President's rule revoked in Manipur, Khemchand to be sworn in as new CM at 6 pm today
President Droupadi Murmu revoked President's Rule in Manipur on February 4, 2026, with immediate effect under Article 356(2) of the Constitution.
The revocation followed the successful formation of a new government by the BJP under Y. Khemchand Singh (also referred to as Yumnam Khemchand Singh), who was sworn in as Chief Minister.
President's Rule had been imposed in Manipur on February 13, 2025 — following the resignation of Chief Minister N. Biren Singh, who faced sustained criticism for the handling of the ethnic conflict between Meitei and Kuki-Zo communities that erupted in May 2023.
This was the 11th instance of President's Rule in Manipur — the highest count for any Indian state.
The revocation proclamation was issued on February 4, 2026, approximately one year after imposition.
Article 356 — President's Rule (Constitutional Emergency in States)
Article 356 of the Constitution empowers the President to assume the functions of a state government if the Governor reports (or the President is otherwise satisfied) that the constitutional machinery in the state has failed. It is popularly called "President's Rule" or "State Emergency."
Key Details
- Article 356(1): President issues a proclamation of state emergency on the basis of Governor's report or otherwise, if satisfied that state government cannot carry on in accordance with the Constitution.
- Article 356(2): The proclamation can be revoked by a subsequent Presidential proclamation at any time — revocation does not require Parliamentary approval (unlike imposition, which requires Parliamentary approval within 2 months under Article 356(3)).
- Duration: Initial proclamation lasts 2 months; can be extended by Parliament for 6 months at a time, up to a maximum of 3 years (with special conditions after 1 year — Article 356(4) and (5)).
- Article 357: During President's Rule, Parliament can confer on the President the power to make laws for the state; laws made by Parliament or President for the state continue even after revocation until repealed.
- Parliamentary approval: Both Houses must approve the proclamation within 2 months by simple majority. Unlike financial and national emergencies, no special majority is required for approval.
- Manipur's 11th President's Rule is the highest for any state — a reflection of its recurring political instability and ethnic conflict history.
The revocation on February 4, 2026, invoked Article 356(2) — the President can revoke President's Rule unilaterally without Parliament, making this constitutionally straightforward once a majority government is formed.
S.R. Bommai v. Union of India (1994) — Judicial Safeguards Against Misuse of Article 356
S.R. Bommai v. Union of India [(1994) 3 SCC 1] is the most consequential Supreme Court judgment on Article 356. A nine-judge constitutional bench held that the imposition of President's Rule is subject to judicial review and that a floor test in the Legislative Assembly is the only constitutionally valid method to determine majority.
Key Details
- Background: S.R. Bommai was Chief Minister of Karnataka when the Janata Dal government was dismissed by the Governor (1989) and President's Rule imposed, based on alleged defections — without any floor test.
- Ruling on Judicial Review: The Court held that the Presidential Proclamation under Article 356(1) is not immune from judicial review; it can be examined on grounds of mala fide exercise of power, lack of any relevant material, or irrelevant considerations.
- Floor Test Mandate: The Court categorically held that the Governor cannot decide a government's majority subjectively; only an Assembly floor test can determine it — this prevents pre-emptive imposition of President's Rule.
- Secularism: The Court held that a state government acting against constitutional values (including secularism) can be dismissed — but the bar is high and judicial review remains available.
- Impact: The judgment effectively curtailed the arbitrary use of Article 356 by the Centre. Between 1950 and 1994, President's Rule was imposed over 90 times; incidence fell sharply after the Bommai judgment.
- A related protective mechanism: if a no-confidence motion is pending in a state assembly, the Governor cannot recommend President's Rule until the motion is decided on the floor.
The Manipur floor test (conducted on February 6, 2026, after the new government was formed) directly follows the Bommai precedent — the floor of the House, not the Governor's subjective assessment, is the constitutional test of majority.
Tenth Schedule — Anti-Defection Law and Legislative Stability
The formation of the Manipur government involved coalition dynamics and the role of Kuki-Zo MLAs — making the Tenth Schedule (Anti-Defection Law) relevant as a static concept.
Key Details
- Tenth Schedule: Inserted by the 52nd Constitutional Amendment Act, 1985 — provides for disqualification of members of Parliament and state legislatures on grounds of defection.
- Disqualification triggers: (a) Voluntarily giving up party membership; (b) Voting contrary to party directions without prior permission; (c) Abstaining from voting against party direction.
- Exception (Para 4): A merger of at least two-thirds of the legislative party with another party does not attract disqualification.
- Decision-maker: The Speaker (or Chairman) of the House decides disqualification — this decision is subject to judicial review (Kihoto Hollohan v. Zachillhu, 1992).
- Relevance to Manipur: The Kuki-Zo community demanded a separate Union Territory — some Kuki-Zo MLAs joined the new government despite a "Lungthu Resolution" of their political body opposing participation. The Tenth Schedule is relevant where MLAs vote against party/community mandates.
- The Kuki-Zo Council threatened a social boycott of MLAs who joined the government, raising questions about the interplay between community mandates and constitutional obligations of elected representatives.
The floor test passed with the absence of Kuki-Zo MLAs from the House physically — raising constitutional questions about the nature of "participation" in parliamentary proceedings and the limits of community boycotts on elected legislators' constitutional duties.
- President's Rule in Manipur imposed: February 13, 2025; revoked: February 4, 2026
- Constitutional basis: Article 356 (imposition), Article 356(2) (revocation)
- New Chief Minister: Y. Khemchand Singh (BJP); sworn in February 4, 2026
- Manipur has had President's Rule 11 times — highest for any Indian state
- Ethnic conflict background: Meitei-Kuki-Zo violence began May 2023; over 200 deaths reported
- S.R. Bommai v. Union of India (1994) — 9-judge bench — landmark judgment on Article 356
- 52nd Amendment Act, 1985 — inserted Tenth Schedule (Anti-Defection Law)
- Maximum duration of President's Rule: 3 years (requires Parliament approval every 6 months after initial 2 months; after 1 year, special conditions under Articles 356(4) and 356(5) apply)
- Article 356(3): Both Houses must approve proclamation within 2 months by simple majority
- Article 357: Laws made during President's Rule continue until repealed even after revocation
- Kuki-Zo community demand: separate Union Territory with legislature (UT-L status)
- Floor test conducted: February 6, 2026 — government passed; Kuki-Zo MLAs not physically present