Manipur Relief Camps: Supreme Court Seeks Probe Into 25 Unnatural Deaths — What the Constitution Demands From the State

Citation: Dinganglung Gangmei v. Mutum Churamani Meetei & Ors., Supreme Court, judgement dated 7 August 2023, arising from SLP(C) Diary No. 19206/2023; connected proceedings including W.P.(C) No. 540/2023, Manipur Tribal Forum Delhi v. State of Manipur & Anr.; subsequent orders in the continuing Manipur proceedings.

Introduction: The Question Is No Longer Merely About Relief

There is a point in every constitutional crisis when statistics cease to be statistics.

They become names.

They become families.

They become unanswered questions.

The latest concern before the Supreme Court regarding 25 unnatural deaths among persons living in Manipur relief camps and settlements must be understood against precisely that background.

The State’s own information, disclosed under the Right to Information Act, has reportedly recorded 731 deaths among internally displaced persons living in relief camps and prefabricated settlements since the violence began in May 2023, of which 25 were classified as unnatural deaths. More than 43,000 persons were still reported to be displaced as of 30 April 2026.

The Supreme Court has now sought information concerning the 25 unnatural deaths, including material relating to the causes of death and post-mortem reports, together with information regarding preventive measures and facilities available to displaced persons.

The significance lies not simply in the number 25.

It lies in the question that follows:

When a citizen is displaced by violence and becomes dependent upon the State for shelter, food, medical care and security, what exactly does Article 21 require the State to do to protect that person’s life and dignity?

That question takes this matter beyond ordinary administration.

It enters the territory of constitutional governance.

First, an Important Legal Clarification: This Is a Continuing Constitutional Proceeding

It would be inaccurate to describe the latest development as though the Supreme Court has delivered an entirely new final judgement establishing that the State is responsible for the 25 deaths.

It has not, on the material presently publicly accessible, made such a finding.

The Supreme Court is dealing with the Manipur crisis through continuing proceedings.

The principal constitutional intervention began in 2023. In Dinganglung Gangmei v. Mutum Churamani Meetei, the Court recognised the extraordinary circumstances arising from the violence and issued extensive directions concerning relief camps, medical care, rehabilitation, compensation, investigation and protection of affected persons.

The Court subsequently constituted a three-member committee headed by former Chief Justice of the Jammu & Kashmir High Court Justice Gita Mittal.

That committee was still functioning in 2026. In January 2026, the Supreme Court recorded that the committee had submitted 42 reports and regularised its continuation after 31 July 2025, granting it time until 31 July 2026 to complete its assigned task.

Therefore, the present concern over deaths in relief camps is best understood as another chapter in an extraordinary continuing constitutional jurisdiction.

What the Supreme Court Had Already Said About Manipur Relief Camps

The importance of the latest development becomes clear when the original 2023 judgement is read carefully.

On 8 May 2023, shortly after the outbreak of violence, the Supreme Court recorded concerns regarding relief and rehabilitation and emphasised the need for vigilance to prevent recurrence of violence.

The Court specifically emphasised three requirements:

• Adequate arrangements in relief camps, including food and medical care;
• Necessary precautions for rehabilitation of displaced persons; and
• Protection of religious places.

Where critical medical care was required, the authorities were directed to make arrangements for treatment at army hospitals or other medical establishments.

That is important.

The Supreme Court was not treating the relief camps merely as temporary shelters.

It was treating the conditions in those camps as a matter capable of engaging constitutional rights.

The 7 August 2023 Judgement Went Much Further

The Court’s 7 August 2023 judgement is the constitutional foundation upon which the present scrutiny rests.

The Court accepted the need for:

• Free and comprehensive medical aid;
• Psychological care;
• Dignity in relief camps;
• Adequate food and essential products;
• Medical facilities;
• Disease-control measures;
• Maternal healthcare;
• Specialised treatment for serious illnesses;
• Sanitation;
• Suicide-prevention services;
• Legal and psychosocial assistance;
• Compensation and restitution;
• Preventive measures;
• Access to information; and
• Dignified disposal of dead bodies.

The Court’s directions specifically contemplated conditions of dignity in relief camps, rather than mere physical shelter.

This is a remarkable feature of the judgement.

The constitutional obligation was conceived broadly.

A relief camp had to be capable of sustaining human dignity.

The Supreme Court Did Not Leave the Matter Entirely to the Executive

The Court also created institutional mechanisms.

The Justice Gita Mittal Committee was tasked with examining and facilitating several aspects of relief and rehabilitation.

Among the matters placed within the broader institutional framework were:

• Compensation;
• Documentation;
• Legal assistance; and
• The needs of displaced persons.

