Delimitation is not an option in Manipur: It is a necessity

The demand of the hill people of Manipur for equitable and proportionate representation in the Manipur Legislative Assembly has been a longstanding one. However, this fundamental right continues to be denied. The opposition by Imphal-based political parties and civil society organisations to the use of the 2001 Census for delimitation has led to the denial of Article 14 of the Constitution—the right to equality—to a significant number of citizens living in the hill districts.

Manipur is geographically and demographically divided into two distinct regions—the Imphal Valley and the hill districts. The Valley, comprising only about one-tenth of the state’s total area of 22,327 square kilometers, includes the districts of Imphal East, Imphal West, Bishnupur, and Thoubal. It is primarily inhabited by the Meitei community. The remaining nine-tenths of the area consists of the hill districts—Senapati, Ukhrul, Chandel, Tamenglong, Churachandpur, and others—home predominantly to Naga and Kuki-Zo tribal communities.

Despite this disparity in geographical spread, the Imphal Valley holds 40 of the 60 seats in the Manipur Legislative Assembly, while the hills are left with just 20. This allocation neither reflects the area distribution nor the population, especially considering the 2001 Census figures.

Population and Representation Based on the 2001 Census

In 2001, Manipur’s total population was approximately 22.93 lakh. Of this, the Imphal Valley accounted for about 14.12 lakh (61.5 percent), and the hill districts for 8.82 lakh (38.5 percent). Based on this data, a fair seat allocation would have given around 23 seats to the hills and 37 to the Valley, instead of the existing 20:40 ratio.

Constituency-wise population data further reveals the disparity. In the Valley, each assembly seat in districts like Imphal West, Imphal East, Thoubal, and Bishnupur represented around 34,000–36,000 people, with an average geographical area per seat ranging from 40 to 83 sq. km. In contrast, the hill constituencies had to represent larger populations over vast areas. For instance, Chandel’s two constituencies each represented about 59,000 people over 1,637 sq. km. Ukhrul’s three seats represented nearly 47,000 people each, across about 1,500 sq. km. Senapati’s six seats represented an average of over 46,000 people each over 545 sq. km.

The average population per assembly constituency in Manipur in 2001 was around 38,232. Had the seats been distributed proportionately, the Imphal Valley’s 14.12 lakh people would have warranted 37 seats, while the hills’ 8.82 lakh population merited at least 23 seats. This would bring the average population per constituency closer to the state average in both regions—around 38,150 in the Valley and 38,350 in the hills.

This imbalance clearly demonstrates the need for the hill districts to gain at least three additional seats—one each for the most under-represented districts of Chandel, Ukhrul, and Senapati.

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Severe Under-Representation in Hill Districts

In 2001, the hill districts were grossly under-represented:

Chandel: Two seats represented nearly 60,000 people each—about 24,000 more than the average in the Valley.

• Ukhrul: Three seats averaged about 47,000 people—around 12,000 above the Valley average.
  
• Senapati: Six seats each represented around 47,000 people.
  

Collectively, these three districts had an “excess population” of over 1.5 lakh when compared to average Valley constituencies. Given the state’s average constituency size of 38,232, this excess alone justifies the creation of three new constituencies in the hill areas.

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Census Exclusions in Senapati and Their Impact

A major flaw in the 2001 Census was the exclusion of three subdivisions in Senapati district—Mao-Maram, Paomata, and Purul—due to local disturbances. The officially recorded population for Senapati was just 2.83 lakh, missing about 97,000 people who were living in those subdivisions. Based on prior growth trends, the actual population of Senapati was closer to 3.80 lakh.

Compare this with Bishnupur district in the Valley, which had a population of 2.08 lakh and was allocated six assembly seats. Despite having nearly twice the population, Senapati received the same number of seats. This clear case of under-representation severely affects the ability of hill people to participate in governance.

Selective Politicisation of the 2001 Census

Opponents of delimitation based on the 2001 Census, mainly from the Imphal Valley, argue that the census data is unreliable due to abnormal growth rates in some hill areas. However, these objections were raised only when delimitation was proposed—not when the same census was used for elections, funding, and development planning over two decades.

This selective objection appears politically motivated. The data was deemed valid for all other purposes, and only contested when it came to equitable redistribution of legislative power.

