Nearly three years after two Kuki-Zo women were disrobed, paraded, and gang-raped by a mob in Manipur’s Thoubal district on May 4, 2023, an attack in which the brother and father of one of the survivors were also killed, three of the accused in the case remain absconding, two have been released on bail by the Gauhati High Court, and the bail application of a third accused is pending before the Supreme Court. The eyewitness husband of one of the victims, an ex-Army soldier serving as a key witness, has publicly stated that the prime suspect identified as Loya, accused of the killings, continues to move freely despite the survivors’ identification, and that no serious efforts are being made to apprehend him.
The case came to national attention only on July 19, 2023, when a video clip of the assault went viral on social media, more than two months after the incident occurred on May 4. The viral video triggered Supreme Court intervention, a transfer of the case to the CBI, a change of trial venue from Manipur to Guwahati on the grounds that the victims could not safely travel to valley areas for hearings, and the appointment of former Maharashtra Police chief Dattatray Padsalgikar as a Special Investigation Team coordinator to oversee multiple Manipur violence cases. The CBI filed a chargesheet on October 12, 2023.
For UPSC aspirants, this case is not merely a criminal justice matter but a test of constitutional law, internal security, the rights of ethnic minorities under the constitutional framework, the accountability of state police forces during communal violence, and the adequacy of judicial monitoring mechanisms for mass human rights violations. The CBI chargesheet’s revelation that police officers present at the scene refused to assist the women, allegedly claiming their vehicle had no key before leaving them to the mob, represents an institutional failure of the gravest kind and raises questions about the accountability of security forces under Article 21 of the Constitution.
Table of Contents
Background and Context of the Manipur Ethnic Violence
Five Important Key Points
- The ethnic violence between Kuki-Zo and Meitei communities in Manipur erupted on May 3, 2023, initially triggered by a High Court direction to the state government to consider the inclusion of Meiteis in the Scheduled Tribe category, which the Kuki-Zo community perceived as a threat to their tribal land rights and political representation, with the conflict rapidly expanding to encompass displacement of over 60,000 people, destruction of thousands of homes, and hundreds of fatalities.
- The CBI chargesheet against the accused in the Thoubal gang rape case alleges that Loya, the prime suspect, beat the brother and father of one of the victims to death using a large wooden log and also participated in the sexual assault, while Chinglen and Inaoton, also named by survivors, remain absconding alongside Loya despite the survivors’ identification of all three during a virtual test identification parade.
- The Gauhati High Court granted bail on September 8, 2025, to two accused, Nameirakpam Kiran Meitei and Arun Khundongbam, acknowledging the gravity of the allegations against them but holding that continued incarceration without trial cannot be used as pre-trial punishment, a legally correct but contextually difficult decision given the broader environment of ethnic violence in Manipur.
- The CBI chargesheet noted that policemen present at the scene of the mob assault refused to assist the women and allegedly claimed their police vehicle had no key before departing, leaving the women to face the mob alone, a level of institutional complicity that the CBI said was still under investigation as of the chargesheet date.
- The Supreme Court’s 12th status report monitoring on February 26, 2026, revealed that Manipur has constituted 36 Special Investigation Teams across eight districts to investigate riot-related cases, with 31 serious cases handed over to the CBI, but the pace of trial and the number of absconding accused across multiple cases suggests that the judicial monitoring mechanism, while valuable, has not translated into the timely justice that survivors were promised.
Constitutional Dimensions: Article 21 and State Accountability
The Thoubal case raises the most fundamental question that Article 21 jurisprudence addresses: whether the state’s duty to protect the right to life and personal liberty includes positive obligations to prevent mob violence against citizens, and whether the deliberate inaction of state security forces during such violence constitutes a constitutional violation for which the state bears direct liability.
In Francis Coralie Mullin versus Union Territory of Delhi (1981), the Supreme Court held that Article 21 encompasses the right to live with dignity, not merely the right to exist. The disrobing, parading, and gang rape of the two women by a mob, in the presence of police who refused to intervene, represents simultaneously a physical attack on the right to life and a profound assault on human dignity. The state’s failure to prevent this attack through the officers it had deployed at the scene, and its subsequent failure to apprehend the absconding accused three years after the incident, raises serious questions about the state’s culpability under Article 21’s positive obligation framework.
The CBI Investigation and Its Limitations
The transfer of the case to the CBI on the Supreme Court’s direction was intended to ensure investigation free from local political pressure. The CBI has filed a chargesheet and has been actively pursuing the case, including filing appeals against the bail granted to the two accused. However, three central limitations have constrained the investigation’s effectiveness.
First, the principal accused Loya remains at large, and his continued freedom suggests either that local intelligence networks are sheltering him or that there is insufficient operational will within the law enforcement system to locate and arrest him. Second, the trial itself has been slowed by logistical challenges, with hearings being conducted by videoconference from Guwahati because the victims cannot safely travel to valley areas of Manipur. This arrangement, while necessary for the victims’ protection, significantly reduces the courtroom effectiveness of victim testimony and creates practical barriers to the full adversarial trial that justice requires. Third, the broader pattern of 31 serious Manipur cases being investigated by the CBI, with 36 SITs covering additional cases, means that resources and attention are stretched across a massive caseload, reducing the intensity of focus on individual cases.
Internal Security and Federalism
The Manipur situation exposes a fundamental tension in India’s federal security architecture. The state government is primarily responsible for maintaining public order under Entry 1 of List II of the Seventh Schedule, but when the state government itself is perceived by one of the two conflict parties as being partial to the other, the ordinary mechanisms of state police investigation and prosecution lose credibility. The Central government’s tools for intervening in state law and order situations are limited: it can deploy Central Armed Police Forces, recommend President’s Rule under Article 356, or initiate a CBI investigation, but it cannot directly supervise state police operations.
The Supreme Court’s monitoring role, exercised through the Padsalgikar committee, represents a judicial attempt to fill this institutional gap. But as the Thoubal case demonstrates, judicial monitoring can ensure that investigations are conducted and chargesheets are filed but cannot guarantee that absconding accused are arrested, that witnesses are protected, or that trials proceed at a pace that delivers timely justice.
Way Forward
The Supreme Court should issue a specific direction to the central government to deploy National Investigation Agency resources to trace and apprehend the three absconding accused in the Thoubal case, using the NIA’s broader geographical reach and intelligence access. The trial court in Guwahati should establish a dedicated fast-track schedule for the Thoubal case, targeting completion within twelve months, with the Supreme Court monitoring compliance on a monthly basis. The National Human Rights Commission should conduct an independent inquiry into the role of police personnel who were present at the scene and failed to protect the victims, with findings submitted to the Supreme Court and state government for action under the relevant service conduct rules.
Relevance for UPSC and SSC Examinations
This topic is relevant to UPSC Mains GS Paper II under Indian Polity and Governance, specifically internal security, constitutional rights of minorities, and the accountability of state security forces. It connects to GS Paper I under communal violence, tribal rights, and Northeast India’s social geography. For GS Paper IV, the ethical failure of police duty during mass violence directly addresses professional ethics and integrity in public service. For the Essay paper, themes around justice, constitutional obligations, internal security, or women’s rights would draw on this material. For SSC examinations, internal security, the CBI, Supreme Court monitoring, and fundamental rights are covered. Key terms aspirants must remember include Article 21, CBI, Special Investigation Team, Unlawful Activities Prevention Act, fast-track court, National Investigation Agency, Gauhati High Court, test identification parade, Prakash Singh judgment, and internal security versus state subject.