Supreme Court Expresses Shock Over Unnatural Deaths in Manipur Relief Camps, Seeks Report from Chief Secretary

The Supreme Court on Thursday expressed profound shock over a report detailing 25 unnatural deaths, including an alleged sexual assault, among internally displaced persons (IDPs) living in relief camps in Manipur. A three-judge bench led by Chief Justice of India Surya Kant directed the state’s Chief Secretary to file a comprehensive affidavit explaining the circumstances of each death, the status of post-mortem examinations, and the compensation paid to the victims’ families. The court also ordered the Manipur State Legal Services Authority (MSLSA) to ensure registration of FIRs in all such cases and to oversee expeditious investigations.

The order came while hearing a batch of petitions concerning the investigation and trial of cases arising from the 2023 ethnic violence in Manipur, which has left thousands displaced and over 200 dead. The bench, also comprising Justices Joymalya Bagchi and V. Mohana, noted that the Justice Gita Mittal Committee—appointed by the Supreme Court in August 2023 to monitor relief and rehabilitation—had flagged serious lapses in addressing deaths in relief camps.

Background: The Unfinished Humanitarian Crisis

The ethnic conflict in Manipur erupted on May 3, 2023, following a ‘Tribal Solidarity March’ against the Meitei community’s demand for Scheduled Tribe status. The violence, primarily between the Meitei and Kuki-Zo communities, led to widespread displacement, with thousands seeking shelter in relief camps across eight districts. The Supreme Court took suo motu cognisance of the situation after a video of two women being paraded naked went viral, and has since been monitoring relief efforts, investigations, and prosecution of crimes.

The court appointed the Justice Gita Mittal Committee to oversee humanitarian issues, and former Maharashtra DGP Dattatray Padsalgikar to supervise the criminal probe. Despite these measures, the committee’s report dated August 14, 2026, revealed that 640 deaths had occurred in relief camps, of which only 34 were classified as unnatural. However, post-mortems were conducted in just 20 cases, and criminal cases were registered in only 25 instances. Compensation paid to the next of kin ranged between ₹20,000 and ₹30,000—a stark contrast to the ₹5–10 lakh typically awarded in other cases.

‘Very, Very Shocking’: Court’s Reaction

During the hearing, Chief Justice Surya Kant expressed dismay at the state’s failure to respond to the committee’s queries. “This is very, very shocking. One of them involves sexual assault. The information sought by the committee was very serious,” the Chief Justice remarked, addressing the state’s Advocate General and Additional Solicitor General Aishwarya Bhati. The court noted that the committee had sent an email on June 11, 2026, seeking district-wise death data, but the information supplied on July 2 was incomplete. A follow-up request on July 4 remained unanswered.

The bench directed the Chief Secretary to furnish a detailed report covering post-mortem findings, preventive measures taken, and steps to ensure the safety and dignity of IDPs. “Tell your Chief Secretary not to invite any problem,” the Chief Justice warned the state’s lawyers, emphasizing that the report must include comprehensive details on medical facilities and daily necessities available in the camps.

Investigation Status: SITs and CBI Cases

The court also perused a status report filed by Dattatray Padsalgikar, who is monitoring the investigation. According to the report, 42 Special Investigation Teams (SITs) have been constituted across eight districts to investigate 3,020 cases. Charge sheets have been filed in 302 cases, closure reports in 1,583, and 1,135 cases remain under investigation. Trials have commenced in 32 cases. The Central Bureau of Investigation (CBI) is probing 31 cases, with charge sheets filed in 28 and closure reports in six; three cases are still under investigation. The CBI has also filed a plea seeking cancellation of bail granted to some accused.

The court suggested setting up two dedicated CBI courts to handle the caseload, and asked Additional Solicitor General Bhati to convey this proposal to the state government. The bench noted that the overall recovery of weapons stood at 8,901 arms, 106,699 ammunition, and 6,390 explosives, indicating some progress in restoring order.

Legal Implications: Right to Life and State Accountability

The Supreme Court’s intervention underscores the constitutional obligation of the state to protect the life and dignity of every person under Article 21. The failure to conduct post-mortems in all unnatural death cases raises serious questions about the adequacy of investigations and the state’s commitment to accountability. The meagre compensation of ₹20,000–30,000 compared to the standard ₹5–10 lakh suggests a possible violation of the right to equal treatment and the right to remedy.

Legal experts point out that the court’s direction to the MSLSA to ensure FIR registration and expeditious investigation is a crucial step in upholding the rule of law. The setting up of special courts could expedite trials, which have been painfully slow—only six witnesses examined out of 978 in CBI cases. The case also highlights the effectiveness of court-appointed committees and monitors in overseeing complex humanitarian crises, setting a precedent for future judicial management of large-scale internal disturbances.

Impact on Legal Practice

For legal practitioners, the order reinforces the importance of timely post-mortems and thorough investigations in cases involving custodial or institutional deaths. The Supreme Court’s insistence on a comprehensive affidavit from the Chief Secretary signals that senior bureaucrats will be held personally accountable for lapses in relief camp management. The involvement of the MSLSA in facilitating FIRs and legal aid to victims’ families is a reminder of the role of legal services authorities in ensuring access to justice for vulnerable populations.

The case also demonstrates the judiciary’s proactive use of its powers under Article 32 to monitor executive action, particularly when fundamental rights are at stake. The court’s suggestion to establish special courts may encourage similar measures in other states facing backlog of criminal cases arising from communal violence.

Conclusion

The Supreme Court has listed the matter for further hearing, with the Chief Secretary’s affidavit expected to provide critical insights into the state’s handling of relief camp deaths. As the legal community watches closely, the case serves as a stark reminder that more than three years after the Manipur violence, the promise of safety and rehabilitation remains unfulfilled for many. The court’s firm stance is likely to compel the state to take immediate remedial action, ensuring that the dignity and rights of internally displaced persons are finally respected.