THE DELIMITATION & NRC ISSUES IN MANIPUR (PUBLISHED)

Disclaimer: The views expressed in this article are the Author’s personal views.

This Article was first published in The Sangai Express in three parts on February 20, 21 & 22, 2023.

This is the updated version. 

This Article was published again in two parts in The Sangai Express on April 24 & 25, 2025.

 

THE DELIMITATION & NRC ISSUES IN MANIPUR

AUTHOR:

K. TIMOTHY ZIMIK, IRS

PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX (RETIRED),

MINISTRY OF FINANCE (REVENUE), GOVERNMENT OF INDIA

 

INTRODUCTION

The hill people of Manipur have been raising their voices to get their legitimate right of equitable representation in the Legislative Assembly of Manipur. But their voices have not been heard. The strong opposition to the delimitation exercise based on 2001 census by the political parties including the Congress and the BJP and the Imphal based civil society organizations has led to the denial of fundamental right to equality provided under Article 14 of the Constitution of India to the hill districts of Manipur.

2. The state of Manipur has a total geographical area of 22,327 square kilometres. The Imphal valley has a total area of 2,238 square kilometres comprising the four districts of Imphal East, Imphal West, Bishnupur and Thoubal and is occupied mainly by the Meitei community, whereas the remaining 20,089 square kilometres comprising the five hill districts of Churachandpur, Ukhrul, Tamenglong, Chandel and Senapati are occupied mainly by the Naga and Kuki-Zo tribes.

 

DELIMITATION BASED ON CENSUS 2001 AND GEOGRAPHICAL AREA

3. As per the census of 2001, the total population of Manipur is 22,93,896. Out of this, the four Imphal valley districts have population of 14,11,766 which comes to 61.54% and the hill districts of Manipur have a population of 8,82,130 which works out to 38.46%. There are 60 legislative assembly constituencies (seats) in Manipur – 40 seats for Imphal valley and 20 seats for the hill areas. The scheduled caste population is mainly concentrated in the districts of Thoubal, Imphal East and Imphal West having one reserved seat. The district wise break-up of population of the state is given in table forms as under:

 

IMPHAL VALLEY

District wise population as per Census 2001

Name of District	Number of existing Assembly Constituencies (seats)	Total population of District	Average Population per Assembly Constituency
Imphal West	13	444382	34183
Imphal East	11	394876	35898
Thoubal	10	364140	36414
Bishnupur	6	208368	34728
	40	14,11,766	35,294

 

HILL AREAS

District wise population as per Census 2001

Name of District	Number of existing Assembly Constituencies (seats)	Total population of District	Average Population per Assembly Constituency
Senapati	6	283621	47270
Churachandpur	6	227905	37984
Ukhrul	3	140778	46926
Chandel	2	118327	59164
Tamenglong	3	111499	37166
	20	8,82,130	44,107

 

 

4. From the above tables, it is seen that the average population per assembly constituency of the Imphal valley is 35,294 whereas the average population per assembly constituency of hill areas is 44,107. The above tables demonstrate that the Imphal valley is over-represented, whereas some hill districts are under-represented in the Manipur legislative assembly. Further, the average area per assembly constituency of the Imphal valley is 56 square kilometres, whereas the hill areas have 1004 square kilometres per assembly constituency. Chandel and Ukhrul districts have 1657 sq. kms. and 1515 sq. kms. average area per assembly constituency respectively. The huge geographical size of the hill areas, physical continuity, extreme remoteness of villages, marginalization hill people, closeness to the unregulated porous international border, and difficult mountainous terrains should also be taken into account for redrawing and re-adjustment of legislative assembly constituencies to ensure that the hill tribes of Manipur are proportionately represented in the Manipur Legislative Assembly. While finalizing the delimitation process in J & K, the Election Commission has taken into account the population, “constituencies’ practicality, geographical compatibility, topography, physical features, and means of communication available”

5. The average population of the entire state of Manipur per assembly constituency is 38,232. As indicated above, the Imphal valley has 61.5% of the state population having 40 assembly seats. But this works out to 66.7% of the total assembly seats of the state. Whereas the hill areas have 38.5% of the state population, but they have only 20 seats which works out to 33.3% of the total assembly seats. Therefore, the 61.5% of the valley population should have only 37 assembly seats and the 38.5% of the hill population must have at least 23 assembly seats.

