Ref. No.72/WKZIC-GHQ/(Memo)/2023-26, Date: 22/01/2026
Petition–cum–Memorandum: Invoking Articles 21, 14, 15, 19, 244, 355 with Lifeline Routes and UT Consideration for Kuki-Zo Community
To,
Her Excellency,
The President of India
Rashtrapati Bhavan
New Delhi
Through:
The Hon'ble Prime Minister of India
South Block
New Delhi.
PETITION–CUM–MEMORANDUM
(Invoking Constitutional Responsibility of the 'Union of India' under Articles 21, 14, 15, 19, 244, and 355 of the Constitution in regards to BLOCKADE of KUKI-ZO LIFELINE ROUTES)
MOST RESPECTFULLY SHOWETH
That the Petitioners submit this Petition–cum–Memorandum to invoke the constitutional conscience and responsibility of the Union of India, in view of the continued and demonstrable failure of the State Government of Manipur to secure the fundamental rights of the minority Kuki-Zo community, as guaranteed under the Constitution of India.
That Article 21 of the Constitution of India imposes a positive, non-derogable obligation upon the State to protect the life and personal liberty of every citizen. The prolonged breakdown of law and order, the foreseeable nature of the violence, and the continued inability of the State Government of Manipur to provide effective and impartial protection to Kuki-Zo civilians constitute a grave breach of this constitutional duty, attracting State liability under public law and giving rise to a continuing constitutional wrong.
That the guarantee of equality before law and equal protection of laws under Article 14, read with Articles 15(1) and 15(2), stands gravely violated. The pattern of unequal deployment of security forces, selective enforcement of law, and differential access to relief, rehabilitation, and justice has rendered the Kuki-Zo community disproportionately vulnerable. Such unequal protection, whether by commission or omission, is constitutionally impermissible.
That the Kuki-Zo people constitute a numerically and politically vulnerable ethnic and tribal minority within the State of Manipur. The constitutional scheme—particularly Articles 19, 21, and 244, together with the protective principles underlying the Fifth and Sixth Schedules—imposes a heightened fiduciary responsibility upon the State to prevent dispossession, targeted violence, and demographic coercion against tribal communities. The destruction of villages, displacement from ancestral lands, and continued insecurity in tribal areas reflect a serious breach of this constitutional trust.
That the continued obstruction, insecurity, or de facto closure of essential road and transport corridors connecting Kuki-Zo inhabited areas has resulted in denial of access to food, medicines, healthcare, education, livelihoods, and humanitarian assistance, in violation of Articles 19(1)(d), 19(1)(e), and 21. The State's failure to ensure safe and continuous access to such lifeline routes constitutes unconstitutional deprivation of the right to life with dignity.
That under Article 355 of the Constitution, it is the duty of the Union Government to protect every State against external aggression and internal disturbance, and to ensure that the government of every State is carried on in accordance with the provisions of the Constitution. In the present situation, where the State of Manipur has repeatedly failed to ensure the protection, security, and humanitarian needs of the minority Kuki-Zo community, Article 355 empowers the Union to take necessary and proportionate measures to restore constitutional governance and protect fundamental rights, without prejudice to the sovereignty of the State.
That despite prolonged constitutional engagement and representations, the State has been unable to secure equal protection, governance, and dignified living conditions for the Kuki-Zo community. Such repeated failure makes the administrative arrangement structurally incapable of fulfilling constitutional obligations.
That where a State framework fails to secure fundamental rights, the Constitution provides alternative mechanisms, including consideration of a Union Territory with Legislature under Articles 2, 3, and 239A, to ensure governance consistent with equality, dignity, and effective protection of minority communities. The long-standing constitutional demand of the Kuki-Zo people for dignified coexistence as fellow citizens of India may thus be assessed as a constitutional remedy in the public interest.
That the Union of India bears the ultimate constitutional responsibility to ensure that governance in every part of the territory of India is carried on in accordance with the Constitution. Your Excellency, as the constitutional head and guardian of the Constitution, is vested with the authority and duty to ensure that no community is abandoned to insecurity, marginalization, or denial of equal protection of laws.
