The Unfolding Kuki–Meitei Conflict in Manipur

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Summary

While the High Court’s directive to the Manipur government to submit its recommendation on the inclusion of the Meitei community in the Scheduled Tribe list was the immediate trigger for the violence between the Meiteis and the Kukis, anger against the Meitei-dominated state government was simmering amongst the Kuki community for quite some time. Crackdown on drug cultivation and eviction drives against illegal migrants attracted large-scale protests in the Kuki-dominated districts. The demand for a separate Kukiland has also been long-standing.

Manipur witnessed large scale ethnic violence in the first week of May 2023, in the aftermath of the ‘Tribal Solidarity March’ organised by the All Tribal Students’ Union Manipur (ATSUM) in the ten Hill Districts of Manipur on 3 May 2023. While the protest marches across the state started peacefully, a march in the Torbung area of Churachandpur district turned violent as an armed mob attacked people of the Meitei community. Many believe that Kuki militants were involved in the attack. In retaliation, the Meiteis attacked the Kukis and burnt down their property. Soon violence spread to the Kuki and Meitei dominated districts of the state. At least 70 people have been killed, 231 injured and 48,000 rendered homeless in the rioting. More than 1,700 houses, including religious places, were burnt.1

As violence spread, the Union government acted swiftly and sent in additional soldiers from the Indian Army and the Assam Rifles. Even the Indian Air Force (IAF) was pressed into service. The Ministry of Home Affairs (MHA) appointed Kudiep Singh, former Director General of the Central Reserve Police Force (CRPF) as security advisor to the Manipur government. The state government clamped curfew in the affected districts, suspended internet and shoot-at-sight orders were issued to deter violent mobs from indulging in looting and arson. While the situation was gradually brought under control, sporadic incidents of violence have also been reported subsequently.2

The ‘Tribal Solidarity March’ which triggered the current round of ethnic violence in Manipur was called on 27 April 2023 by ATSUM following a meeting of the tribal students’ organisations held on 21 April 2023 in which the students organisations felt the need to express dissent against the Meitei community’s demand for Scheduled Tribe (ST) status.3 Accordingly, they resolved to organise the marches in all hill district HQs under the theme, ‘Come Now Let Us Reason Together’.

The meeting of the tribal students organisations was called following a High Court order of 19 April 2023, wherein a single bench judge, after hearing a petition by eight people representing the Meetei Tribe Union (MTU), directed the Manipur government to submit its recommendation on the inclusion of the Meitei community in the ST list, preferably within a period four weeks.4 The order has since been stayed by the Supreme Court which termed it as a “factually wrong judgement”.5

Demand for ST Status by Meitei Community

The demand for inclusion of Meitei in the ST list by the Meitei community has existed for quite some time. The demand first came up in 1981 when the then Chief Minister of Manipur, Rishang Keishing raised the matter in the State Legislative Assembly. The discussions on the issue did not lead anywhere as there were dissenting voices within the Meitei community against getting ST status. In 1995, the Meitei community was given the status of Other Backward Class (OBC). Two groups within the Meitei community—Chakpas (previously known as lois) and Thoubal Khunous (previously Yaithibis)—were already identified as Scheduled Castes (SC) in 1956.

Nevertheless, the Meitei community intensified its demand for ST status with the formation of the Scheduled Tribes Demand Committee of Manipur Valley (STDCM). The STDCM submitted a memorandum to Governor Gurbachan Jagat in November 2012, and also met the then Prime Minister Manmohan Singh in July 2013 to reiterate their demand for a ST status. On 29 May 2013, the Union Ministry of Tribal Affairs asked the Manipur government to submit a formal recommendation along with the latest socio-economic survey and ethnographic report for the inclusion of Meitei community in the ST list. The state government, however, did not reply to the letter.6

In April 2022, the MTU once again submitted a representation to the Union Tribal Affairs Ministry to consider inclusion of Meitei community in the ST list. The Ministry, on its part, forwarded the letter to the Manipur government in May 2022.7 Once again, the state government did not respond to the letter. In 2023, Mutum Churamani and seven others of the MTU filed a writ petition in the High Court urging the Hon’ble Court to issue a writ mandamus to the Manipur government to reply to the letter of Union Ministry of Tribal Affairs.8 The High Court order was issued in response to this writ petition.