6. If we do this exercise, the revised average population per constituency of hill areas comes to 38,353 ( 8,82,130 ÷ 23 ) as against the revised average population of 38,156 ( 14,11,766 ÷ 37 ) per constituency in the case of the valley. This tallies with the above-mentioned average population of 38,232 of Manipur per constituency. Thus, if the redrawing and re-adjustment of constituencies in Manipur is done on the basis of 2001 census, then the hill districts should have at least 23 legislative assembly seats instead of the existing 20 seats.

7. The above discussions show that the assembly seats of Ukhrul, Chandel and Senapati districts should increase by one assembly seat each. Let us take the case of Chandel district for illustration purpose. The average population per assembly constituency of Chandel district is 59,164 whereas the average population per assembly constituency of Imphal valley is 35,294. The difference per assembly constituency between the Chandel district and the Imphal valley is 23,870 (59,164 – 35,294). The Chandel district has two assembly seats. Thus, the excess population available for one additional seat works out to 47,740 (23,870 x 2) in the case of Chandel.

 

The details of three districts as compared to Imphal valley districts are as under:

Name of the district	Chandel, Ukhrul, Senapati average population per assembly constituency less Imphal valley average population per assembly constituency.	Excess population (Difference × No. of assembly seats)
Chandel (2 seats)	59164 – 35294	23870 x 2 = 47,740
Ukhrul   (3 seats)	46926 - 35294	11632 x 3 = 34,896
Senapati (6 seats)	47270 - 35294	11976 x 6 = 71,856

The excess population available for three or four additional seats = 1,54,492

The above tables demonstrate that the three districts of Chandel, Ukhrul, and Senapati are under-represented in the Manipur legislative assembly for the last three decades.

 

EXCLUSION OF MAO-MARAM, PAOMATA & PURUL POPULATION FROM 2001 CENSUS

8. The official 2001 census record shows that the population of Mao-Maram, Paomata & Purul sub-divisions of Senapati district was as under:

Sub-divisions of Senapati	Population (1991)	Original Census Figure	Adjusted Figure (included in the 2001 Census on estimate basis)	Original Decadal growth (%)	Adjusted Decadal Growth (%)
Mao-Maram	49,676	1,20,778	69,131	143.12	39.16
Paomata	19,448	43,299	27,065	122.63	39.16
Purul	22,213	59,705	30,912	168.78	39.16
	Total	2,23,778	1,27,108

 

9. Out of total population of 2,23,778 of these three sub-divisions, the Registrar General of India included the population of 1,27,108 in the 2001 census on estimate basis (39.16%). Thus, the population of 96,670 ( 2,23,778 – 1,27,08 ) from Mao-Maram, Paomata & Purul sub-divisions of Senapati district was excluded from the 2001 census. This means that, due to this exclusion of 96,670 population from the 2001 census, Senapati district will lose at least two assembly seats. Since the Census Authority had excluded this figure of 96,670 in its census of 2001, there is no way to revise the said census at this stage. But the complaint against the abnormal growth in these sub-divisions had been dealt with by the concerned authority.

10. The other three sub-divisions of Senapati district ( inhabited by the Kukis, Nepalis and Nagas ) had a population of 1,56,513 = Sadar Hills West (60,945) + Sadar Hills East (51,438) + Saitu Gamphazol (44,130). In the 2001 census, the Census Authority finally recorded the adjusted population of Senapati district at 2,83,621 having 6 assembly seats. If a comparison is made, the Bishnupur district having only a population of 2,08,368 has the same number of 6 assembly seats.