The Court also required nodal officers at relief camps and mechanisms to provide information concerning investigations, missing persons and recovery of bodies. (CaseMine)

This is significant because constitutional adjudication in India has increasingly recognised that some rights violations cannot be remedied through a single declaratory judgement.

They require continuing supervision.

Why the 25 Unnatural Deaths Are Different From Ordinary Camp Deaths

This distinction is critical.

The RTI data reportedly records 731 deaths among displaced persons living in relief camps and prefabricated housing.

But only 25 were classified as unnatural deaths.

The two numbers must not be conflated.

Figure	Reported Significance
731 deaths	Deaths among displaced persons living in relief camps and prefabricated housing, from various causes.
25 unnatural deaths	Deaths classified as unnatural and therefore requiring examination of their individual circumstances.

The 731 figure includes deaths from various causes.

The 25 figure concerns deaths categorised as unnatural.

The reported examples include drowning, electrocution, hanging, overdose, bullet injury and a sexual-assault-related death.

The legal significance of an unnatural death is that its circumstances ordinarily require greater scrutiny.

But an important caution is necessary:

“Unnatural death” is a classification requiring investigation; it is not itself a finding of criminal liability or state negligence.

A drowning may be an accident.

A hanging may be suicide.

A bullet injury may be homicide or accidental.

An overdose may have several possible causes.

A death associated with sexual assault raises entirely different questions.

The constitutional court must therefore examine evidence rather than convert the classification into a conclusion.

Why the Post-Mortem Report Matters

The Court’s demand for post-mortem material is therefore legally important.

A post-mortem report may assist in answering:

• What was the medical cause of death?
• What injuries were present?
• Were those injuries consistent with the initial explanation?
• Was there evidence of violence?
• Was there evidence of poisoning or intoxication?
• Was the death accidental, suicidal or homicidal?
• Was further investigation required?
• Were there discrepancies between the medical evidence and the administrative account?

The Court is therefore moving from general assurances to primary evidence.

That is a major difference.

A government affidavit can say:

“Adequate arrangements have been made.”

A post-mortem report says something different.

It is an evidentiary document concerning an individual human death.

That is precisely the kind of material a constitutional court requires before determining whether further intervention is justified.

The Current Criminal-Procedure Framework Is Also Relevant

There is another development which cannot be ignored.

The criminal-procedure framework has changed since the original 2023 proceedings.

The Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), came into force on 1 July 2024.

Section 194 deals with police inquiry and reporting concerning certain deaths, including circumstances in which there is reason to suspect death by suicide or death occurring in circumstances requiring an inquest.

Section 196 provides for inquiry by a magistrate into the cause of death in specified circumstances and permits a magistrate, where appropriate, to conduct an inquiry instead of or in addition to the police investigation. It also contains special provisions concerning persons dying or disappearing in custody and requires forwarding of the body for medical examination within the statutory framework.

This is important for the present controversy.

If the Supreme Court is asking for post-mortem reports and circumstances surrounding unnatural deaths, the State cannot answer merely at the level of administrative statistics.

The Court can ask whether the deaths were dealt with through the procedures mandated by criminal law.

The Disaster Management Act Provides Another Layer of Responsibility

The Disaster Management Act, 2005, is also relevant, although the Manipur violence cannot simply be reduced to an ordinary natural-disaster scenario.

Section 12 requires the National Disaster Management Authority to recommend minimum standards of relief.

Those standards expressly include:

• shelter;
• food;
• drinking water;
• medical cover; and
• sanitation in relief camps.

The provision also contemplates special provisions for widows and orphans.

The significance is conceptual.

Indian statutory law itself recognises that a relief camp is not merely a roof.

A relief camp has minimum standards.

Those standards reflect the basic necessities of human survival.

In Manipur, these statutory principles operate alongside constitutional obligations and the specific Supreme Court directions issued in the continuing litigation.

Article 21 Is the Constitutional Centre of Gravity

Ultimately, however, the deepest legal question is Article 21.

Article 21 states:

“No person shall be deprived of his life or personal liberty except according to procedure established by law.”

The Supreme Court’s interpretation of Article 21 has long moved beyond the narrow protection against physical deprivation.

It encompasses dignity, healthcare and conditions necessary for meaningful human existence.

The Court’s Manipur judgement expressly approached the crisis through this constitutional framework.

The Right to Health Strengthens the Argument

The Supreme Court’s broader jurisprudence concerning medical treatment is particularly relevant.

