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Dinganglung Gangmei vs. Mutum Churamani Meetei & Ors.

Diary No. · 2023 INSC 698Decided 7 Aug 2023
Diary No. 19206 of 2023
Dr. Dhananjaya Y. Chandrachud · J.B. Pardiwala · Manoj Misra

Background

This matter originated from a challenge to a Manipur High Court order directing the State to consider including the Meitei community in the Scheduled Tribes list, which had triggered a Tribal Solidarity March and, from May 2023, large-scale ethnic (sectarian) violence between communities in Manipur. The violence resulted in over 150 deaths, thousands of FIRs, mass displacement into relief camps, destruction of homes and places of worship, and, disturbingly, video evidence of sexual violence against women. Multiple writ petitions under Article 32 were filed seeking court-monitored investigation, protection, compensation, and rehabilitation, and the Supreme Court had been monitoring the situation through a series of hearings since March 2023.

Decision Breakdown

Finding the state investigative machinery's pace "tardy" (with serious delays in registering FIRs, recording victim statements, conducting medical examinations, and making arrests) the Court held that a fair, swift investigation is essential both to secure justice and to prevent wrongful acquittals or convictions. It constituted a three-member committee of retired women judges (Justices Gita Mittal, Shalini Phansalkar Joshi and Asha Menon) to look into the sexual violence against women, oversee victim compensation and rehabilitation, and ensure dignified conditions in relief camps (covering rations, sanitation, medical care, and psychological support). It appointed a former Director General of Police, Dattatray Padsalgikar, to supervise the CBI's and the state police's investigation of the violence-related FIRs, including two FIRs of sexual violence already referred to the CBI, and directed the Union Government to depute outside police officers (including women officers) to strengthen the investigating teams. The Court emphasized that victims must be helped and perpetrators punished "irrespective of community," directed a detailed list of applicable penal provisions to be used in registering FIRs, and ordered periodic status reports, listing the matter for further hearing in October 2023, with the possibility of shifting trials outside Manipur to be considered later.

Lesson Learnt

The Supreme Court can and will use its continuing writ jurisdiction to actively monitor and direct a state's law-and-order and criminal-justice response during a major civil crisis, appointing independent judicial committees and investigators to ensure victims (especially of sexual violence) receive protection, compensation and dignity, and that accountability for violence and any police collusion cuts across community lines.

Official source (sci.gov.in)View Judgment (PDF)

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