Shortcomings of the envisaged Delimitation Exercise in Manipur

A THREE-MEMBER bench of the Hon’ble Supreme Court of India in their order dated 17-03-2025 passed in the writ petition, W.P. (C) No. 357/2022 has granted three months to the Union Government for carrying out delimitation exercise in Arunachal Pradesh, Assam, Manipur, and Nagaland. The writ petition was filed by the Delimitation Demand Committee for the states of Arunachal Pradesh, Assam, Manipur and Nagaland in Northeast India against the Union of India and Others.  The delimitation exercise is to be executed in accordance with the provisions of the Delimitation Act, 2002 and its amendment Acts viz., The Delimitation (Amendment) Act, 2003 and The Delimitation (Amendment) Act, 2008. According to Section 4 of the Delimitation Act, 2002 the Delimitation Commission ‘shall readjust the division of each State into territorial constituencies for the purpose of elections to the House of the People and to the State Legislative Assembly on the basis of the census figures as ascertained at the census held in the 2001’. 

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The 2001 census in respect of Manipur had already courted many controversies. The 2001 census was inherently defective as it had shown up abnormal population growth in some hill districts of Manipur. The office of Registrar General of India (ORGI) released two sets of data—enumerated and estimated—for the three sub-divisions (cf. Table 1). The enumerated population data showed that the three sub-divisions of Senapati (Mao-Maram, Paomata and Purul) grew at abnormally high rate of more than 120 per cent between 1991 and 2001. The growth rates of these three sub-divisions far exceeded those of the rest of Senapati and the whole of Manipur.  Later the ORGI excluded the three sub-divisions from subsequent publications before releasing estimated figures for these sub- divisions. As per the estimated figures, the population of these sub-divisions grew at the decadal rate of 39 per cent during 1991–2001. The ORGI had deflated the population size of Mao-Maram, Purul and Paomata sub-divisions for the simple reason that an increase of over 100 percent population in ten years was “impossible”. There was no field verification for this magic figure of decadal growth rate of 39 percent. The ORGI explained neither the procedure followed to arrive at the estimated figures, nor how it chose between enumerated and estimated figures. Chakpikarong, a sub-division of Chandel also showed a similarly high population growth rate (100.18%). The ORGI did not make any changes to the population size of Chakpikarong.  

Based on the enumerated census figures, the whole State of Manipur experienced a decadal population growth rate of 30.02 % between 1991 and 2001, which was significantly higher than the national average of 21.54%. The population estimates given by the ORGI were debated by various demographers and statisticians as the estimates were far above the average population growth of the State. Conventional demographic explanations, viz., in-migration and higher fertility rates, could not explain the abnormal increase. It is reported that the exorbitant increase in the population of the four sub-divisions in the hill districts was most probably due to manipulation driven by economic and political considerations.  

Table 1: Population Change and Assembly Seats in Manipur, 1991-2001

Article | The 2001 Delimitation Process in Manipur: A Detailed Analysis

Notably, a Presidential Order issued on 8^th February 2008 indefinitely deferred delimitation based on the census 2001 because it was “likely to arouse the sentiments of the different groups of people living in the State of Manipur due to their apprehension that new delimitation in many electoral constituencies may result in break-up of the delicate social equilibrium which may cause alienation among different ethnic groups.”  The order further noted that delimitation could trigger “ethnic clashes, leading to law and order problems throughout the State” and threaten “the peaceful coexistence among the communities” apart from offering “an opportunity” to various insurgent groups “to exploit the sentiments of the local people to indulge in large scale violence, in furtherance of their agenda” of disrupting “the sovereignty and territorial integrity of India”.  Prior to the issuance of the Presidential order dated 8^th February 2008 which deferred the delimitation of Manipur due to security risks, the Delimitation Commission under the chairmanship of Justice Kuldip Singh, Retired Supreme Court Judge prepared a Draft Working Table based on 2001 rectified census figures, which is reproduced below:

Table 2:  Draft Working Table prepared by the Delimitation Commission

As per the Draft Working Table shown above, the Assembly Seats of the districts of Imphal East, Imphal West and Bishnupur in the valley would be reduced by one each while, the Assembly Seats of the districts of Ukhrul, Senapati and Chandel in the hills would be enhanced by one each.