In Paschim Banga Khet Mazdoor Samity v. State of West Bengal, (1996) 4 SCC 37, the Court treated adequate medical facilities as part of the State’s obligations under Article 21.

The principle was subsequently reiterated in several decisions.

The Supreme Court has recently restated that the right to health is integral to the right to life and that the government has a constitutional obligation to provide health facilities.

Similarly, in Parmanand Katara v. Union of India, (1989) 4 SCC 286, the Court famously emphasised the State’s obligation to preserve life and the duty of doctors to provide immediate medical assistance necessary to save life.

These cases did not concern Manipur relief camps.

That distinction must be maintained.

But their constitutional principle is relevant.

If a displaced citizen living in a state-supported relief environment develops a life-threatening medical condition, access to timely medical care can engage Article 21.

The State cannot simply say:

“A medical facility exists somewhere.”

The practical question may be:

Was timely and effective medical assistance reasonably available to the person who needed it?

From Negative Rights to Positive State Duties

This is where modern Article 21 jurisprudence becomes particularly important.

Fundamental rights were once understood primarily as restrictions upon state power.

Modern constitutional jurisprudence also recognises circumstances in which the State has positive obligations.

The State may have to:

• provide medical assistance;
• protect persons in custody;
• investigate serious violations;
• provide basic rehabilitation;
• establish mechanisms to prevent foreseeable harm; and
• create conditions necessary for meaningful exercise of constitutional rights.

The Manipur proceedings illustrate this transformation very clearly.

The Court is not merely telling the State:

“Do not violate rights.”

It is also asking:

“What are you doing to protect people whose circumstances make them exceptionally vulnerable?”

Internally Displaced Persons Are Still Constitutional Rights-Holders

This point deserves emphasis.

Internal displacement does not suspend the Constitution.

A person does not cease to be entitled to Article 21 merely because he has lost his house.

A person living in a relief camp remains entitled to:

• life;
• dignity;
• equality;
• access to justice;
• medical care within the constitutional framework;
• protection from violence; and
• lawful investigation of suspicious deaths.

Indeed, vulnerability may make constitutional protection more—not less—important.

The Protection of Human Rights Act Adds Another Perspective

The Protection of Human Rights Act, 1993, defines human rights by reference to rights relating to life, liberty, equality and dignity guaranteed by the Constitution or embodied in international covenants and enforceable by Indian courts.

The Act provides the institutional framework for the National Human Rights Commission, State Human Rights Commissions and Human Rights Courts.

This does not mean that every death in a relief camp automatically becomes a human rights violation.

It means that life, liberty and dignity are legally recognised human-rights concerns.

The Supreme Court’s scrutiny therefore fits into a much larger Indian legal architecture concerning protection of vulnerable persons.

The Constitutional Compensation Jurisprudence

Suppose, eventually, the evidence demonstrates that an established violation of Article 21 occurred.

What remedy could follow?

The answer is found in the constitutional compensation jurisprudence beginning with Rudul Sah v. State of Bihar (1983) 4 SCC 141 and significantly developed in Nilabati Behera v. State of Orissa (1993) 2 SCC 746.

In Nilabati Behera, the Supreme Court recognised the power of constitutional courts to grant monetary compensation for established violations of fundamental rights.

The Court has subsequently reiterated that public-law compensation is distinct from ordinary civil damages and can be awarded where the constitutional violation is sufficiently established.

More recently, the Supreme Court has reiterated that compensation may be appropriate where the violation of Article 21 is patent and incontrovertible and of sufficient gravity.

But that principle should not be misapplied here.

The present 25 cases do not automatically establish entitlement to constitutional compensation.

The factual and legal circumstances of each death would have to be established.

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The State’s Possible Defence Must Also Be Understood

A balanced constitutional analysis must examine the other side.

The State may contend that:

• Not every death occurring in a relief camp is attributable to the State;
• Some deaths may result from natural causes;
• Some unnatural deaths may be accidents or suicides;
• The State has already established medical and welfare mechanisms;
• investigations have been undertaken in individual cases;
• the continuing displacement results from a complex security situation beyond the state’s unilateral control; and
• Courts should not substitute their administrative judgement for that of the executive.

These are not legally frivolous propositions.

They must be tested against evidence.

The Court cannot properly convert every unfortunate death into state liability.

The Counterargument: Relief-Camp Residents Are Not Ordinary Residents

There is, however, an important response.

The State itself has created or administered a system in which displaced persons depend substantially upon public authorities for:

• shelter;
• food;
• water;
• sanitation;
• medical assistance;
• security; and
• rehabilitation.

The Supreme Court itself has already directed that relief camps must meet standards of dignity and that critical medical treatment must be made available.

