Constitutional Structure and Decentralised Governance: Examining the Sixth Schedule within the Federal Framework of Hill Area Governance in Manipur
Dr. Elisheva Solomon Navgaonkar
Distinguished Fellow in Constitutional Jurisprudence, Centre for Constitutional Studies and Federal Governance, Mumbai, New Delhi and Tuensang, India.
Dr. Mungreishang Horam
Assistant Professor, Dept of Political Science, St. Joseph College, Ukhrul, Manipur. Director, Centre for North-East Development and Policy Research (CNEDPR), Ukhrul, Manipur, India.
Dr. Aniruddha Babar
Senior Academic, Writer & Researcher, Dept of Political Science, St Joseph college, Ukhrul, Manipur. Deputy Director, Centre for North-East Development and Policy Research (CNEDPR), Ukhrul, Manipur, India.
Jessica Raleng
Assistant Professor, Dept of Political Science, St Joseph college, Ukhrul, Manipur. Assistant Director, Centre for North-East Development and Policy Research (CNEDPR), Ukhrul, Manipur, India.
Thaichuingam Gonmei
Assistant Professor, Dept of Political Science, St Joseph college, Ukhrul, Manipur, India.
“Where administrative realities reveal structural pressures within existing statutory arrangements, constitutional design invites careful and disciplined examination. The Constitution provides institutional mechanisms through which differentiated regional conditions may be addressed through calibrated allocation of authority. Such constitutional calibration strengthens clarity of jurisdiction, fiscal responsibility and accountable decentralisation while preserving the sovereignty of the State and the Union within the federal framework of the Republic.”
The Constitution of India was conceived as a framework of governance for a society marked by plural histories, varied geographies and layered identities. Its architecture reflects a carefully calibrated balance within the federal design of the Republic. Institutional stability within a constitutional republic depends upon clarity in the allocation of authority and fidelity to established constitutional procedure. Administrative arrangements operating in particular regions must therefore be examined within the discipline of constitutional structure rather than through episodic policy responses alone. The constitutional enquiry concerning the hill districts of Manipur and the possible operation of the Sixth Schedule therefore invites measured consideration grounded in constitutional principle. Such consideration is informed not only by constitutional text but also by the institutional experience of decentralised governance across the North-Eastern states where the Sixth Schedule presently operates. In constitutional adjudication and scholarship alike, salus populi suprema lex-the welfare of the people is the supreme law-guides institutional design, while expressio unius est exclusio alterius reminds that powers expressly conferred define the boundaries of authority. Federal governance proceeds on the understanding that ubi jus ibi remedium, ensuring that authority remains enforceable through constitutional remedies. The Constitution does not contemplate fragmentation of authority but structured differentiation within unity. This constitutional philosophy recognises that diversity in geography, culture and administrative conditions may require differentiated institutional responses. The durability of the Indian constitutional order lies in its capacity to accommodate such variation while maintaining coherence in the federal structure. Decentralised governance must therefore be understood as a disciplined allocation of functions within the constitutional framework rather than a departure from it. Such allocation operates within constitutional continuity, federal equilibrium, democratic sovereignty and the basic-structure doctrine recognised by the Supreme Court of India.
The discussion that follows approaches this question through the lens of constitutional structure, institutional design and the federal balance contemplated by the Constitution. The enquiry therefore turns from constitutional principle to the institutional arrangements through which decentralised governance is organised. The examination that follows proceeds through the constitutional text, the institutional arrangements presently governing the hill areas of Manipur and the broader federal framework within which decentralised governance operates. Within this constitutional frame, the enquiry concerning Manipur’s hill districts turns on institutional structure and the defined allocation of authority. The Constitution provides mechanisms through which local governance may be organised within a coherent national framework. The Sixth Schedule forms part of this design. The constitutional foundation for the administration of such tribal areas is provided by Article 244 of the Constitution, which directs that the provisions of the Sixth Schedule shall apply to specified tribal regions in the North-Eastern states. Article 244 thus serves as the constitutional gateway through which the institutional framework of the Sixth Schedule operates within designated tribal areas of the region. Paragraph 2 of the Schedule provides for the constitution of Autonomous District Councils and Regional Councils in these areas, while subsequent provisions enumerate their legislative, administrative and limited judicial powers within defined constitutional boundaries. Paragraph 3 of the Sixth Schedule enumerates the legislative powers that may be exercised by these councils over specified subjects within their territorial jurisdiction. These powers operate within defined constitutional limits and remain subject to gubernatorial assent and constitutional supervision. In certain circumstances the Schedule also provides for the constitution of Regional Councils within Autonomous Districts, enabling more granular institutional representation where distinct tribal communities inhabit particular sub-regions. The Schedule represents an early constitutional experiment in territorially structured decentralisation within the Indian Union. The Sixth Schedule has historically functioned as one of the most distinctive constitutional innovations developed for governance in the North-Eastern region, representing a unique institutional experiment in territorially structured autonomy within a federal democratic framework. Its design reflects a careful attempt to balance tribal self-governance with constitutional supervision by the State and the Union. The authority so conferred operates under gubernatorial oversight and within the constitutional competence of Parliament. The legislative authority of the State Legislature continues to operate within the constitutional framework alongside these institutions, and interaction between state legislation and council regulations occurs within the distribution of competences defined under the Sixth Schedule.