GROUNDS
* The failure to protect life, liberty, and dignity violates Articles 14, 15, 19, 21, and 244 of the Constitution;
* Obstruction or insecurity of lifeline routes constitutes unconstitutional deprivation of the right to life with dignity;
* The State's failure engages the Union's responsibility under Article 355 to ensure constitutional governance and protection against internal disturbances;
* Denial of equal protection and humanitarian access to a vulnerable minority constitutes a continuing constitutional wrong;
* Where existing arrangements fail, constitutional reorganisation under Articles 2, 3, and 239A is a recognised and permissible mechanism to secure equality, dignity, and governance;
* The Union of India is constitutionally obligated to ensure governance consistent with the basic structure, rule of law, and human dignity.
PRAYER
In view of the facts and grounds stated hereinabove, it is most respectfully prayed that Your Excellency may be pleased to:
• Cause immediate constitutional intervention to secure the life, liberty, equality, and dignity of the minority Kuki-Zo community in Manipur;
• Direct the Union Government to ensure the immediate, safe, and continuous opening of all essential Kuki-Zo lifeline routes, under adequate and neutral central security protection;
• Ensure that no obstruction—formal or informal—impedes the movement of civilians, essential commodities, medical supplies, and humanitarian assistance;
• Direct deployment of adequate, impartial central forces to guarantee equal protection of laws and secure humanitarian access;
• Ensure independent, impartial, and time-bound investigations into acts of violence, destruction, displacement, and obstruction of essential routes;
• Direct comprehensive relief, rehabilitation, and restitution, including safe return, reconstruction of habitations, and livelihood security;
• Invoke Article 355 powers, in a proportionate manner, to ensure that governance in Manipur is carried on in accordance with the Constitution, restoring public confidence and constitutional order;
In the alternative, and should the existing constitutional arrangement continue to fail in securing equal protection and dignified existence, be pleased to cause consideration, in accordance with the Constitution, of the creation of a Union Territory with Legislature ("Kukiland"), as a remedial measure to guarantee effective governance, equality, and dignity for the Kuki-Zo people.
"AND FOR THIS ACT OF CONSTITUTIONAL JUSTICE, HUMANITARIAN PROTECTION, AND NATIONAL INTEGRITY, THE PETITIONERS AS IN DUTY BOUND SHALL EVER PRAY".
Sd/-
(SAMUEL T. ZOU)
General Secretary
Sd/-
(DR.TS HAOKIP)
President
Place: Songpi/ Churachandpur,
Date:The 22nd January, 2026.
_____________________
ANNEXURE INDEX
Petition–cum–Memorandum: Invoking Constitutional Responsibility of the Union for Protection of the Minority Kuki-Zo Community in Manipur
Submitted to:
Her Excellency,
The President of India
Through:
The Hon'ble Prime Minister of India
Annexure A – Constitutional and Legal References
Sl. No. Description - Reference /Source - Purpose
A1: Article 21 – Right to Life and Personal Liberty; Constitution of India, 1950, Demonstrates State duty to protect life and liberty
A2: Article 14 – Equality before Law; Constitution of India, 1950, Supports claim of unequal protection to Kuki-Zo community
A3: Article 15(1), 15(2) – Prohibition of Discrimination; Constitution of India, 1950, Basis for legal claim against selective policing
A4: Article 19(1)(d), 19(1)(e) – Freedom of Movement and Residence; Constitution of India, 1950, Supports right to access lifeline routes
A5: Article 244, Fifth and Sixth Schedule Principles; Constitution of India, 1950, Demonstrates special fiduciary duty to tribal communities
A6: Article 355 – Union Duty to Protect States; Constitution of India, 1950, Justifies Union intervention to restore constitutional governance
A7: Articles 2, 3, 239A – Union Territory Consideration; Constitution of India, 1950, Supports alternative remedy of UT with Legislature
Annexure B – Evidence of Violence, Displacement, and Humanitarian Crisis
Sl. No. - Description - Reference /Source - Purpose
B1: Reports of armed attacks on Kuki-Zo villages; Local administration / police records /, community affidavits - Documents breach of law and order: .... (to be enclosed/ provide when required).