Therefore, once a specific deficiency is demonstrated, the constitutional question becomes much stronger.

The critical inquiry should be:

Was there a constitutional or statutory duty, was the duty reasonably capable of performance, and did a failure in that duty materially contribute to the harm?

That is a much more rigorous question than simply asking whether “the government is responsible”.

The Separation-of-Powers Question

There is another constitutional tension which should not be ignored.

Courts cannot run governments.

The Supreme Court itself has repeatedly cautioned against judicial overreach.

In Divisional Manager, Aravali Golf Club v. Chander Hass, (2008) 1 SCC 683, the Court stressed the importance of judicial restraint and recognised that courts should not assume functions belonging to the executive or legislature.

That principle is particularly relevant when courts are dealing with:

• allocation of resources;
• staffing of hospitals;
• construction of shelters;
• administrative structures; and
• public expenditure.

A constitutional court must therefore distinguish between:

• setting constitutional minimum standards
• and
• running the relief administration itself.

The former is unquestionably within judicial review where fundamental rights are implicated.

The latter raises legitimate separation-of-powers concerns.

Why Continuing Mandamus Is Justified in Exceptional Circumstances

Yet there is another side.

Manipur is not an ordinary administrative dispute.

The Supreme Court has already recorded the scale of the violence, displacement and institutional difficulties.

The Court therefore adopted an exceptional supervisory structure.

The creation of the Justice Gita Mittal Committee was not an ordinary exercise of appellate jurisdiction.

It was a response to a situation in which ordinary litigation could not easily address thousands of displaced persons and multiple categories of grievances.

The continuing nature of the proceedings also explains why the Court continues to receive reports.

As of January 2026, the Court recorded that the committee had already submitted 42 reports.

That fact is itself revealing.

The crisis could not realistically be resolved through one final judgement.

The 2026 Developments Show That Relief-Camp Conditions Remain Judicially Relevant

A particularly important subsequent development came on 19 January 2026.

In Anthony Naulak v. District Commissioner, Churachandpur, SLP(C) No. 1458/2026, the Supreme Court considered complaints concerning alleged deficiencies in relief camps, including food, sanitation and medical facilities.

The petitioner had submitted a detailed representation to the authorities in July 2025.

The Court recorded that the representation had been forwarded to the Justice Gita Mittal Committee and directed the Committee to examine the complaints and submit a report.

This is powerful contextual evidence.

It demonstrates that, even three years after the violence began, the Supreme Court was still treating the condition of relief camps as a live constitutional concern.

The Court’s Earlier Directions Also Covered Compensation and Dignified Disposal of Bodies

The 2023 judgement was not limited to shelter.

The Court’s directions contemplated:

• compensation;
• restitution;
• medical care;
• psychological care;
• dignity in relief camps;
• preventive measures;
• access to information;
• investigation; and
• dignified disposal of dead bodies.

This last point becomes particularly relevant to the present controversy.

A death does not end the constitutional relationship between the state and the citizen.

The dignity owed to the deceased and the rights of surviving family members continue to matter.

The Question of Investigation Is as Important as the Question of Relief

The Supreme Court’s earlier Manipur judgement also recognised concerns concerning investigation and institutional accountability.

That means the current issue has two separate dimensions.

First: Preventive Responsibility

Did the State provide reasonably adequate conditions of safety, sanitation and medical care?

Second: Investigative Responsibility

When an unnatural death occurred, did the authorities conduct a lawful, prompt and credible investigation?

The second question can remain important even if the state ultimately proves that it could not have prevented the death.

An accident does not necessarily establish state negligence.

But failure to properly investigate an accident—or a suspected homicide—can create an entirely different constitutional problem.

Why the 25 Deaths May Become a Larger Constitutional Inquiry

The Court may ultimately need to ask whether the 25 deaths are:

• isolated incidents
• or
• indicators of systemic vulnerability.

That distinction is crucial.

If the cases are entirely unrelated, arose from different circumstances and were properly investigated, the constitutional implications may be limited.

But if several deaths demonstrate recurring failures—for example:

• inadequate medical response;
• dangerous camp conditions;
• lack of emergency transport;
• inadequate sanitation;
• absence of suicide-prevention mechanisms;
• unsafe water bodies;
• electrical hazards;
• delayed investigations; or
• inadequate security—

Then the constitutional question becomes broader.

The Court may then legitimately ask whether the system itself requires correction.

The 731 Deaths: A Statistic That Requires Context

The reported figure of 731 deaths must be handled carefully.

It is not correct to say:

“The Supreme Court is investigating 731 deaths.”