The financial architecture of the Sixth Schedule further illustrates the structured nature of this constitutional arrangement. Paragraphs 7 and 9 of the Schedule provide for the establishment of District Council Funds into which revenues received by the councils may be credited and from which expenditure for authorised purposes may be made. The fiscal competence of Autonomous District Councils is further structured through the taxation powers recognised under Paragraph 8 of the Sixth Schedule. These provisions permit councils to levy and collect specified taxes within their jurisdiction including taxes on lands and buildings, tolls on persons, taxes on animals, vehicles and boats, and certain forms of trade and professional taxation. Although limited in scope, these powers introduce a measure of locally generated revenue that strengthens fiscal responsibility and administrative autonomy within the broader financial framework of the State. These provisions enable councils to exercise defined fiscal responsibilities within their jurisdiction while operating within broader financial oversight mechanisms of the State. Grants-in-aid from the Consolidated Fund of the State and other statutory allocations may supplement locally generated revenues. Such fiscal structuring reinforces administrative viability while maintaining coherence with the financial framework of the State.
Fiscal decentralisation within the Sixth Schedule framework also interacts with the broader system of intergovernmental fiscal transfers operating within the Indian Union. Recommendations of the Finance Commission under Article 280 and the devolution of central tax revenues to the states influence the fiscal environment within which Autonomous District Councils operate. While councils possess limited taxation powers and locally administered funds, their financial sustainability frequently depends upon structured transfers from state governments and centrally sponsored development programmes. Effective decentralised governance therefore requires institutional clarity not only in legislative competence but also in fiscal channels through which developmental resources reach district-level institutions. Such fiscal structuring operates within the broader architecture of constitutional governance in which financial decentralisation coexists with the continuing legislative authority of national institutions.
The constitutional arrangement established under the Sixth Schedule does not displace the broader legislative authority of Parliament within the constitutional scheme. Parliament retains the power to enact legislation in accordance with the distribution of legislative subjects contained in the Seventh Schedule, and such authority continues to operate alongside the powers conferred upon Autonomous District Councils. The institutional framework of the Sixth Schedule therefore represents a form of constitutionally structured decentralisation rather than a transfer of sovereign legislative competence. The coexistence of these authorities reflects the layered nature of India’s federal governance system.
Consideration of the Sixth Schedule within Manipur’s federal framework necessarily begins with constitutional procedure. The Sixth Schedule presently applies to tribal areas in Assam, Meghalaya, Tripura and Mizoram. Extension of its provisions to Manipur would proceed through amendment of the Constitution under Article 368. Such amendment requires a special majority in both Houses of Parliament. Ratification by half of the States would generally not arise in such circumstances, as the federal distribution of legislative powers remains unaffected. Upon amendment the districts specified would fall within the constitutional framework of the Schedule and the institutional structure would operate in accordance with its provisions. The amendment procedure prescribed under Article 368 embodies deliberation and constitutional discipline. Constitutional change occurs through parliamentary scrutiny, reasoned debate and formal enactment. Any restructuring under the Sixth Schedule therefore arises through a structured constitutional process. The resulting institutional arrangement derives authority from the Constitution itself and remains subject to judicial review before the Supreme Court and the High Courts under Articles 32 and 226 of the Constitution. Judicial oversight ensures that the exercise of authority by both state institutions and autonomous councils remains consistent with constitutional guarantees and the rule of law, forming an essential safeguard within the architecture of Indian constitutional governance. The supervisory jurisdiction of constitutional courts also reflects the broader constitutional doctrine that the federal structure forms part of the basic structure of the Constitution. Judicial interpretation has consistently recognised that institutional arrangements within the federal framework must operate in a manner compatible with constitutional principles, including the preservation of democratic governance, the rule of law and the distribution of powers between different levels of authority. In this context, decentralised institutions established under the Sixth Schedule function within a constitutional environment in which the courts remain empowered to ensure that all public authorities act within the limits prescribed by the Constitution.