Here it is important to note that while both the Kuki and Naga communities are opposed to the demand of ST status of the Meitei community, the solidarity marchesin Naga-dominated areas remained peaceful in contrast to the Kuki-dominated areas. In fact, the Naga community has distanced itself from the violent protests and claimed that the Indigenous Tribal Leaders’ Forum (ITLF), which was involved in various violent activities, does not represent all tribespeople of Manipur.9

Reasons for the Meitei–Kuki violence

While the High Court’s directive to the Manipur government is the immediate trigger for the violence between the Meiteis and the Kukis, anger against the Meitei-dominated state government was simmering amongst the Kuki community for quite some time. The Manipur government over the past few months had taken few actions and decisions which have generated a sense of discrimination and insecurity among the Kuki community. To begin with, Chief Minister Biren Singh has been claiming that many illegal migrants from Myanmar have settled in the state, mostly in the reserved and protected forests. Such is the anxiety of illegal migrants from Myanmar that his government reportedly suspended the Free Regime Movement (FMR) with Myanmar and detained 410 ‘illegal migrants’ from Myanmar. Furthermore, the Biren Singh government also carried on with the land survey of reserve forests, protected areas, wetlands and wildlife. During the survey, the state government ‘identified’ the encroachers, and served them eviction notices.

Since some of these evictions were forcible, clashes between villagers and the forest and police officials took place. These drives against ‘illegal encroachers’ from Myanmar are interpreted by the Kukis as action against their own community because they identify the Chin refugees from Myanmar as members of their own tribe, i.e., the Chin-Kuki tribe. However, the Manipur government had claimed that of the total 291 encroachers removed from Manipur’s forests between 1 January 2017 and 18 April 2023, 160 belonged to Meitei community, which shows that the Kuki community was not exclusively targeted.10 But it appears that the Kuki community continues to remain aggrieved.

In addition, the Manipur government had also launched the ‘War on Drugs’ campaign in the state in 2017. The hills of Ukhrul, Senapati, Kangpokpi, Kamjong, Churachandpur and Tengnoupal districts were especially targeted as large-scale illegal cultivation of poppy was being carried out. The government states that of 2,518 people arrested under Narcotics Drugs and Psychotropic Substances (NDPS) Act between 2017 and 2023, only 873 were from Kuki-Chin community, while 1,083 were Muslims, 381 Meiteis and 181 from other communities. This despite the fact that Kuki-Chin community cultivated poppy in 13,121.8 acres of land and the Naga Community only in 2,340 acres.11

The forcible destruction of illicit poppy cultivation and arrests of villagers, however, is perceived by the Kuki community as depriving them of their livelihood because the ‘affected cultivators’ never received the compensation promised by the state government.12 Consequently, these drives against encroachers and illicit poppy cultivators attracted large-scale protests, especially in the Kuki-dominated districts. Many of such protests also turned violent, the most recent being the one held on 27 April 2023 in Churachandpur.13

The state government views the protests as anti-government and claims that the protesters were heavily influenced and instigated by the Kuki militant organisations especially the Kuki National Army (KNA) and Zomi Revolutionary Army (ZRA), who were not only providing shelter to illegal migrants from Myanmar, but also encouraging illegal poppy cultivation and drug trade. In fact, on 10 March 2023, the Biren Singh government decided to withdraw from the tripartite Suspension of Operations (SoO) agreement with the Kuki militant organisations. This unilateral withdrawal from the agreement has not only upset the Kuki community but also put a question mark on the resolution of the Kuki militancy problem in the state. The peace talks between the government and the militant groups, which started in 2016, had generated hopes among the Kuki community that after all their demand for a separate Kukiland will be met. This hope had, in fact, propelled them to support the BJP during the 2022 Manipur elections.

Demand for a Separate Kukiland

The Kukis have been demanding self-determination for their community since long. The earliest case where the Kukis demanded a separate state for themselves was in 1960, in the aftermath of the 1957 elections to elect village chiefs in the state. The Kuki community argued that the system of electing the village chief under the Village Authorities Act of 1956 was a means to “do away with the rights of the chiefs over land”14 , and given that the Kukis had traditional system of unelected village chieftains, they opposed it. This desire to safeguard their interests was also reinforced by the fact that the Kukis do not share a cordial relationship with the Meiteis and the Nagas.

