Kuki-Zo Council seeks return of President’s Rule in Manipur, says community feels ‘unsafe, excluded’
The Kuki-Zo Council issued a statement seeking the reimposition of President's Rule in Manipur, citing continuing security incidents and a lack of confidence in the current administrative arrangement.
The council stated that the community was not consulted before a high-level meeting on the state's deferred Census exercise, while 14 civil society organisations representing other communities were part of the consultation.
President's Rule was in force in Manipur from 13 February 2025 (following the resignation of the incumbent Chief Minister) until it was revoked on 4 February 2026, after which an elected government was sworn in.
Ethnic violence in Manipur, involving the Meitei and Kuki-Zo communities, has continued intermittently since May 2023, forming the backdrop to demands for renewed central intervention.
Article 356 and President's Rule
Article 356 of the Constitution empowers the President to assume the functions of a state government if satisfied, on the basis of a Governor's report or otherwise, that a situation has arisen in which the government of a state cannot be carried on in accordance with constitutional provisions. It falls under Part XVIII (Emergency Provisions), alongside Article 352 (National Emergency) and Article 360 (Financial Emergency).
Manipur's President's Rule spell of February 2025–February 2026 is one of the more recent invocations of Article 356 with an ongoing internal-security backdrop; the Kuki-Zo Council's demand for its reimposition is a request to re-trigger the same constitutional mechanism on grounds of breakdown of law and order and administrative confidence.
Judicial Review of Article 356: S.R. Bommai v. Union of India (1994)
Before 1994, Article 356 proclamations were treated as largely non-justiciable "satisfaction" of the President, leading to frequent misuse for dismissing state governments on political grounds. A nine-judge Constitution Bench of the Supreme Court changed this position.
Key Details
- S.R. Bommai v. Union of India (1994) held that a proclamation under Article 356 is subject to judicial review; courts can examine whether the satisfaction was based on relevant material and was not mala fide.
- The judgment held that a state government's majority must be tested on the floor of the Assembly, not through the Governor's subjective assessment (the "floor test" principle).
- It clarified that Article 356 must be used only as a measure of last resort, in cases of genuine breakdown of constitutional machinery, not for reasons of political expediency.
- The Sarkaria Commission (1988) had earlier recommended that Article 356 be used sparingly, "in the rarest of rare cases" — a phrase the Bommai judgment reinforced.
Any renewed invocation of Article 356 in Manipur would remain subject to these Bommai-era safeguards — it must rest on an objective breakdown of governance (such as sustained ethnic violence and administrative paralysis) rather than being a discretionary political response to a community's grievance alone.
Governor's Report and Federal Union structure
Article 355 casts a duty on the Union to protect every state against external aggression and internal disturbance, and to ensure that the government of every state is carried on in accordance with the Constitution. Articles 355 and 356 operate together: 355 is the enabling/duty provision, 356 is the remedial mechanism.
Key Details
- The Governor's report to the President is the usual trigger for an Article 356 proclamation, though the President can act "otherwise" than on a Governor's report.
- In north-eastern states with prolonged internal-security situations, invocation of Article 355/356 is often accompanied by deployment of central forces and, in some regions, special laws such as the Armed Forces (Special Powers) Act, 1958, which grants armed forces specific powers in areas declared "disturbed."
The Kuki-Zo Council's demand is effectively a call for the Union to re-exercise its Article 355 duty by invoking Article 356, on the ground that the state machinery is unable to guarantee security and inclusive governance for all communities.
- President's Rule in Manipur: imposed 13 February 2025, revoked 4 February 2026 (roughly one year).
- Article 356 proclamation: needs parliamentary approval within 2 months (simple majority); renewable every 6 months up to a 3-year outer limit (44th Amendment, 1978).
- S.R. Bommai v. Union of India, 1994 — nine-judge bench, made Article 356 proclamations justiciable and established the floor-test principle.
- Ethnic violence in Manipur, involving Meitei and Kuki-Zo communities, has recurred since May 2023.