It is a proven fact that Manipur has a number of illegal migrants/refugees who have sneaked into the state from the neighbouring country Myanmar and that the populace of such refugees/ illegal immigrants are accommodated in the hill districts of Manipur.  So, it is indispensable that all the illegal migrants/refugees from Myanmar must be first identified using the mechanism of the National Register of Citizens (NRC) prepared in 1951, after the 1951 Census. It may be worthwhile to note that Manipur shares a 398 km long border with Burma (now) Myanmar. Before Manipur was merged into India on 15^th October 1949, Manipur had a Permit System for regulating entry into and exit from Manipur for all outsiders including Chin-Kuki-Zo tribes from Union of Burma. On 26 September 1950, the Ministry of Home Affairs (MHA) published a Notification whereby the ‘hill tribes, who is either a citizen of India or the Union of Burma and who is ordinarily a resident in any area within 40 km (25 miles) on either side of the India-Burma frontier’ were exempted from the carrying passport or visa while entering into India. On 18^th November 1950, the Government of Manipur published another Notification whereby the then existing Permit System for entry into and exit from Manipur was withdrawn. Again, on 20^th September 1951, the Government of India published a Notification whereby (i) Any Kuki tribe, (ii) Any Lushai tribe, and (iii) Any Naga tribe were recognized as the Scheduled Tribes of Manipur.

As the 398 km long Manipur-Burma border was virtually fenceless, there have created, since the latter part of 1950, a conducive atmosphere along the border that would favor illegal migrants/refugees from Myanmar to easily sneak into Manipur and obtain Indian citizenship using the card of ‘Scheduled Tribes’ under the patronage of tribal chiefs, just like visa on arrival.

As per the Final Electoral Rolls 2025, released by the Chief Electoral Officer, Manipur through a Press Note dated 6^th January 2025, the final Electors to Population (EP) ratio of the existing sixteen districts of Manipur is as under:

Table 3:  Electors’ Population & Electors to Population (EP) Ratio as on 1st January 2025

From Table 3, it is seen that all the districts in the valley viz., Imphal East (64.7), Imphal West (60.2), Bishnupur (65.3), Thoubal (63.6), Jiribam (62.5), Kakching (61.6)  have EP ratio values above 60 which is close to the national  EP ratio 66.76, determined on the basis of the electoral roll as on 08.02.2024. The extremely low values of EP ratio manifested by some hill districts viz., Chandel (41.5),  Ukhrul (49.7), Senapati (35.4), Kangpokpi (34.6) and Pherzawl (49.3) vividly show that the electoral rolls of these districts are faulty and call for physical verification of the entire populace of these districts so that the EP ratios of the districts may be set alright. Notably, if delimitation is carried out in Manipur on the basis of Electoral Rolls as on 1^st January 2025, the districts which will gain in terms of the new assembly constituencies might occur in the districts which have very low EP ratios. So, the hill districts of Manipur which may be most benefitted by the delimitation, in the changed scenarios, are likely Kangpokpi (34.6), Senapati (35.4) and Chandel (41.5). Interestingly, these are the districts where most of the illegal migrants/refugees from Myanmar are accommodated.

The National Register of Citizens (NRC) prepared in 1951, after the 1951 census is to be used to identify those illegal migrants/refugees who had sneaked into Manipur from Burma (now Myanmar). Those confirmed illegal migrants/refugees by NRC 1951 may be deported from the soil of Manipur using the provisions under (i) The Passport (Entry into India) Act, 1920, (ii) The Foreigners Act, 1946, and (iii) The Registration of Foreigners Act, 1939. The status of ST is entitled only to the bonafide citizens of India under the Constitution of India and not to the foreigners. Whatever Government orders issued in connection with STs are meant only for bonafide citizens of India and not for foreigners.

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The need of the hour in Manipur is to implement the National Register of Citizens (NRC) with base  year 1951 for identification of illegal migrants/refugees who have taken settlement in Manipur since the State was integrated to India in October, 1949.  Until and unless the NRC is implemented, the pending 2021 census will not correctly screen out illegal migrants/refugees residing in Manipur and any delimitation exercise in Manipur  based on faulty and incorrect census data will invite massive unrest that may create serious misunderstanding among some communities living in Manipur. Notably, following the 84th amendment to the Constitution of India in 2002, delimitation is to be done across the country after 2026, based on the first census conducted after 2026 i.e., the census 2021. In view of the inherent defects in the census 2001 data of Manipur, as already explained above, it will be in the best interest of Manipur to put on halt the envisaged delimitation exercise in Manipur till the pending 2021 census is completed.

The author is an independent researcher and may be reached at yugindrokangujam@gmail.com.

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