 

RESISTANCE TO DELIMITATION EXERCISE BASED ON 2001 CENSUS

11. All the major political parties and the Imphal valley-based civil social organizations have strongly opposed the delimitation exercise based on the 2001 census with the argument that the 2001 census figures are erroneous as there is abnormal population growth in nine sub-divisions of hill districts. The Census Authority of India had officially notified the census 2001 after adjusting the population figures of Mao-Maram, Paomata and Purul sub-divisions of Senapati districts. There were some routine rectifications carried out in other sub-divisions, but no major adjustments. Based on the 2001 census, the state of Manipur headed by these Imphal based leaders has been conducting its business and administration for years without any complaint from any quarter. While receiving the revenues and funds from the Centre, these political parties and CSOs have not opposed the census of 2001.

12. Further, based on the population census of 2001, the Government of India and the Government of Manipur had conducted parliamentary, assembly, district council and local civic elections peacefully without difficulties. It is only when the delimitation exercise to be carried out based on the population census of 2001 that the above-named parties have raised hue and cry against it. Due to the stiff opposition against the use of 2001 census, the delimitation exercise based on 2001 census has not been carried out in Manipur.

13. The 2011 census is the latest census available. No census is undertaken for 2021 due to Covid-19 pandemic. If we consider the latest census of 2011 for delimitation purpose the result will be as follows:

 

As per the office of the Registrar General of India 2011 census and Economic Survey Manipur-2014-15, the total population of Manipur is 28,55,794 including the population of Mao-Maram, Paomata and Purul sub-divisions of Senapati district. Out of this, the Imphal valley has a population of 16,33,672 (57.20%) and the hill areas have the population of 12,22,122 (42.80%). The average population per assembly constituency of Imphal valley is 40,842 whereas in the case of hill districts, it comes to 61,106. If delimitation exercise is carried out on the basis of census 2011, the hill districts Ukhrul (1), Chandel (1) and Senapati (4) should get at least 6 additional assembly seats. The additional seats to hill districts have emerged from the officially recorded census documents.

 

14. The examination of the tables below shows that some districts are clearly under-represented in the Manipur legislative assembly.

IMPHAL VALLEY

District wise population as per Census 2011

Name of District	Number of existing Assembly Constituencies (seats)	Total population of District	Average Population per Assembly Constituency
Imphal West	13	517992	39846
Imphal East	11	456113	41465
Thoubal	10	422168	42217
Bishnupur	6	237399	39567
	40	16,33,672	40,842

 

HILL AREAS

District wise population as per Census 2011

Name of District	Number of existing Assembly Constituencies (seats)	Total population of District	Average Population per Assembly Constituency
Senapati	6	479148	79858
Churachandpur	6	274143	45691
Ukhrul	3	183998	61333
Chandel	2	144182	72091
Tamenglong	3	140651	46884
	20	12,22,122	61,106

 

15. The Government of India had completed the delimitation exercise (based on 2011 census as per the J&K Reorganization Act, 2019) in the case of Jammu and Kashmir but the states of Manipur, Assam, Nagaland and Arunachal Pradesh had been omitted from the purview of the Delimitation Commission vide the Notification dated 30/03/2021. Vide the Office memorandum dated 19th July, 2022, the Government of India decided to initiate delimitation exercise in the states of Assam and Manipur based on 2001. Following such instructions, the Election Commission of India (ECI) has completed the delimitation exercise of parliamentary and assembly constituencies of Assam as per Section 8A of Representation of the People Act, 1950 and 2001 census figures are used for this purpose. In Assam, there are multiple unresolved problems such as controversial NRC exercise, illegal immigration issue, etc. and yet, the ECI has initiated and completed the delimitation exercise in Assam. However, the Centre had abandoned the delimitation exercise in Manipur due to the stiff opposition against the use of 2001 census.

REASONS FOR INCREASE OF POPULATION OF HILL AREAS

17. There are some reasons for the increase of population in some sub-divisions of hill districts. These reasons are as follows:

(a) The Naga hill districts were seriously affected by the prolonged armed conflict between the India’s Armed Forces and the Nagas. Thus, there was no proper census taken in these hill areas. Many of the villages of these districts are so remotely located and are not easily accessible. The census officials did not visit these remote villages to count the population in those years. Many people were left out from the population census.