The Kukis are resentful towards the Meiteis because they feel that the Meitei-dominated state governments kept their areas backward and did not provide them adequate political representation. Their unease with the Naga community stemmed from the demand of the National Socialist Council of Nagalim (NSCN) to include the area inhabited by the Kukis into the Greater Nagalim in 1980s. The demand for a separate state, however, became prominent following clashes with the Nagas in 1990s. Between 1992 and 1997, the Kukis were subjected to ethnic cleansing by the Naga militant groups, following which multiple Kuki armed groups demanding separate/independent Kukiland cropped up in the state.

After years of violence, 23 insurgent outfits (later increased to 25) belonging to the Kuki, Zo, Paite and Hmar groups organised themselves under two umbrella organisations—KNO (Kuki National Organisation) and UPF (United People’s Front)—and signed a SoO with the Union and the Manipur governments in August 2008.15 In 2016, eight years after signing of the SoO agreement, the Union and the State governments started peace negotiations with the KNO and UPF. Even after several rounds of talks, no headway could be made because of the difference in the demands of the KNO and the UPF. The KNO demanded a separate Kuki state while the UPF insisted on a state-within a state under Article 244A of the Indian Constitution.

At present, it appears that both the groups have reconciled their differences and have come around to accepting a Kukiland Territorial Council carved out of Kuki-inhabited districts of Churachandpur, Pherzawl, Chandel, Tengnoupal, Kangpokpi and Kamjong. The Territorial Council, according to them, should be modelled on the Bodoland Territorial Council which was established under the Sixth Schedule in 2003. In fact, the impressive win of the Hill People’s Alliance (HPA), an alliance of independent candidates backed by the UPF in Churachandpur district in 2015 Autonomous District Council elections also indicate a strong desire among the Kukis for a Kukiland Territorial Council.

The state government dominated by the Meiteis is, however, against the creation of Kukiland Territorial Council as they see it as the first step towards creation of a separate Kuki state. In fact, when 10 MLAs including seven from his own party, demanded separate administration for the Kuki community in May 2023, Biren Singh categorically rejected the proposal and asserted that “the territorial integrity of Manipur will be protected at all costs.”16

The ongoing conflict between the Meitei and Kuki communities is also a manifestation of the larger Valley-Hill divide which has bedevilled the process of peace and reconciliation in Manipur.

The Valley-Hill Divide

Manipur has two distinct geographical features—the Imphal Valley and the Hills which surround the Valley. The Valley constitutes the five districts and the Hill constitutes 10 districts.17 The Imphal Valley covers 10 per cent of the land area of Manipur and rest 90 per cent is covered by the Hills. Ethnically, Manipur has three main groups—the Meiteis, the Nagas, and the Kukis. The Meiteis constitute 53 per cent of the total population and are primarily settled in the Valley districts of East and West Imphal, Thoubal, Kakching, Bishnupur and Jiribam. The Naga (17 per cent) and Kuki communities (26 per cent) which together constitute 41 per cent of the population are categorised into 34 Scheduled Tribes in the state. The Nagas are concentrated in the North consisting mainly of Senapati, Ukhrul, Tamenglong and Chandel districts. The Kuki tribes primarily populate the southern hills comprising Churachandpur, Kangpokpi, Chandel and Tengnoupal districts.

This disproportionate spatial distribution between the Meitei community and the Tribespeople is the crux of the problem. The Meitei community feels that even though they constitute 53 per cent of the population, they are confined to only 10 per cent of the land in the valley. Even in the valley, they argue that they are getting squeezed because tribespeople are buying land and settling there, while being non-tribal, they cannot buy land in the hills because of the protection provided to the tribespeople under Article 371 (c) of the constitution. The Meitei community further claims that in addition to the tribespeople, many ‘outsiders’ including illegal migrants from Bangladesh and Myanmar and people from rest of the country are settling in their land. They, therefore, argue that if the community has to “preserve” and “save the ancestral land, tradition, culture, and language”, they need the ST status.18

The Tribal communities, as evident, are opposed to the demand of the Meitei community for ST status on the grounds that Meiteis are a dominant community in the state with 40 of the 60 legislative seats occupied by them. They further argue that Meitei language is included in the Eighth Schedule of the Constitution and they are educationally, socially and economically better off than the tribespeople. Therefore, if ST status is bestowed upon the Meiteis, they will not only corner all the government jobs and other benefits, hitherto granted to the tribes by the Constitution, but also grab land belonging to the tribespeople as restrictions on purchasing land in the hills will not apply to them.