The information publicly reported from the RTI response concerns 731 deaths among displaced persons living in camps and prefabricated housing.

The separate figure is 25 unnatural deaths.

More than 43,000 displaced persons were reportedly still living in camps and temporary housing as of 30 April 2026.

The number 731 therefore raises a significant humanitarian question.

But it does not, without more, prove that the State caused those deaths.

A lawyer must resist the temptation to convert a troubling statistic into a legal conclusion.

The More Difficult Question: How Long Can a Relief Camp Remain “Temporary”?

This may ultimately be the most profound constitutional issue.

A relief camp created for three weeks is one thing.

A relief camp continuing for three years is another.

Once temporary displacement becomes prolonged, the constitutional vocabulary changes.

People need:

• education;
• employment;
• permanent housing;
• healthcare;
• documentation;
• family security;
• political participation;
• property restoration; and
• a realistic path to normal life.

The Supreme Court’s own earlier directions recognised rehabilitation as a central part of the constitutional response.

The law should therefore not permit “relief” to become a substitute for rehabilitation indefinitely.

The International Dimension

There is also an international human-rights dimension, although it must be used carefully.

The UN Guiding Principles on Internal Displacement recognise that internally displaced persons remain entitled to protection and humanitarian assistance.

But those principles are not, by themselves, an Indian statute creating directly enforceable domestic obligations.

Their value lies in providing persuasive international standards for understanding displacement, dignity, humanitarian protection and rehabilitation.

The domestic legal foundation remains the Constitution, statutes, binding Supreme Court precedent and applicable governmental schemes.

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The Present Legal Position

As matters presently stand, several propositions can safely be stated.

Legal Proposition	Position
1. Article 21 protects displaced persons.	Internal displacement does not remove constitutional protection.
2. The State has positive obligations concerning life and healthcare.	The Supreme Court’s Article 21 jurisprudence recognises a constitutional obligation to preserve life and provide access to medical care.
3. Relief camps are subject to constitutional scrutiny.	The Supreme Court expressly directed that relief camps must provide basic amenities and dignified conditions.
4. Unnatural deaths require investigation.	The BNSS provides the procedural framework for inquiry into specified unnatural and suspicious deaths, including magistrate inquiry in appropriate cases.
5. The Disaster Management Act recognises minimum relief standards.	These include shelter, food, drinking water, medical cover and sanitation.
6. Constitutional compensation is possible in an established Article 21 violation.	But it is not automatic merely because a death occurred.
7. Judicial supervision has limits.	The Court can enforce constitutional rights but should not ordinarily substitute itself for the executive in questions of detailed administration.

What the Supreme Court Should Ultimately Ask

In my view, the legally useful way of approaching the 25 cases is through a structured matrix.

For each death:

Question	Evidence Required
Identity of deceased	Official records
Date and place of death	Camp/district records
Circumstances	Police and administrative reports
Cause of death	Post-mortem/medical report
Nature of death	Accident/suicide/homicide/other
FIR/inquest	Police records
Magistrate inquiry, where applicable	Magistrate record
Medical treatment before death	Hospital/camp medical records
Emergency response	Ambulance/referral records
Security arrangements	Camp/security records
Prior complaints	Camp grievance records
Preventive measures	Administrative records
Investigation outcome	Final police report/charge sheet/closure report
Compensation	Victim compensation records
Family informed	Communication records

Such a framework would allow the Court to distinguish individual tragedy from systemic failure.

What Would Constitute a Constitutional Failure?

Not every unfortunate outcome constitutes a violation.

A stronger constitutional case may arise where evidence demonstrates:

• known risk
• State responsibility
• inadequate response
• foreseeable harm
• causal connection

For example, if authorities were repeatedly informed of a serious safety hazard in a relief camp and did nothing, and a resident subsequently died because of that hazard, the Article 21 question would be substantially different from an unforeseeable accident.

Likewise, if a critically ill patient repeatedly sought emergency treatment and was denied or delayed without lawful justification, the medical-rights jurisprudence becomes directly relevant.

The law must therefore remain evidence-based.

The Real Test Is Not Whether the State Can Explain the Death

There is a subtle but important distinction.

The constitutional test should not be:

“Can the government produce an explanation?”

The better question is:

“Can the Government demonstrate that it discharged the constitutional and statutory duties reasonably applicable to the circumstances?”

That is a much higher standard.

An explanation after a death is not necessarily equivalent to prevention before death.

A Lawyer’s Reading of the Latest Intervention

Seen from the perspective of constitutional law, the Supreme Court’s latest move has three layers.