(b) The extension of Ceasefire Agreement entered between the Government of India and National Socialist Council of Nagaland (NSCN-IM) of 1997 beyond Nagaland was violently opposed and resisted by the dominant valley-based community leading to the forced migration of hill people from the Imphal valley to their hill areas. When the violent agitation against the said Ceasefire Agreement was at its height, the Nagas residing in the Imphal valley went back to their own places in hill areas. Many of these people did not go back to Imphal valley.

(c) It was only after the Ceasefire Agreement of 1997 entered between the Government of India and NSCN-IM that security, law and order situation improved in these hill districts and the census exercise of 2001 could be taken more properly and accurately. It is likely that the population of hill areas will further increase if proper head count is undertaken in all the remote villages of Naga areas.

(d) Another very important reason for the increase in the population of these districts is on account of poverty, under-development, low mortality and high illiteracy. Unlike the more educated and advanced sections of the society, there is no family planning in these poor tribal areas. The tribal families in the hill areas have 5 to 6 children or even more as a norm.

(e) Moreover, the migration of people from other areas to these hill sub-divisions are taking place on account of better business and employment opportunities available in some areas.

(f) The Naga-Kuki conflict of 1992-1997 forced so many people to migrate to safer places and in some hill stations on permanent basis. Similarly, the present Meitei-Kuki-Zo armed conflict will see people moving to the safer places on permanent basis.

 

DELIMITATION, ILLEGAL IMMIGRANTS & NRC

18. As far as illegal immigrants included in the population census and false / fictitious entries in the census record are concerned, it is the duty and responsibility of the Governments of India and Manipur to identify such people and remove such entries from the census record. All the major political parties including the Congress and BJP and the Imphal valley-based CSOs have come out in public that the National Registry of Citizens (NRC) be carried out first and thereafter, the delimitation exercise be undertaken. There is nothing wrong in this assertion. The question is how serious these political parties and the Imphal valley-based CSOs are on the RNC issue! A concerted effort is required to implement NRC in Manipur. Under the collective leadership of the United Naga Council (UNC), Nagas have taken a firm stand to implement NRC in Manipur immediately. However, the NRC exercise should not be linked with the delimitation exercise. Looking at the ground realities and the nature of protests, it appears that the NRC is used more as a weapon to stop the delimitation exercise.

19. If we dive deeper into the NRC issue, then, we will see the real challenges facing us. There is the issue of treatment to be given to the illegal immigrants particularly who came from Myanmar to Manipur before 1951 and after 1951. Without going into the question of who brought them to Manipur in the first place and protected them, these illegal immigrants have been entering Manipur continuously for ages and have settled in Manipur illegally and permanently. From the public and media discussions, it is seen that a view has emerged that those people who had entered Manipur prior to 1951 to be treated as ‘permanent residents’ of Manipur and those people who entered Manipur after 1951 (the base year) to be treated as illegal immigrants. Some parties and leaders are advocating 1961 to be the base year for this purpose. This debate is still continuing without a conclusion.

20. It is the Government of India to decide whether to carry out NRC or not. The GOI has just the intention. Nothing more. Despite the opposition to the 2001 census for delimitation purpose in Manipur by the major political parties and the Imphal valley-based civil social organizations, court orders and the demand for NRC, the GOI has not taken any action in the last 22 years plus to identify those illegal immigrants and deport them. The point raised here is that the identification, imprisonment or deportation of illegal immigrants should be a continuous process under the existing laws such as the Foreigners Act, 1946, the Passport (Entry into India) Act, 1920, Registration of Foreigners Act of 1939 and the Citizenship Act, 1955 (amended many times). The illegal immigrants must be imprisoned or deported under the Foreigners Act, 1946, and the Passport (Entry into India) Act, 1920. This should have been done long ago. According to Indian law, the illegal immigrants are not refugees, but illegal aliens. India is not signatory to the 1951 refugee UN Convention and its 1967 Protocol. India does not have a law to define a refugee. India grants refugee status on a case-by-case and ad-hoc basis. If a registered migrant or a genuine refugee is granted refugee status, then he or she has certain protections. India did not treat Rohingyas from Myanmar (facing serious persecution in Myanmar’s Rakhine state) as not refugees but illegal immigrants and deported them.