B2: Photographs of destroyed villages and property; Field documentation / NGO reports, Visual evidence of destruction and displacement: ...... (to be enclosed/ provide when required).
B3: Verified lists of displaced families; Relief camp records / local administration, Demonstrates scale of humanitarian crisis: ..... (to be enclosed/ provide when required).
B4: Medical emergency reports; Hospitals / health departments, Evidence of denial of access to healthcare – FULLY DENIED AS POSSIBLE AS THEY CAN.
B5: Relief and aid blockage reports; NGO / field documentation, Shows obstruction of essential supplies – FULLY BLOCKED AS POSSIBLE AS THEY CAN.
Annexure C – Lifeline Routes and Access Maps
Sl. No. - Route /Area - Reference /Source - Status /Issue
C1: Pre 3rd May 2023 - Lifeline Route; [Lamka, SONGPI (Churachandpur) to IMPHAL and headquarters of Chandel, Tengnoupal, Kamjong, Ukhrul, Kangpokpi, Noney, Tamenglong and Jiribam districts .......... route connecting Kuki-Zo villages, totally disrupted since the outbreak of Kuki Genocides by majority Meitei community, on the 3rd May 2023 till date] - Assam/Manipur Road & Transport Maps, Field Verification – to be made/ collected professionally by concerned Government department (s), to confirm - Fully blocked / restricted access.
C2: Post 3rd May 2023 - Lifeline Route - till date; [SONGPI- KANGGUI ROAD (Ccpur-Kangpokpi passing through Tolbung (Torbung), Nalon and Kukimun etc. of Churachandpur district, Joujangtek, Tupul, Dolang & Sangji etc. (Noney district); Kotlen, **Ireng Liangmai & **Makhan Liangmai of Kangpokpi district), the LIFELINE of KUKI-ZO community since the outbreak of Kuki Genocides in Manipur on the 3rd May 2023] – to be comfirmed by concerned - (Government department from Local administration / community mapping & Satellite / Google Maps) – FULLY BLOCKED AND ROADS CUT OFF IN DIFFERENT DIRECTIONS IN 3 LOCATIONS - Unsafe due to armed presence /ZUF(K), NSCN-IM & MEITEI MILITANTS probably at IRENG LIANGMAI Village /conflict zone.
C3: [Emergency medical corridor] Health Department / NGO reports Restricted / STATE CAPITAL (Imphal) inaccessible to Kuki-Zo community – CHURACHANDPUR DISTRICT HOSPITAL functional in THOUBAL (Meitei Area), and KANGPOKPI HOSPITAL, TENGNOUPAL-MOREH HOSPITAL almost neglected, no Renovations, no Upgradation and Kuki Area Hospitals intentionally leave out from SUPPER SPECIALITY HOSPITAL under PM-Dev INE Scheme.
C4: [Supply routes for food and essential commodities] Relief agencies / local authorities Obstructed /delayed – Concerned Government Department is requested to get information (s) from local adminstration / authorities.
C5: GIS-based map showing network of Kuki-Zo villages and connectivity - Assam Archives / Satellite imagery - Visual aid to support urgent opening of Lifeline Routes: Urgent humanitarian necessity as indicated below:
i) SONGPI-KANGGUI (Churachandpur-Kangpokpi) via Leimata-Joujangtek-Kotlen through SAIKUL via DONGSUM to LITAN to join State Highways.
ii) SONGPI-MOREH (Churachandpur-Moreh) via Teijang, Sanlup AR, Chakpikarong, Toupokpi and Chandel Bazar of CHANDEL district through Komlathabi and Thamlapokpi of TENGNOUPAL district .... joining National Highway 53 (NH 53) along Bongyang- Saivom-Tengnoupal upto SIBONG (Khudengthabi) to Moreh Hill Town.
Date: 22/01/2026 ,
Place: Songpi/Ccpur.