Layer	Constitutional Question
Layer One: Individual Justice	What happened to each of the 25 persons?
Layer Two: Administrative Accountability	What did the authorities do before and after each death?
Layer Three: Constitutional Governance	Do the facts reveal a systemic failure to protect a vulnerable displaced population?

The first requires evidence.

The second requires accountability.

The third requires constitutional judgement.

The Opposing View Must Not Be Ignored

There is a legitimate concern that prolonged judicial supervision can blur the constitutional line between adjudication and administration.

If the Court begins deciding:

• how many doctors should be posted;
• how much money should be spent;
• which contractor should supply food;
• how a camp should be administered; or
• how the State should design its entire rehabilitation policy,

It risks entering territory ordinarily entrusted to elected governments and administrators.

Judicial restraint is therefore not an enemy of human rights.

It is itself part of constitutional governance.

The proper judicial role is to establish enforceable constitutional standards, require accountability, examine evidence and intervene where rights are violated—not to become the permanent administrator of the State.

But Judicial Restraint Cannot Become Judicial Indifference

The opposite danger is equally real.

A court confronted with a vulnerable population cannot simply say:

“This is an administrative matter.”

The Supreme Court’s Article 32 jurisdiction exists precisely because fundamental rights require an effective judicial remedy.

The Court itself explains that Article 32 gives it extensive original jurisdiction to enforce fundamental rights through directions, orders and writs.

The constitutional balance therefore lies between two extremes:

• judicial over-management
• judicial disengagement

The Manipur proceedings occupy that difficult middle ground.

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The Most Important Lesson for Constitutional Law Students

For a law student, this case presents a fascinating study in the evolution of Article 21.

The traditional question was:

Can the State unlawfully take life?

The modern question is broader:

What reasonable positive obligations does the State owe to preserve life when people are placed in conditions of extraordinary vulnerability?

The answer emerges from a chain of jurisprudence:

Rudul Sah → Nilabati Behera → D.K. Basu → Paschim Banga → Parmanand Katara → continuing Article 21 jurisprudence → Manipur relief-camp directions.

The cases involve different factual situations.

But they collectively demonstrate the expansion of constitutional protection from negative restraint to positive state responsibility.

What Happens Next?

The immediate legal significance of the latest order is that the court is seeking documentary material.

The next stage should therefore be evidence.

The State’s response may determine whether the matter remains a fact-finding exercise or develops into a broader inquiry concerning systemic deficiencies.

The Court may eventually ask:

• Were the deaths properly classified?
• Were investigations adequate?
• Were post-mortems conducted?
• Were medical facilities sufficient?
• Were preventive measures implemented?
• Were complaints ignored?
• Were families informed?
• Was compensation provided?
• Were earlier Supreme Court directions complied with?

The answers could have consequences beyond the 25 individual cases.

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Conclusion: A Relief Camp Is Not a Constitutional Vacuum

The most important principle emerging from the Manipur relief-camp litigation is a simple one:

Displacement does not displace the Constitution.

A person who has lost his house has not lost Article 21.

A family living under a temporary roof remains entitled to dignity.

A seriously ill person in a relief camp remains entitled to the protection of life.

And when a person dies an unnatural death in circumstances requiring investigation, the State must be able to account for what happened through lawful investigation and reliable evidence.

The Supreme Court’s latest scrutiny of the 25 unnatural deaths should therefore not be reduced to a headline about a number.

It represents a much deeper constitutional inquiry.

The question is not merely:

“How many people died?”

The constitutional question is:

“What did the State know? What was the State required to do? What did it actually do, and what does the evidence establish?”

That is the correct legal lens.

The Supreme Court’s earlier Manipur judgement had already stated that displaced persons must be provided with dignity, medical care, psychological assistance, basic necessities, sanitation, preventive measures and access to justice.

The 25 unnatural deaths now place those principles under a harder test.

Because constitutional rights are not measured by the quality of an administrative promise.

They are measured by what happens to the individual citizen when that promise is put to the test.

And for a person living in a Manipur relief camp, that test may ultimately come down to the most fundamental promise contained in the Constitution:

The State must not become indifferent to human life.