The fear of losing their land has become so prominent among the Meitei community that they started demanding the extension of Inner Line Permit (ILP) in the state to protect the rights of Manipuri ‘indigenous’ people. Subsequently, in December 2019, the Union government extended the ILP in the state. The state government in June 2022 decided that 1961 shall be the ‘base year’ to decide who is a ‘native resident’. This government order is opposed by the tribespeople. They assert that in 1961, hardly any census official visited their villages because of poor connectivity. In addition, during that time, most of the village chiefs were illiterate and therefore did not keep records of the villagers. As a result, the tribespeople do not have the required documents to prove that they are native residents of Manipur.

The Hill-Valley divide is most evident in the administration of these two geographical entities. During the colonial times, the British deliberately introduced the ‘hill-valley divide’ by separating the administration of the hills from the plains.19 This divide was also accentuated by the religious divide between the two wherein the Meiteis embraced Vaishnavism patronised by their Kings of Manipur and the hill people were converted to Christianity by the missionaries who were allowed to function in the hill areas.20 The British policy of keeping the tribes administratively separated from the valley finally ended with lapse of British paramountcy and the enforcement of the Manipur State Constitution Act in 1947, wherein the responsibility of administering the hill areas was entrusted to the Council of Ministers. The Council of Ministers had two elected persons from the hills who were in charge of hill affairs, forests and agriculture.

Autonomous (Hill Areas) District Councils

A significant step towards the administration of the hill areas of the state was taken with the insertion of Article 371 (C) in the Constitution of India. This Article provided for the enactment of the ‘Manipur (Hill Areas) District Councils Act’ in 1971, which was enforced in 1973 after Manipur attained statehood. Under the Act, the hill areas of Manipur were divided into six Autonomous District Councils (ADCs).21 In addition to the ADCs, the Hill Area Committee (HAC) was constituted under the Manipur Legislative Assembly (Hill Areas Committee) order of 1972. The members elected from the hill areas of Manipur comprise its members, who then elect a Chairman and a Vice Chairman. The HAC is the highest body “at the legislative level to oversee the planning, implementation and monitoring of all development activities in the hill areas of the state”.22 Furthermore, as provided under Article 371(C) of the Constitution of India, the HAC also vets all laws affecting these hill districts.

The ADCs of Manipur are, however, fundamentally different from that of the ADCs in the other four north-eastern states. Firstly, the ADCs in Manipur was established by an Act of Parliament and not under the Sixth Schedule of the Constitution of India as Sixth Schedule was meant only for the Hill Districts of the undivided Assam. Secondly, unlike the ADCs under the Sixth Schedule, the ADCs of Manipur are not entrusted with judicial and legislative powers. Thirdly, the ADCs were also given limited financial powers which means that the ADCs had limited ways to raise revenue.23 Fourthly, the 17 subjects that were supposedly under the ‘control and administration’ of the district councils were not so in reality because they were subjected to exceptions and conditions imposed by the  the Administrator.24 As a consequence, the district councils were reduced to weak and ineffective executive and administrative agencies. In fact, between October 1988 and December 1990, the six ADCs were superseded and their administration was entrusted to the district officials due to continuous resistance by the tribal groups.25

Meanwhile, the tribespeople of the Manipur hill areas could see that the ADCs in the Sixth Schedule areas were much more powerful and autonomous, and, therefore the demand for extending the Sixth Schedule in Manipur as well was made. In response to these demands, the Manipur state cabinet passed three resolutions in favour of extending the Sixth Schedule to the hill areas ‘with certain local adjustments’ on 13 May 1991, 17 August 1992 and 28 March 2001.26 Despite committing to devolving greater autonomy to the ADCs, these resolutions could not be implemented because the state government failed to respond to the union government’s query as to what constituted ‘local adjustments’.27

Significantly, the National Commission to Review the Working of the Constitution in its Report of March 2002 had recommended the extension of Sixth Schedule in the hill areas of Manipur. Here, it is important to note that the demand for the extension of Sixth Schedule in the hill areas apparently does not find favour with the Naga organisations such as the United Naga Council (UNC) and the NSCN (I-M) because they view it as a hindrance in their aim of realising the goal of greater Nagalim.28

Be that as it may, in October 2008, the Manipur Legislative Assembly passed the Manipur (Hill Areas) District Councils (Third Amendment) Bill. The amendment reiterated the need to continue with the 1971 Act with necessary amendments. The amendment increased the total number of seats in the district council from 18 to 24 and provided that the elections to the districts councils shall be conducted and supervised by the State Election Commission.29 The Act also increased the number of subjects to be devolved to the ADCs from 17 to 26. The Act has been opposed on the ground that the new amendments do not provide any autonomy to the ADCs.