Sd/- (Samuel T. Zou)
Petition–cum–Memorandum: Invoking Articles 21, 14, 15, 19, 244, 355 with Lifeline Routes and UT Consideration for Kuki-Zo Community
To,
Her Excellency,
The President of India
Rashtrapati Bhavan
New Delhi
Through:
The Hon'ble Prime Minister of India
South Block
New Delhi.
PETITION–CUM–MEMORANDUM
(Invoking Constitutional Responsibility of the 'Union of India' under Articles 21, 14, 15, 19, 244, and 355 of the Constitution in regards to BLOCKADE of KUKI-ZO LIFELINE ROUTES)
MOST RESPECTFULLY SHOWETH
That the Petitioners submit this Petition–cum–Memorandum to invoke the constitutional conscience and responsibility of the Union of India, in view of the continued and demonstrable failure of the State Government of Manipur to secure the fundamental rights of the minority Kuki-Zo community, as guaranteed under the Constitution of India.
That Article 21 of the Constitution of India imposes a positive, non-derogable obligation upon the State to protect the life and personal liberty of every citizen. The prolonged breakdown of law and order, the foreseeable nature of the violence, and the continued inability of the State Government of Manipur to provide effective and impartial protection to Kuki-Zo civilians constitute a grave breach of this constitutional duty, attracting State liability under public law and giving rise to a continuing constitutional wrong.
That the guarantee of equality before law and equal protection of laws under Article 14, read with Articles 15(1) and 15(2), stands gravely violated. The pattern of unequal deployment of security forces, selective enforcement of law, and differential access to relief, rehabilitation, and justice has rendered the Kuki-Zo community disproportionately vulnerable. Such unequal protection, whether by commission or omission, is constitutionally impermissible.
That the Kuki-Zo people constitute a numerically and politically vulnerable ethnic and tribal minority within the State of Manipur. The constitutional scheme—particularly Articles 19, 21, and 244, together with the protective principles underlying the Fifth and Sixth Schedules—imposes a heightened fiduciary responsibility upon the State to prevent dispossession, targeted violence, and demographic coercion against tribal communities. The destruction of villages, displacement from ancestral lands, and continued insecurity in tribal areas reflect a serious breach of this constitutional trust.
That the continued obstruction, insecurity, or de facto closure of essential road and transport corridors connecting Kuki-Zo inhabited areas has resulted in denial of access to food, medicines, healthcare, education, livelihoods, and humanitarian assistance, in violation of Articles 19(1)(d), 19(1)(e), and 21. The State's failure to ensure safe and continuous access to such lifeline routes constitutes unconstitutional deprivation of the right to life with dignity.
That under Article 355 of the Constitution, it is the duty of the Union Government to protect every State against external aggression and internal disturbance, and to ensure that the government of every State is carried on in accordance with the provisions of the Constitution. In the present situation, where the State of Manipur has repeatedly failed to ensure the protection, security, and humanitarian needs of the minority Kuki-Zo community, Article 355 empowers the Union to take necessary and proportionate measures to restore constitutional governance and protect fundamental rights, without prejudice to the sovereignty of the State.
That despite prolonged constitutional engagement and representations, the State has been unable to secure equal protection, governance, and dignified living conditions for the Kuki-Zo community. Such repeated failure makes the administrative arrangement structurally incapable of fulfilling constitutional obligations.
That where a State framework fails to secure fundamental rights, the Constitution provides alternative mechanisms, including consideration of a Union Territory with Legislature under Articles 2, 3, and 239A, to ensure governance consistent with equality, dignity, and effective protection of minority communities. The long-standing constitutional demand of the Kuki-Zo people for dignified coexistence as fellow citizens of India may thus be assessed as a constitutional remedy in the public interest.
That the Union of India bears the ultimate constitutional responsibility to ensure that governance in every part of the territory of India is carried on in accordance with the Constitution. Your Excellency, as the constitutional head and guardian of the Constitution, is vested with the authority and duty to ensure that no community is abandoned to insecurity, marginalization, or denial of equal protection of laws.