Moreover, while three subdivisions in Senapati did show inflated growth rates, this was a direct result of data being excluded in 2001 and then revised in 2003. This revision inflated growth rates on paper, but in reality, it merely restored omitted data. Therefore, branding the entire hill population data as unreliable lacks both legal and statistical basis.

The Case for Using the 2011 Census

If the 2021 Census had been conducted, it would have provided the most current data. However, due to the COVID-19 pandemic, the 2021 Census was delayed. Therefore, the only viable alternative is the 2011 Census, which shows even starker disparities.

In 2011, Manipur’s total population had increased to 28.56 lakh, with the Imphal Valley holding about 16.34 lakh (57.2 percent) and the hill districts 12.22 lakh (42.8 percent). However, the seat allocation remained unchanged—40 for the Valley, 20 for the hills.

The population per constituency in the Valley ranged from about 34,000 to 41,000, while in the hills it ranged from over 50,000 to nearly 80,000:

• Chandel: Two seats represented over 72,000 people each.
  
• Ukhrul: Three seats represented over 61,000 people each.
  
• Senapati: Six seats represented around 79,500 people each.
  

In contrast, a Valley district like Bishnupur had each of its six seats represent just around 34,700 people.

If equitable representation were applied, the hill districts would gain at least six more assembly seats based on 2011 figures. This would bring the seat ratio to about 34:26 between the Valley and the hills—closer to the actual population distribution.

Delimitation Elsewhere: The Assam Example

Initially, the Union Government deferred delimitation in Assam, Manipur, Nagaland, and Arunachal Pradesh in March 2021. However, the decision was reversed in July 2022, and delimitation was successfully completed in Assam based on the 2001 Census.

Assam’s delimitation process was significantly more complex. It had to address contentious issues related to illegal immigration, the NRC, and ethnic representation. Despite these hurdles, the process was carried out effectively.

In Manipur, there were no such challenges—no NRC issues, no significant boundary disputes—yet the process was halted. This was largely due to sustained opposition from Imphal-based political actors who viewed any increase in hill representation as a threat to their political dominance.

NRC Issues in Manipur

The National Register of Citizens (NRC) has also been a subject of concern in Manipur. Unlike Assam, where the NRC process is already completed, Manipur has only recently initiated the process in response to public demand and legal directives. The call for NRC stems from the need to identify illegal immigrants and to preserve the indigenous identity of the people, especially in the hill areas.

However, the implementation of NRC in Manipur must be approached with sensitivity and inclusiveness. It should not become another tool for exclusion or political gain. Instead, it should aim at fair identification processes, protection of indigenous communities, and preventing demographic manipulation through illegal immigration.

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Constitutional Principles and the Way Forward

The Indian Constitution guarantees equality and proportional representation. Article 170 mandates that legislative assemblies shall be constituted so that the ratio between the population of a state and the number of seats is the same throughout the state. This principle is clearly violated in Manipur.

Furthermore, the continued under-representation of hill districts contradicts Article 14 (Right to Equality) and Article 371C, which provides for special administrative arrangements for hill areas in Manipur. The Hill Areas Committee, created under this provision, has also demanded a fair and transparent delimitation based on official census data.

The way forward is clear:

1. Immediate Resumption of Delimitation: The Election Commission must resume the delimitation exercise in Manipur, using either the 2001 or 2011 Census.
   
2. Reallocation of Seats: Based on population and area, at least 3–6 additional seats should be allocated to the hill districts.
   
3. Constitutional Compliance: The principles enshrined in Articles 14, 170, and 371C must be respected.
   
4. Transparency: The process should involve all stakeholders—hill and valley representatives alike—in a spirit of mutual respect.
   

Conclusion

The failure to conduct delimitation in Manipur is not merely an administrative issue—it is a constitutional injustice. The people of the hill districts continue to be denied their rightful voice in governance despite representing a large portion of the state’s population and geography.

If delimitation could be undertaken in Jammu and Kashmir and Assam—both far more politically sensitive—there is no valid reason for its continued deferral in Manipur. Upholding democratic values and ensuring fair representation must not be subject to regional or communal politics.

Delimitation is not a favour—it is a constitutional and democratic imperative. The time to act is now. 

 The author is Former Principal Chief Commissioner of Income Tax, Ministry of Finance (Revenue), Government of India

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