Key Authorities and Statutory Framework

Supreme Court

1. Dinganglung Gangmei v. Mutum Churamani Meetei & Ors.
   Supreme Court, judgement dated 7 August 2023 — relief camps, rehabilitation, medical care, dignity, compensation, investigation and institutional mechanisms.
2. Paschim Banga Khet Mazdoor Samity v. State of West Bengal
   (1996) 4 SCC 37 — State obligation to provide adequate medical facilities under Article 21.
3. Parmanand Katara v. Union of India
   (1989) 4 SCC 286 — constitutional obligation to preserve life and provide immediate medical assistance.
4. Nilabati Behera v. State of Orissa
   (1993) 2 SCC 746 — public-law compensation for established fundamental-right violations.
5. D.K. Basu v. State of West Bengal
   (1997) 1 SCC 416 — protection of life and liberty and state accountability for custodial violations.
6. Divisional Manager, Aravali Golf Club v. Chander Hass
   (2008) 1 SCC 683 — judicial restraint and separation of powers.

Statutes

Constitution of India

• Article 14 — equality before law.
• Article 21 — life and personal liberty.
• Article 32 — constitutional remedies.
• Articles 38 and 39 — Directive Principles relevant to welfare and social justice.

Bharatiya Nagarik Suraksha Sanhita, 2023

• Section 194 — police inquiry/report concerning specified deaths.
• Section 196 — inquiry by magistrate into cause of death in specified circumstances.

Disaster Management Act, 2005

• Section 12 — minimum standards of relief, including shelter, food, drinking water, medical cover and sanitation.

Protection of Human Rights Act, 1993

Human rights include rights relating to life, liberty, equality and dignity guaranteed by the Constitution or embodied in international covenants and enforceable by courts in India.

Current Position as of September 2026

The legally safest position is:

• The Supreme Court has not, on the material presently publicly accessible, held that the State of Manipur is liable for the 25 deaths.
• The Court’s intervention concerns obtaining information and examining the circumstances.
• The earlier 2023 judgement establishes a strong constitutional framework requiring dignified relief camps, medical care, rehabilitation, preventive measures and investigation.
• The Justice Gita Mittal Committee continued its work into 2026, having submitted 42 reports by January 2026, with its mandate regularised up to 31 July 2026.
• Separately, in January 2026, the Supreme Court directed the Committee to examine complaints of deficiencies in relief camps, including food, sanitation and medical facilities.
• The RTI data recording 731 deaths and 25 unnatural deaths provides important factual context, but the RTI classification itself is not a judicial finding of state negligence or criminality.

That distinction, in my view, is essential if this article is to withstand scrutiny from practising lawyers, judges, academics and serious readers.

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This article is a legal analysis based on publicly accessible judicial records, statutory material and reported official RTI disclosures. The factual circumstances and legal responsibility for individual deaths remain subject to investigation and judicial determination.

Frequently Asked Questions — Manipur Relief Camps Supreme Court Case

1. Why has the Supreme Court sought information about 25 unnatural deaths in Manipur relief camps?

The Supreme Court has sought details concerning 25 unnatural deaths of internally displaced persons (IDPs) in Manipur relief camps, including causes of death, post-mortem reports and information about preventive measures. The Court’s inquiry is significant from an Article 21, human rights and constitutional governance perspective because displaced persons remain entitled to protection of life and dignity.

2. What constitutional rights do internally displaced persons living in Manipur relief camps have?

Internally displaced persons living in Manipur relief camps continue to enjoy fundamental rights guaranteed by the Constitution of India, particularly Article 14 and Article 21. Displacement does not extinguish the right to life, personal liberty and human dignity. The Supreme Court has previously directed authorities to ensure adequate food, medical care, sanitation, psychological assistance and other basic necessities in relief camps.

3. Does an unnatural death in a Manipur relief camp automatically establish government negligence?

No. An unnatural death in a Manipur relief camp does not automatically establish state negligence or criminal liability. Each death must be examined on its facts. Post-mortem reports, police investigation, inquest proceedings, medical records and other evidence may be necessary to determine whether the death resulted from an accident, suicide, homicide, medical circumstances or another cause. The Supreme Court’s request for documentary material is therefore important for establishing the factual position.

4. What is the Supreme Court’s role in protecting the human rights of displaced persons in Manipur?

The Supreme Court has exercised continuing constitutional oversight over the Manipur violence, relief camps, rehabilitation and protection of internally displaced persons. Its earlier directions addressed medical treatment, food, sanitation, psychological care, compensation, investigation and dignified rehabilitation. The Court has also used institutional mechanisms, including the Justice Gita Mittal Committee, to examine grievances concerning relief and rehabilitation.

5. What legal remedies are available when the fundamental rights of persons in Manipur relief camps are violated?

Depending upon the facts, affected persons may pursue remedies under Article 32 of the Constitution before the Supreme Court or Article 226 before a High Court, apart from remedies available under criminal law, human-rights legislation and applicable compensation mechanisms. Where a serious and established violation of Article 21 is demonstrated, constitutional courts may, in appropriate cases, grant public-law relief, including compensation. The appropriate remedy depends upon the evidence, nature of the violation and circumstances of the individual case.