GROUNDS
* The failure to protect life, liberty, and dignity violates Articles 14, 15, 19, 21, and 244 of the Constitution;
* Obstruction or insecurity of lifeline routes constitutes unconstitutional deprivation of the right to life with dignity;
* The State's failure engages the Union's responsibility under Article 355 to ensure constitutional governance and protection against internal disturbances;
* Denial of equal protection and humanitarian access to a vulnerable minority constitutes a continuing constitutional wrong;
* Where existing arrangements fail, constitutional reorganisation under Articles 2, 3, and 239A is a recognised and permissible mechanism to secure equality, dignity, and governance;
* The Union of India is constitutionally obligated to ensure governance consistent with the basic structure, rule of law, and human dignity.
PRAYER
In view of the facts and grounds stated hereinabove, it is most respectfully prayed that Your Excellency may be pleased to:
• Cause immediate constitutional intervention to secure the life, liberty, equality, and dignity of the minority Kuki-Zo community in Manipur;
• Direct the Union Government to ensure the immediate, safe, and continuous opening of all essential Kuki-Zo lifeline routes, under adequate and neutral central security protection;
• Ensure that no obstruction—formal or informal—impedes the movement of civilians, essential commodities, medical supplies, and humanitarian assistance;
• Direct deployment of adequate, impartial central forces to guarantee equal protection of laws and secure humanitarian access;
• Ensure independent, impartial, and time-bound investigations into acts of violence, destruction, displacement, and obstruction of essential routes;
• Direct comprehensive relief, rehabilitation, and restitution, including safe return, reconstruction of habitations, and livelihood security;
• Invoke Article 355 powers, in a proportionate manner, to ensure that governance in Manipur is carried on in accordance with the Constitution, restoring public confidence and constitutional order;
In the alternative, and should the existing constitutional arrangement continue to fail in securing equal protection and dignified existence, be pleased to cause consideration, in accordance with the Constitution, of the creation of a Union Territory with Legislature ("Kukiland"), as a remedial measure to guarantee effective governance, equality, and dignity for the Kuki-Zo people.
"AND FOR THIS ACT OF CONSTITUTIONAL JUSTICE, HUMANITARIAN PROTECTION, AND NATIONAL INTEGRITY, THE PETITIONERS AS IN DUTY BOUND SHALL EVER PRAY".
Sd/-
(SAMUEL T. ZOU)
General Secretary
Sd/-
(DR.TS HAOKIP)
President
Place: Songpi/ Churachandpur,
Date:The 22nd January, 2026.
_____________________
ANNEXURE INDEX
Petition–cum–Memorandum: Invoking Constitutional Responsibility of the Union for Protection of the Minority Kuki-Zo Community in Manipur
Submitted to:
Her Excellency,
The President of India
Through:
The Hon'ble Prime Minister of India
Annexure A – Constitutional and Legal References
Sl. No. Description - Reference /Source - Purpose
A1: Article 21 – Right to Life and Personal Liberty; Constitution of India, 1950, Demonstrates State duty to protect life and liberty
A2: Article 14 – Equality before Law; Constitution of India, 1950, Supports claim of unequal protection to Kuki-Zo community
A3: Article 15(1), 15(2) – Prohibition of Discrimination; Constitution of India, 1950, Basis for legal claim against selective policing
A4: Article 19(1)(d), 19(1)(e) – Freedom of Movement and Residence; Constitution of India, 1950, Supports right to access lifeline routes
A5: Article 244, Fifth and Sixth Schedule Principles; Constitution of India, 1950, Demonstrates special fiduciary duty to tribal communities
A6: Article 355 – Union Duty to Protect States; Constitution of India, 1950, Justifies Union intervention to restore constitutional governance
A7: Articles 2, 3, 239A – Union Territory Consideration; Constitution of India, 1950, Supports alternative remedy of UT with Legislature
Annexure B – Evidence of Violence, Displacement, and Humanitarian Crisis
Sl. No. - Description - Reference /Source - Purpose
B1: Reports of armed attacks on Kuki-Zo villages; Local administration / police records /, community affidavits - Documents breach of law and order: .... (to be enclosed/ provide when required).
