioners, underscored that the President's 2020 order rendered the delimitation process a binding legal obligation.

The Supreme Court's directive to complete the Delimitation exercise in Manipur stands as their sole opportunity to regain control of the government. While legislators have limited involvement in the Delimitation process, which can also be carried out under the President's Rule, this is a pivotal moment for the 50 MLAs—both from the ruling and opposition parties—to reclaim their influence. Even among those 10 Kuki MLAs, some may be keen to join the government, as their tenure since being elected in 2022 has offered little time to serve their constituents.

Following their efforts to secure the position of Chief Minister, BJP legislators now appear to have recognized the repercussions of their actions. Recent developments within the party indicate potential shifts in alignment. The solidarity exhibited by 18 rebel BJP MLAs during the closing ceremony of the Yaoshang Sports event in Wangkhei, Imphal East—under the leadership of Thokchom Satyabrata Singh, Yumnam Khemchand Singh, and Thokchom Radheshyam Singh—represents a significant political maneuver, signaling a No Confidence Motion against the faction led by former Chief Minister N Biren Singh, Thongam Biswajit Singh, and Konthoujam Govindas Singh. While internal contests for leadership roles may be undermined by the BJP high command's centralized decision-making authority, a unified and strategically sound approach could bolster their case for the prompt reinstatement of an elected government.

The Meitei legislators, in particular, must reflect upon the history of their forefathers. It was the internal struggle for the throne of Manipur that forced King Marjit and Chourjit to flee for their lives when the Burmese usurped the throne and installed a puppet king, much to their dismay. Their unquenchable thirst for power plunged the people into profound suffering, a period historically remembered as the Seven Years' Devastation. Similarly, the current power-driven legislators must prioritize the welfare of the people above personal ambitions, embracing sacrifice and compromise. After all, who would favour autocratic rule while living in a democracy?

The present moment marks an important crossroads for all legislators, encompassing the ruling party, rebel factions, the separatist Kuki group, and the opposition MLAs. It presents a rare opportunity to transcend political divisions and collectively reclaim governance. Failure to seize this moment risks the prolonged imposition of President's Rule beyond March, a development that would erode the state's autonomy and jeopardize the political prospects of some MLAs in the valley. With fresh elections in 2026 or 2027 looming, many legislators face the potential loss of their seats, thus making delimitation a critical lifeline in their increasingly fragile political careers.

The BJP high command has retained exclusive authority over leadership appointments, selecting individuals deemed most capable of serving both the party and the state. Legislators must, therefore acknowledge the futility of lobbying for leadership roles and instead channel their efforts toward demonstrating unity. At this moment, presenting a cohesive front, BJP MLAs can effectively persuade the central leadership in Delhi of the urgent necessity to restore a popular government, thereby facilitating the delimitation exercise and safeguarding their political future.

For Manipur, the 2025 delimitation exercise is unlikely to introduce significant changes compared to Assam's 2023 delimitation, apart from a possible increase in Scheduled Caste (SC) and Scheduled Tribe (ST) reserved seats. While Assam's delimitation relied on the 2001 Census as its population base year, Manipur's process is expected to utilize either the 2001 or 2011 Census data, which has been protested by several organisations due to anomalies in the data.

Manipur's administrative and demographic record has undergone a substantial transformation since its last delimitation exercise in 1973, which was based on the 1971 Census. Over the decades, the number of districts has grown from nine to sixteen, reflecting shifts in population distribution and addressing ethnic and administrative demands. However, these changes have yet to be reflected in the state's electoral map, leaving Assembly constituencies tethered to outdated boundaries that fail to align with current demographic and geographic realities.

The delimitation exercise, if executed effectively, could redefine the balance of power and representation in Manipur's legislative framework. The delimitation process in Manipur faces significant challenges, as its effectiveness hinges on the finalization of district boundaries—a task yet to be completed. Speculation suggests that the state could see an increase to approximately 70 to 75 Assembly seats in the future. Newly created districts such as Jiribam, Kakching, Tengnoupal, Noney, Kangpokpi, Kamjong, and Pherzawl are anticipated to gain additional Assembly seats as part of this potential expansion.

The protests demanding the rollback of newly created districts further complicate the situation. Without redrawn boundaries, the delimitation process risks perpetuating existing disparities. Resolving these issues requires the presence of a popular government capable of addressing grievances and ensuring equitable representation. The absence of such a government not only delays critical decisions but also undermines the democratic framework necessary for fair and effective governance. This necessitates the urgency of restoring an elected administration to manage these complex challenges and deliver judicious outcomes.