The tribespeople persisted with their demands for greater autonomy. In 2021, the HAC drafted the ‘Manipur (Hill Areas) Autonomous District Councils Bill, 2021’ and sent it to the state government in August 2021 for it to be tabled and enacted into legislation.30 The new Bill proposes an increase in the number of council members from 24 to 31, with the three members being nominated. It further proposes that the delimitation of the 28 constituencies be done in such a manner that three fourth of the seats are allocated according to the population and one fourth of the seats be reserved for socio-economically underdeveloped areas.31 It proposes greater autonomy and financial powers for the ADCs. The Bill also proposes creation of Hill Areas Secretariat for managing, coordinating and monitoring the working of all the ADCs.32

The drafters of the new bill argue that the proposed bill has been drafted with the twin objectives of development of the hill areas and maintaining the territorial integrity of Manipur. As expected, the valley-based civil organisations appealed to the state government to not table the bill as it contained maximum provisions for the creation of ‘Naga Autonomous Territorial Council and Kuki Autonomous Territorial Council’, to which they were opposed.33

Conclusion

Manipur is the most violence-prone state in the Northeast accounting for more than 50 per cent of the total incidents of violence in the region. Demands for greater Nagalim and separate Kukiland with overlapping territorial claims have generated tensions and distrust between the Meitei, Naga and Kuki communities. These tensions and distrust are further accentuated by the fact that successive state governments have been unsympathetic and uncaring towards the hill areas. As a result, the hill areas have remained economically underdeveloped with poor quality of life. In fact in 2021, the Manipur government ranked quite low in Good Governance Index and was judged one of the worst governed state.

If Manipur wishes to experience sustainable peace and maintain its territorial integrity, it is incumbent on all the communities to step back from their belligerent and rigid stands and work towards a compromise. In fact, it is the Meitei-dominated state government which should lead the way by agreeing to give greater autonomy to the hill tribes in administering their own affairs. The Kuki community on their part, should reconsider their demand for separate state or an autonomous territorial council because such a council will not contain contiguous Kuki-Chin-Mizo inhabited areas. In fact, this could be the cause for future ethnic clashes between communities residing in these districts. In addition, the community also has substantial intra-tribe differences and rivalries, with the 1999 Kuki–Paite clash a case in point. These differences could potentially aggravate further in future thus defeating the purpose of a separate territorial council for the community.

The state government should urgently focus on ushering in industry and service sectors-led development in the state which would provide more non-farm economic opportunities to the people of Manipur. This could potentially reduce people’s attachments to the land. Most importantly, the state government should sincerely strive towards providing an effective, transparent and inclusive governance to the people of Manipur.

Views expressed are of the author and do not necessarily reflect the views of the Manohar Parrikar IDSA or of the Government of India.