21. The NRC exercise is to be in addition to the existing laws to stop illegal immigrants entering Manipur, identify such people and deport them. It is becoming very clear that the GOI is not in a position to undertake the NRC exercise in Manipur. This is the harsh reality facing Manipur whether one likes it or not. Considering the Manipur’s recurring ethnic armed conflicts, the complexity of the issues involved, India’s geo-politics of regional dominance involving the North-East India, Myanmar and its Chin state and Sagaing Region, South–east Asian Countries and China, there will be no NRC for many years to come in Manipur. As things stand, the argument put forward by the Imphal-based political parties and CSOs that the NRC be carried out first before the delimitation exercise is not well-founded.

22. The NRC should be carried out in Manipur immediately without further delay whether the delimitation takes place or not. But no genuine attempts have been made to implement the NRC in Manipur. The anger and the protests we see today are directed against the impending delimitation exercise and not against the non-implementation of NRC. This is the tragedy.

23. For the indigenous people of Manipur, the NRC is a serious matter being connected with their land, their identity, their socio-economic and political rights, their culture and heritage and the protection of their people.

24. The Delimitation Act, 2002 is the law enacted by the Parliament to carry out delimitation in the entire country based on 2001 census. The published 2001 census is the final document on population. When the 2001 census is accepted and used for all other purposes, but rejecting the same for the delimitation exercise is unfair. The parliamentary and assembly seats are frozen until 2026. The next delimitation exercise will be carried out on the basis of the census taken after 2026 i.e. the 2031 census. The delimitation exercise carried out on the basis of 2001 census was completed in 2008 in other states, and the delimitation exercise carried out on the basis of 1971 census under the Delimitation Act, 1972 was completed in 1976. Such exercise took 4 to 6 years. The next delimitation exercise for the entire country is likely to be completed in the year 2036. This means that, if no delimitation exercise takes place on the basis of 2001 census in Manipur, the districts of Ukhrul, Senapati and Chandel will continue to be under-represented for more than three decades.

25. The issue of whether the delimitation exercise based on 2001 census should be carried out or not in Manipur, Nagaland, Assam and Arunachal Pradesh had been hotly contested before the Guwahati High Court and the Supreme Court of India. On 21-08-2014, the Apex Court dismissed all related cases upholding the Notification dated 8^th February, 2008 deferring the process of delimitation for the states of Assam, Manipur, Arunachal Pradesh and Nagaland. The latest case being the Writ Petition(s) (Civil) No(s). 357/2022 filed before the Supreme Court by the Delimitation Demand Committee. In its order dated 17-03-2025, the Supreme Court of India has directed the Centre that “The earlier orders shall be complied with within a period of three months from today. Re-list in the week commencing 21-07-2025”. The Supreme Court of India will definitely take into account all the arguments and points put forward by the Union of India, the respondents and the petitioners and will pass the final order. The order of the Supreme Court will be binding on all the parties.

 

26. For the limited purpose of delimitation exercise, the population census figures published by the Census Authority alone are used to arrive at the above conclusions regardless of the outcome whether it favours one group or the other group.

 

CONCLUSION

27. The hill people of Manipur have been unjustly deprived of their legitimate right of equitable and proportionate representation in the state legislative assembly, and therefore, the delimitation exercise of redrawing and re-adjustment of the legislative assembly constituencies of Manipur must be carried out judiciously on the basis of published census record so that the grievances of the hill people of being under-represented in the Manipur assembly are addressed to and the big divide between the Imphal valley and the hills of Manipur are bridged to a great extent.