The delimitation process is fundamentally an objective to ensure equitable representation, grounded in the democratic precept of equal electoral weight— “one person, one vote.” In Manipur, however, its execution is complicated by historical and socio-political factors. The state’s electoral boundaries, last delineated in 1973 using the 1971 Census, fail to reflect contemporary realities. Many argued that the tribal-majority hill regions, encompassing 90 percent of the state’s territory, retain only 20 of the 60 assembly seats, while the Meitei-dominated Imphal Valley holds 40.

Currently, Manipur designates 19 ST-reserved seats, encompassing all hill Assembly Constituencies except Kangpokpi AC, and one SC-reserved seat, Sekmai AC, out of its total 60 Assembly seats. However, the 19:40 distribution of seats between tribal and non-tribal populations in the Manipur Legislative Assembly, as determined by the Delimitation Commission in 1973 based on the 1971 Census, was a carefully calculated allocation that accurately reflected the state’s demographic and geographic composition at the time. According to the 1971 Census, Manipur had a population of 1,072,753, with Scheduled Tribes (ST) constituting approximately 31 percent (332,553) and non-STs, predominantly the Meiteis residing in the valley, comprising 69 percent (740,200).

The Manipur Assembly’s 60 seats alignment, mandated under Article 332 of the Constitution to ensure proportional representation "as nearly as may be," highlights the fairness of the delimitation process, particularly as it expanded tribal representation from 10 to 20 hill constituencies after Manipur attained statehood in 1972, effectively doubling tribal political participation while preserving the valley’s majority with 40 seats.

The 1973 delimitation’s rationale is further substantiated by its equitable approach to Manipur’s pronounced hill-valley dichotomy. The valley, home to 69 percent of the population condensed within 10 percent of the state’s land area (740,200 individuals, averaging approximately 18,505 people per seat), was allocated 40 seats, reflecting its dense, non-tribal majority. Conversely, the hills, which encompass 90 percent of the land and house 31 percent of the population (332,553 individuals, averaging approximately 16,628 people per seat), received 20 seats, 19 of which were reserved for STs, thereby ensuring adequate tribal representation in less densely populated constituencies.

The complexities of representation are further illustrated by the arrangement securing a reserved parliamentary seat for Scheduled Tribes (ST). The incorporation of 1,20,185 non-tribal Meitei voters from Thoubal, Kakching, Bishnupur, and Jiribam into the Outer Manipur constituency increased its electorate from 1,80,641 to 3,00,826, a measure necessary to preserve Manipur’s dual parliamentary representation. Nonetheless, smaller hill communities—such as the Aimol, Kom, and Tarao—remain politically marginalized, while non-tribal voters in ST-reserved constituencies and others in areas like Tengnoupal and Sekmai are denied full electoral participation. Rectifying these inequities requires a meticulous and inclusive approach.

Central to the integrity of the delimitation process is the implementation of the National Register of Citizens (NRC). Manipur’s proximity to Myanmar and Bangladesh has long raised concerns about unregulated immigration, a matter exacerbated by porous borders. Official census data reveal extraordinary population increases in the hill districts—153.3 percent between 1971 and 2001, and 250.9 percent from 2001 to 2011—far exceeding India’s national growth rates of 87.67 percent and 120 percent over the same periods. The 2021 military coup in Myanmar further intensified this trend, driving an influx of Kuki-Chin refugees and prompting former Chief Minister N Biren Singh to note the “sudden emergence of new villages.” These demographic shifts pose a profound threat to the indigenous populations—whether Meitei, Naga, or Kuki—whose political influence risks dilution by non-citizen residents.

Over the years, several NGOs, political think tanks, and tribal leaders have voiced dissent, attributing the disproportionate number of seats held by the Meitei community compared to the tribal population to discrepancies in census data from 2001 and 2011. Questions have been raised regarding how a particular community's decadal growth could surge to 41 percent in the 2011 Census, while the growth rate of other communities declined from 69 percent to 59 percent. There were no reports of mass deaths or significant migration to other states during this period. The theory of illegal immigration from Myanmar has been posited as the primary explanation for the abnormal population increase among tribals in certain districts, allegedly aimed at enhancing their electoral representation.