• 1. “Manipur Violence: Assam Rifles Rescues 96 People in Air Evacuation Ops from India-Myanmar Border”, The Economic Times, 15 May 2023.
• 2. Ritu Maria Johny, “Army Deployed as Fresh Violence Erupts in Manipur, Houses Set On Fire in Imphal”, Hindustan Times, 22 May 2023.
• 3. “Office Memorandum, 27 April 2023”, available at Phurailatpam Keny Devi, “Manipur: ATSUM to Hold Solidarity March on May 3 Protesting the Meiteis Demand for Inclusion in ST Category”, India Today NE, 30 April 2023.
• 4.   Bikash Singh, “Manipur High Court: Manipur HC extends time frame for the inclusion of Meitei community to ST list”, The Economic Times, 12 May 2023. 
• 5. “‘Completely Factually Wrong’: SC Slams Manipur HC Order on Meiteis and ST List”, The Wire, 17 May 2023.
• 6. “Explained: Manipur High Court’s Judgment that Triggered Violence in Manipur Over Inclusion of Meitei Community in Scheduled Tribe list”, SSC Online Blog, 6 May 2023.
• 7. “ST Demand for Meiteis Gets a Fillip Send Recommendations to Centre, Directs HC to State Govt”, The Sangai Express, 20 April 2023.
• 8. ‘Letter No.1902005/2012- C&IM dated 29.5.2013’.  The MTU also urged the High Court to restore ST status to the Meetei/Meitei Community as it existed before September 1949, i.e., before signing of the Merger Agreement. See, n. 4.
• 9. Raju Das, “Everything You Need to Know About Manipur Violence by Tribal Groups Opposing ST Status Demand by Meitei Community”, OpIndia, 4 May 2023.
• 10. Bharti Jain, “Manipur Official: No Tribal Bias in Evictions or in War on Drugs”, The Times of India, 17 May 2023.
• 11. Ibid.
• 12. For more on the consequences of the ‘War on Drugs’ campign, see Lily Sangpui and Jenny Kapngaihlian, “The Quest to End Illicit Poppy Cultivation in Manipur: Examining the War on Drugs Campaign”, Economic and Political Weekly, Vol. 56, No. 32, 7 August 2021.
• 13. “Manipur: Unrest in Churachandpur as Protests Turn Violent”, India Today NE, 28 April 2023.
• 14. Bela Bhatia, “Justice Denied to Tribals in the Hill Districts of Manipur”, Economic and Political Weekly, Vol. 45, No.31, 31 July–31 August 2010, p. 40. Also see, “Planning in the Sixth Schedule Areas and Those Areas Not Covered by Part ix and Part ix-a, 2006”, Report of the Expert Committee,  Ministry of Panchayati Raj, Government of India, September 2006.
• 15. Jimmy Leivon, “What is the SoO Agreement with Tribal Insurgent Groups that the Manipur Govt. Withdrew From?”, The Indian Express,14 March 2023.
• 16. “Manipur CM Rejects Demand for Separate Administration for Kuki Areas”, The Indian Express, 15 May 2023.
• 17. Valley districts are: East and West Imphal, Kakching, Bishnupur and Thoubal. Hill Districts are: Senapati, Kangpokpi, Ukhrul, Kamjong, Chandel, Tengnoupal, Churachandpur, Pherzawl, Noney, and Tamenglong. Jiribam district is an extension of the Cachar valley.
• 18. Tejas Harad, “ST Status for Manipur’s Meiteis: What is at Stake?”, The Quint, 6 May 2023.
• 19.   H. Kham Khan Suan, “Hills-Valley Divide as a Site of Conflict”, in Sanjib Baruah (ed.), Beyond Counter-Insurgency, Breaking the Impasse in Northeast India, Oxford University Press, New Delhi, 2009, p. 273.
• 20. Rajendra Kshetri, District Councils in Manipur, Formations & Functioning, Akansha Publishing House, Delhi, 2006, p. 5.
• 21. The autonomous districts were: Senapti, Ukhrul, Tamenglong, Chandel and Churachandpur. The district of Senapati had two councils—Senapati and Sadar Hills, and the rest had four district councils.
• 22. “Comprehensive Details about Manipur State and its Environmental & Social Sensitivities”, Government of Manipur, 2015.
• 23. Rajendra Kshetri, District Councils in Manipur, Formations & Functioning, no. 20, p. 24.
• 24. Bela Bhatia, “Justice Denied to Tribals in the Hill Districts of Manipur”, no. 14, p. 40.
• 25. “Planning in the Sixth Schedule Areas and Those Areas Not Covered by Part ix and Part ix-a, 2006”, Report of the Expert Committee, Ministry of Panchayati Raj, Government of India, September 2006.
• 26. Kham Khan Suan Hausing, “From Opposition to Acquiescence: The 2015 District Council Elections in Manipur”, Economic and Political Weekly, Vol. 50, No. 46/47, 21 November 2015, p. 80.
• 27. Bela Bhatia, “Justice Denied to Tribals in the Hill Districts of Manipur”, no. 14.
• 28. Kham Khan Suan Hausing, “From Opposition to Acquiescence: The 2015 District Council Elections in Manipur”, no. 26.
• 29. “The Manipur (Hill Areas) District Councils (Third Amendment) Act, 2008, (Manipur Act No. 7 of 2008)”, Manipur Gazette Extraordinary, 27 October 2008.
• 30. “Manipur (Hill Areas) Autonomous District Councils Bill, 2021 Introduced”, Imphal Free Press, 20 August 2021.
• 31. Ibid.
• 32. Ibid.
• 33. Jimmy Leivon, “Manipur: Civil bodies oppose Manipur (Hill Areas) Autonomous District Councils Bill 2021”, The Indian Express, 22 August 2021.