 

 

 

Delimitation : Points for consideration

 

AUTHOR:

K. TIMOTHY ZIMIK, IRS

PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX (RETIRED),

MINISTRY OF FINANCE (REVENUE), GOVERNMENT OF INDIA

Date: 25-4-2025

 

 

1. Setting up of a Delimitation Committee:

 

The Delimitation Demand Committee is fighting the delimitation issue before the Supreme Court of India through crowdfunding. We, the Public are fighting this case. Due to stiff opposition from several interested groups, the Centre Government had abandoned the delimitation exercise in Manipur, Nagaland, and Arunachal Pradesh. In Manipur, major political parties including the Congress and BJP and the valley-based CSOs are vehemently opposing the delimitation exercise. The BJP has already set up their delimitation committee. The Apex Court is expected to pass a final order soon directing the GOI to carry out the delimitation exercise based on 2001 census. We need to be prepared to protect our interest. Under the leadership of UNC, a strong Delimitation Committee must be set up immediately to take a stand and fight for our interest.

This Committee shall re-draw and re-adjust the boundaries of assembly constituencies in all hill districts of Manipur so that all Naga areas spread out to different jurisdictions are properly consolidated as far as permitted. Voting rights of some 24 plus foothill (mostly) Naga villages included in the Kherao, Lamlai, Wangkhem and Khetrigao constituencies must be brought back to Senapati district jurisdiction. We lost heavily in the last delimitation exercise carried out under the Delimitation Act, 1972 because of our ignorance and blunders. The other communities (who are very shrewd and cunning) took full advantage of our weaknesses. We shall not allow this to happen again. Let no individual or group interest dictate the outcome this time.

 

2. Who gains:

Ukhrul, Chandel, and Senapati districts will gain one assembly seat each, if the delimitation exercise is carried out based on 2001 census.

1. Ukhrul district having 3 assembly seats, the gain goes to the Nagas.

2. Senapati district having 6 assembly seats namely Mao, Karong, Tadubi, Saikul, Kangpokpi and Saitu, the gain can go to the Gurkhas or the Nagas. The role of the Delimitation Committee will be crucial.

3. Out of 2,83,621 population of Senapati District, Mao-Maram + Paomata + Purul sub-divisions have a population of 1,27,108. The excess population of these areas available for additional seat is 12,411 (1,27,108 ÷ 3 = 42,369 – 38,232 = 4,137 × 3 = 12,411).

4. And Sadar east + Sadar west + Saitu sub-divisions have a population of 1,56,513. One rough estimate (subject to correction) gives the break-up of population of Sadar west + Sadar east + Saitu sub-divisions as follows:

 

Gurkha / Nepali population = 32,000

Naga population                   = 11,000

Kuki population                   = 1,14,513

------------------------------------------------

Total                                     = 1,56,513

 

5. Since the Kuki group has already 3 assembly seats, the average Kuki population per assembly seat works out to 38,171 ( 1,14,513 ÷ 3 ) leaving no excess population for getting one more seat. The average population per assembly constituency of Manipur is 38,232. The Gurkha-Naga combined population of these Kuki sub-divisions comes to 43,000 (32,000+11,000). Further, there is some excess population of 12,411 available in the Mao-Maram, Paomata and Purul sub-divisions for re-adjustment. The average population per assembly seat of these 3 Naga sub-divisions is 42,369 (1,27,108 ÷ 3) and thus, the excess works out to 12,411 as indicate above. The excess Naga population in the entire Senapati district is 23,411 (11,000+12,411). Gurkha + Naga population available for one seat = 55,411 (32,000+23,411) as against the average population of 38,232 per assembly seat.

6. In Chandel district, the situation is very different. There are two assembly seats. In these two constituencies, two Naga MLAs can be elected if only one single Naga candidate is put up in each constituency. The moment two or more Naga candidates are put up in these two constituencies, the Kuki candidate(s) will be elected. This is happening.

 

If one more seat is increased in Chandel district, two options are available. They are:

1. The boundaries are re-drawn and re-adjusted giving one seat to the Kukis. And the Nagas take the other two seats.
2. The second option is to re-draw and re-adjust the boundaries in such a manner that there can be three Naga MLAs provided that only one Naga candidate is put up in each constituency - failing which the Kukis will be elected in all the three constituencies.