The population growth observed in several hill districts of Manipur between the 2001 and 2011 censuses has brought to light significant anomalies, prompting considerable debate regarding their implications. According to the 2001 Census, Manipur's population stood at 2.17 million, with Scheduled Tribes constituting 34.2 percent (741,141), predominantly residing in hill districts such as Churachandpur, Ukhrul, and Senapati. By 2011, the population had risen to 2.86 million, with the ST proportion increasing to 40.9 percent (1,167,422), reflecting an overall decadal growth of 24.5 percent.

The hill districts experienced disproportionately high growth rates: Churachandpur’s population increased from 227,905 to 274,143 (20.3 percent), Ukhrul's from 140,778 to 183,998 (30.7 percent), and Senapati's from 283,621 to an extraordinary 479,148 (68.9 percent). Senapati's growth, far surpassing the state average, has been identified as an anomaly, potentially attributable to factors such as migration, undercounting in 2001, or administrative boundary modifications. There are also allegations of political manipulation aimed at inflating tribal population figures to strengthen tribal representation.

Given these discrepancies and the possibility of inflated data, achieving a fair and accurate delimitation process in Manipur appears unlikely in its current state. Addressing these inconsistencies would require extensive analysis and time, making it impractical to accomplish within the Supreme Court’s three-month deadline. This raises concerns about the equitable representation through pro rata distribution of seats and integrity of the forthcoming delimitation exercise.

Therefore, several stakeholders have voiced their support for the National Register of Citizens (NRC) which is an indispensable safeguard to ensure that electoral boundaries reflect the will of legitimate citizens. Absent this measure, delimitation based on inflated population figures could disproportionately favour regions with higher immigrant concentrations, thereby disenfranchising indigenous people of Manipur.

Even during the 2019 Electoral Verification Programme, the identification of 67,844 fraudulent voters—including 24,636 from a single district—highlighted the widespread prevalence of electoral irregularities. Comprehensive verification, as advocated by former Chief Minister N. Biren Singh, through cross-referencing records and conducting field assessments, remains essential to protecting legitimate voter rights while eliminating unlawful entries. Moreover, the Election Commission's initiative to link Aadhaar with Electoral Photo Identity Cards requires active legislative involvement—an endeavor rendered impractical under President's Rule.

A significant number of tribal voters from Churachandpur, Kangpokpi, and Tengnoupal, residing in the Valley areas such as Langol Game Village and New Checkon, reportedly possess dual voter registrations. This enables them to cast votes both in the Valley and in the Hill Assembly Constituencies, a practice that has persisted for several years in Manipur. The Election Commission of India's directive to link voter cards with Aadhaar is the only viable solution to eliminate such fraudulent entries. However, this process requires the active involvement of elected representatives to identify and remove bogus voters from their respective constituencies. Consequently, the establishment of a functioning government is imperative to facilitate this critical exercise in Manipur.

Historically, delimitation exercises following the 1951, 1961, 1971, and 2001 censuses benefited from state-level coordination, a precedent that underscores the value of local governance. The aborted 2007 delimitation effort, hindered by irregularities in the 2001 Census, proposed adding one assembly constituency each to Senapati, Ukhrul, and Chandel, while reducing one each in Imphal East, Imphal West, and Bishnupur. Since then, the creation of seven new districts in 2016 has rendered these projections obsolete, necessitating a process informed by the latest administrative structure and census data. The Supreme Court’s three-month timeline, however, raises legitimate concerns about the feasibility of conducting thorough groundwork, risking a superficial approach that could exacerbate existing disparities.

The delimitation process in Manipur transcends technical adjustment; it is a profoundly political undertaking that requires meticulous preparation, transparency, and public confidence. Essential prerequisites—such as the NRC, voter verification, and inter-community dialogue—cannot be adequately addressed within a compressed timeframe. An elected government is best positioned to execute these tasks, oversee post-delimitation implementation, and maintain stability during the transition. In contrast, prolonged President’s Rule—invoked 11 times in Manipur’s history—relies solely on bureaucratic and security mechanisms, ill-suited to manage the socio-political nuances of this exercise.

Manipur finds itself at a critical juncture. The Supreme Court’s directive offers a chance to fortify democratic representation, but its success hinges on the restoration of an elected government and a deliberate, inclusive approach. Addressing political marginalization, securing the electoral rolls through the NRC, and navigating ethnic complexities are imperatives that demand more than haste—they require statesmanship. A failure to rise to this occasion risks undermining the principles of equity and democracy that delimitation seeks to uphold, with far-reaching consequences for Manipur’s stability and governance.

Politicians must abandon their divisive groupism, embrace collective responsibility, and work steadfastly to ensure that this Delimitation fortifies the unity of Manipur’s polity, rather than weakening its foundations.