B2: Photographs of destroyed villages and property; Field documentation / NGO reports, Visual evidence of destruction and displacement: ...... (to be enclosed/ provide when required).
B3: Verified lists of displaced families; Relief camp records / local administration, Demonstrates scale of humanitarian crisis: ..... (to be enclosed/ provide when required).
B4: Medical emergency reports; Hospitals / health departments, Evidence of denial of access to healthcare – FULLY DENIED AS POSSIBLE AS THEY CAN.
B5: Relief and aid blockage reports; NGO / field documentation, Shows obstruction of essential supplies – FULLY BLOCKED AS POSSIBLE AS THEY CAN.
Annexure C – Lifeline Routes and Access Maps
Sl. No. - Route /Area - Reference /Source - Status /Issue
C1: Pre 3rd May 2023 - Lifeline Route; [Lamka, SONGPI (Churachandpur) to IMPHAL and headquarters of Chandel, Tengnoupal, Kamjong, Ukhrul, Kangpokpi, Noney, Tamenglong and Jiribam districts .......... route connecting Kuki-Zo villages, totally disrupted since the outbreak of Kuki Genocides by majority Meitei community, on the 3rd May 2023 till date] - Assam/Manipur Road & Transport Maps, Field Verification – to be made/ collected professionally by concerned Government department (s), to confirm - Fully blocked / restricted access.
C2: Post 3rd May 2023 - Lifeline Route - till date; [SONGPI- KANGGUI ROAD (Ccpur-Kangpokpi passing through Tolbung (Torbung), Nalon and Kukimun etc. of Churachandpur district, Joujangtek, Tupul, Dolang & Sangji etc. (Noney district); Kotlen, **Ireng Liangmai & **Makhan Liangmai of Kangpokpi district), the LIFELINE of KUKI-ZO community since the outbreak of Kuki Genocides in Manipur on the 3rd May 2023] – to be comfirmed by concerned - (Government department from Local administration / community mapping & Satellite / Google Maps) – FULLY BLOCKED AND ROADS CUT OFF IN DIFFERENT DIRECTIONS IN 3 LOCATIONS - Unsafe due to armed presence /ZUF(K), NSCN-IM & MEITEI MILITANTS probably at IRENG LIANGMAI Village /conflict zone.
C3: [Emergency medical corridor] Health Department / NGO reports Restricted / STATE CAPITAL (Imphal) inaccessible to Kuki-Zo community – CHURACHANDPUR DISTRICT HOSPITAL functional in THOUBAL (Meitei Area), and KANGPOKPI HOSPITAL, TENGNOUPAL-MOREH HOSPITAL almost neglected, no Renovations, no Upgradation and Kuki Area Hospitals intentionally leave out from SUPPER SPECIALITY HOSPITAL under PM-Dev INE Scheme.
C4: [Supply routes for food and essential commodities] Relief agencies / local authorities Obstructed /delayed – Concerned Government Department is requested to get information (s) from local adminstration / authorities.
C5: GIS-based map showing network of Kuki-Zo villages and connectivity - Assam Archives / Satellite imagery - Visual aid to support urgent opening of Lifeline Routes: Urgent humanitarian necessity as indicated below:
i) SONGPI-KANGGUI (Churachandpur-Kangpokpi) via Leimata-Joujangtek-Kotlen through SAIKUL via DONGSUM to LITAN to join State Highways.
ii) SONGPI-MOREH (Churachandpur-Moreh) via Teijang, Sanlup AR, Chakpikarong, Toupokpi and Chandel Bazar of CHANDEL district through Komlathabi and Thamlapokpi of TENGNOUPAL district .... joining National Highway 53 (NH 53) along Bongyang- Saivom-Tengnoupal upto SIBONG (Khudengthabi) to Moreh Hill Town.
Date: 22/01/2026 ,
Place: Songpi/Ccpur.
Sd/- (Samuel T. Zou)
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