The United Naga Council (UNC) on 21 July 2026 submitted a petition to the Governor of Manipur, Ajay Kumar Bhalla, a Constitutional Petition invoking the Doctrine of Constitutional Morality for the immediate dismissal of Nemcha Kipgen, Hon’ble Deputy Minister of Manipur from the Council of Ministers due to an irreconcilable structural conflict of interest.
The petition reads, “the United Naga Council (UNC) submits this formal constitutional petition to your esteemed office in your capacity as the Constitutional Head of the State of Manipur. We are compelled to bring to your immediate attention a severe and continuing subversion of the Constitution of India, specifically regarding a paramount conflict of interest within the highest echelons of the State Cabinet that is currently paralyzing the administration of criminal justice.
“In continuation of our unanswered memorandum dated June 12, 2026, addressed to the Hon’ble Chief Minister, which failed to elicit executive rectification, we now escalate this crisis to you. This petition formally requests the invocation of your constitutional prerogatives under Article 164(1) of the Constitution of India to remove Mrs. Nemcha Kipgen from the office of Deputy Chief Minister on the strict legal grounds of institutional compromise and the breach of Constitutional Morality.
I. THE FACTUAL AND STATUTORY MATRIX (The UA(P)A Trigger)
The law enforcement apparatus of Manipur is currently investigating a series of premeditated abductions and subsequent extrajudicial killings of six unarmed Naga civilians that occurred on May 13, 2026, at Leilon Vaiphei village.
TERRORIST ACTS: These offenses are formally registered under Zero FIR No. 00(7)(5)2026 SEK-PS, subsequently transferred as FIR No. 23(5)2026-GSPM-PS. The investigating agencies have explicitly invoked Section 16(1)(b) of the Unlawful Activities (Prevention) Act [UA(P)A), officially classifying these acts as terrorism.
THE PERPETRATORS: The primary accused organization executing these UA(P)A offenses is the Kuki National Front -President Group (KNF-P), operating under the umbrella of the United Peoples’ Front (UPF).
II. THE STRUCTURAL CONFLICT OF INTEREST
The integrity of the state’s executive and investigative machinery is fundamentally nullified by an undeniable farnilial and operational nexus at the Cabinet level.
THE COMMAND STRUCTURE: The Chairman of the UPF and President of the KNF-P -the exact organization legally implicated in the aforementioned UA(P)A FIR-is Mr. ST Thangboi Kipgen.
THE CABINET NEXUS: Mr. ST Thangboi Kipgen is the spouse of Mrs. Nemcha Kipgen, the sitting Deputy Chief Minister of Manipur.
THE JURISDICTIONAL OVERLAP: The jurisdictional domain where these acts of terror and abductions were orchestrated falls directly within her political constituency and administrative sphere of influence.
III. SUBVERSION OF CONSTITUTIONAL OATH AND MORALITY
Under the Third Schedule of the Constitution of India, a Minister swears an oath to “do right to all manner of people in accordance with the Constitution and the law, without fear or favour, affection or ill-will
INVESTIGATIVE PARALYSIS: It is a foundational tenet of jurisprudence that the State Police and allied intelligence agencies cannot conduct an impartial, unhindered investigation into a designated narco-terrorist organization when the spouse of the organization’s supreme commander holds the office of the Deputy Chief Minister.
BREACH OF TRUST: Her continuation in a Cabinet role constitutes a direct structural conflict of interest. It provides institutional shield to the KNF-P, thereby subverting the rule of law, undermining the National Investigation Agency’s (NIA) operational independence within the state, and entirely eroding public trust in the democratic apparatus.
IV. PRAYER FOR CONSTITUTIONAL ACTION
The Doctrine of Constitutional Morality dictates that individuals holding high public office must be entirely free from conflicts that jeopardize the security of the state and the fundamental rights of its citizens. The presence of Mrs. Nemcha Kipgen in the Council of Ministers is legally and morally irreconcilable with an active UA(P)A investigation into her spouse’s organization.
Because the executive head of the state has failed to rectify this constitutional breakdown following our June 12, 2026, submission, the United Naga Council formally petitions your office to:
1. Exercise your constitutional discretion under Article 164(1) of the Constitution (wherein Ministers hold office during the pleasure of the Governor) to secure the immediate dismissal of Mrs. Nemcha Kipgen from the Council of Ministers.
2. Restore the constitutional machinery of the state, enabling a free, fair, and politically uncompromised investigation into the UA(P)A-designated murders of the six Naga civilians.
3. Further, reiterate for expediting the addressal of the UNC Charter of Demands dated June 12, 2026.
“We rely upon your office to uphold the sanctity of the Constitution and secure justice for the aggrieved” stated the petition signed by NG. Lorho, President, UNC and Vareiyo Shatsang, General Secretary, UNC.