Key Takeaways: Manipur Relief Camps — Supreme Court Seeks Probe Into 25 Unnatural Deaths

Key Issue	What It Means
Supreme Court scrutiny of Manipur relief camps	The Supreme Court has sought information concerning 25 unnatural deaths of internally displaced persons (IDPs) living in relief camps and settlements in Manipur.
Post-mortem reports sought	The Court’s demand for post-mortem reports, causes of death and related records shifts the inquiry from general administrative assurances toward documentary and evidentiary scrutiny.
Article 21 and right to life	The issue directly engages Article 21 of the Constitution, which protects the right to life and personal liberty and has been judicially expanded to include the right to live with dignity.
Human rights of displaced persons	Internally displaced persons do not lose their constitutional rights merely because they have been forced from their homes. Their right to life, dignity, equality and access to justice continues in relief camps.
State’s positive constitutional duty	The case raises an important question about the State’s positive obligation to protect life, particularly where displaced citizens depend upon government authorities for shelter, food, healthcare, sanitation and security.
Medical care in relief camps	The Supreme Court’s earlier Manipur proceedings emphasised the need for adequate medical facilities, emergency treatment, psychological care and essential healthcare for displaced persons.
Unnatural death does not automatically mean negligence.	The classification of a death as “unnatural” does not by itself establish criminal liability or government negligence. Each death must be examined through post-mortem findings, investigation, inquest proceedings and other evidence.
BNSS provisions are relevant.	The Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), provides the statutory framework governing police inquiry and, in specified circumstances, magistrate inquiry into deaths requiring investigation.
Relief-camp standards have a statutory dimension.	The Disaster Management Act, 2005, recognises minimum standards of relief involving shelter, food, drinking water, medical cover and sanitation.
Supreme Court’s continuing supervision	The latest development forms part of the Court’s continuing constitutional oversight of the Manipur violence, relief, rehabilitation, investigation and protection of displaced persons, rather than representing an isolated proceeding.
Justice Gita Mittal Committee	The Supreme Court’s institutional mechanism headed by former Chief Justice Justice Gita Mittal has played an important role in examining issues concerning relief, rehabilitation and grievances of affected persons.
Relief is not rehabilitation.	The prolonged existence of Manipur relief camps raises a larger constitutional question: how long can temporary relief remain a substitute for permanent rehabilitation, livelihood, security and dignified restoration?
731 deaths require contextual understanding.	Reported official RTI data has identified 731 deaths among displaced persons living in relief camps and prefabricated settlements, while 25 were categorised as unnatural deaths. These figures should not be conflated.
Evidence will determine state accountability.	The central legal inquiry is not simply whether deaths occurred, but what the authorities knew, what legal and constitutional duties applied, what preventive measures were taken, and what the evidence establishes.
Separation of powers remains relevant.	While the Supreme Court can enforce fundamental rights, constitutional governance also requires judicial restraint. The Court must distinguish between setting enforceable constitutional standards and administering relief camps itself.
Potential wider constitutional implications	If the evidence reveals repeated or systemic failures involving medical care, safety, sanitation, security or investigation, the proceedings could raise broader questions concerning state accountability and Article 21 protection in situations of mass displacement.

Summary

The Supreme Court’s scrutiny of 25 unnatural deaths in Manipur relief camps raises significant questions concerning Article 21, human rights, state accountability, medical care and the constitutional protection of internally displaced persons. The Court’s demand for post-mortem reports and information on preventive measures places evidence-based accountability at the centre of the continuing Manipur relief and rehabilitation proceedings.

Primary Sources Worth Linking With the Published Article

• Supreme Court — Dinganglung Gangmei judgement, 7 August 2023 – https://api.sci.gov.in/supremecourt/2023/19206/19206_2023_1_7_45953_Judgement_07-Aug-2023.pdf
• Supreme Court — Anthony Naulak order, 19 January 2026 – https://www.sci.gov.in/sci-get-pdf
• Supreme Court — Manipur proceedings / Justice Gita Mittal Committee report, February 2026 – https://api.sci.gov.in/officereport/2023/19458/19458_2023_2026-02-26.pdf
• India Code — Bharatiya Nagarik Suraksha Sanhita, 2023 – https://www.indiacode.nic.in/indiacode/handle/123456789/20099
• India Code — Disaster Management Act, 2005 – https://www.indiacode.nic.in/bitstream/123456789/19269/1/dm_act_2005_english-1.pdf

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