Supreme Court expresses shock over deaths in relief camps in Manipur, asks Chief Secretary to respond
The Supreme Court expressed concern over reports of unnatural deaths of internally displaced persons (IDPs) in relief camps in Manipur and directed the state's Chief Secretary to file a detailed affidavit explaining the deaths and the disparity in compensation paid to victims' families.
The Bench directed the Manipur State Legal Services Authority (MSLSA) to ensure First Information Reports (FIRs) are registered and investigated expeditiously for every unnatural death recorded in relief camps, and to file a separate status report.
The directions followed reports submitted by a court-appointed oversight committee and an IAS officer, flagging that adequate follow-up action had not been taken on earlier findings relating to deaths in the camps.
The Bench also directed that the safety and dignity of IDPs continuing to live in relief camps be ensured.
Continuing Mandamus and Article 142
A "continuing mandamus" is a judicial technique where a court keeps a matter open and issues periodic directions, monitoring compliance over time, rather than disposing of the case after a single order — used in public interest matters involving systemic institutional failure. Article 142 separately empowers the Supreme Court to pass any order necessary for "complete justice" in a matter pending before it.
Key Details
- The continuing mandamus technique is associated with cases such as Vineet Narain v. Union of India (1997), on CBI functional autonomy
- Article 142 has been used by the Court to appoint and empower court-monitored committees in matters of humanitarian or institutional breakdown
- The Manipur relief-camp matter forms part of an ongoing writ proceeding on the 2023 ethnic violence, in which the Supreme Court earlier constituted a committee of retired judges to oversee relief and rehabilitation
Directing the Chief Secretary and the MSLSA to file fresh reports, rather than issuing a final order, is an exercise of continuing supervisory jurisdiction over the state's rehabilitation response.
Legal Services Authorities Act, 1987 and Article 39A
Article 39A, inserted by the 42nd Constitutional Amendment (1976) as a Directive Principle, requires the State to ensure equal justice and provide free legal aid so that opportunities for securing justice are not denied due to economic or other disabilities. The Legal Services Authorities Act, 1987 (in force since 9 November 1995) operationalises this through a tiered network — the National Legal Services Authority (NALSA) at the apex, with a State Legal Services Authority (SLSA) in every state, District Legal Services Authorities, and Taluk Legal Services Committees below it.
Key Details
- Each SLSA is headed, ex officio, by the Chief Justice of the concerned High Court as Patron-in-Chief, with a serving or retired judge as Executive Chairman
- Core statutory functions include providing free legal aid and organising Lok Adalats; courts have also used the SLSA network as an implementing arm for access-to-justice directions in specific cases
- NALSA sits at the top of the four-tier structure created under the Act
The Court used the Manipur SLSA as the on-ground institutional mechanism to secure FIR registration and investigation for IDP deaths, illustrating how the Legal Services Authorities network can be deployed beyond routine legal aid to enforce access to justice for a vulnerable population.
Article 21 — Right to Life and Dignity, and the Status of Internally Displaced Persons
Article 21 guarantees protection of life and personal liberty, judicially expanded since Maneka Gandhi v. Union of India (1978) to include the right to live with human dignity — extended by courts to cover adequate shelter, health, and safety, including for persons in state-run relief camps.
Key Details
- India has no dedicated national statute on internal displacement; the UN Guiding Principles on Internal Displacement (1998) are the reference international framework, but are non-binding
- In the absence of binding domestic legislation specific to IDPs, courts have relied on Article 21 and public interest litigation to enforce welfare and safety standards in relief camps
- Compensation disparity among similarly placed victims can itself raise Article 14 (equality) concerns alongside Article 21
The Court's scrutiny of unnatural deaths and compensation disparities in Manipur's relief camps functions, in substance, as an Article 21 enforcement exercise for a displaced population that lacks a dedicated statutory protection framework in India.
- Reported unnatural deaths of IDPs in Manipur relief camps under court scrutiny: figures cited across reports and affidavits range from about 25 to over 30
- Court-appointed committee overseeing Manipur relief and rehabilitation: constituted in August 2023, following the 2023 ethnic violence, and headed by a former High Court Chief Justice
- Legal Services Authorities Act in force since: 9 November 1995
- Article 39A inserted by: the 42nd Constitutional Amendment, 1976
- Institutional authorities directed to report: the Manipur Chief Secretary and the Manipur State Legal Services Authority