With the procedural pathway clarified, attention turns to the content of the powers conferred. The powers vested in Autonomous District Councils under the Sixth Schedule are structured and enumerated. Councils may legislate on subjects including land management excluding reserved forests, village administration, inheritance, social customs and shifting cultivation. Their enactments require the assent of the Governor before acquiring legal effect. Provision also exists for limited judicial authority through village courts and district council courts in matters governed by customary law. Financial authority is defined through limited taxation powers and grants-in-aid. Law and order, including policing authority, remains vested in the State Government unless altered through constitutional amendment. The Schedule therefore establishes a supervised and defined form of decentralised governance operating within the constitutional structure of the Republic.
The constitutional role of the Governor occupies an important place within the functioning of the Sixth Schedule. Several provisions of the Schedule confer supervisory and regulatory responsibilities upon the Governor, including the power to assent to laws enacted by Autonomous District Councils, modify the application of certain provisions and constitute or reorganise administrative arrangements where necessary. These functions operate within the constitutional position of the Governor as a constitutional authority acting within the framework of the Constitution and the advice of the Council of Ministers except in matters where the Constitution provides otherwise. The presence of such supervisory authority ensures that decentralised governance operates within the discipline of the constitutional order.
The structural location of these powers within the constitutional text invites consideration of the broader federal framework established by the Constitution of India. India’s constitutional system is frequently described as a form of cooperative and asymmetrical federalism in which differentiated institutional arrangements are accommodated within a unified constitutional order. Such asymmetry is neither accidental nor exceptional within the constitutional scheme of the Indian Union. Rather, it forms part of a deliberate federal strategy through which the Constitution accommodates historical and regional particularities within a single sovereign framework. Within this constitutional logic the Sixth Schedule functions as a calibrated instrument of territorial autonomy within the Union. Operating under the enabling provisions of Article 244 it establishes Autonomous District Councils and Regional Councils endowed with legislative, executive, financial and limited judicial powers over specified subjects. These councils presently function in states including Assam, Meghalaya, Tripura and Mizoram where they exercise authority over enumerated fields such as land management, forest resources other than reserved forests, village administration, inheritance, social customs, shifting cultivation and certain forms of local taxation. Despite this decentralised distribution of authority the institutional arrangement remains firmly embedded within the constitutional structure of the Union. Laws enacted by Autonomous District Councils require the assent of the Governor before acquiring legal effect and the exercise of powers remains subject to constitutional scrutiny before the courts.
Within the constitutional framework of the Indian Union, the institutional arrangements contemplated under the Sixth Schedule do not compromise or challenge the territorial integrity of the State within which such councils operate. Introduced through Article 244(2) of the Constitution, the Sixth Schedule provides for the establishment of Autonomous District Councils and Regional Councils in certain tribal areas of the North-Eastern region, conferring upon them limited legislative, administrative and fiscal authority over specified local subjects. These powers generally relate to matters such as land management other than reserved forests, village administration, inheritance, social customs and shifting cultivation. The authority exercised by these councils operates within clearly defined constitutional limits and remains subject to institutional safeguards, including the requirement that laws enacted by the councils obtain the assent of the Governor before acquiring legal effect. At the same time, the broader executive authority of the State Government continues to extend over these areas, and core functions of governance such as law and order, policing, statewide development policy and territorial administration remain vested in the State. Consequently, the Sixth Schedule represents a constitutionally structured form of decentralised governance within the federal framework of the Republic rather than any alteration of the territorial sovereignty or constitutional integrity of the State concerned. Within this broader constitutional landscape decentralised institutions established under the Sixth Schedule may also be viewed through the lens of cooperative federalism. The constitutional structure of India does not envisage isolated spheres of authority operating without coordination; rather, it contemplates interlocking institutions functioning within a shared constitutional framework. Autonomous District Councils therefore operate alongside state administrative structures and national constitutional institutions, forming part of a layered governance system. Such coordination enables local participation in governance while ensuring that broader developmental planning, fiscal policy and constitutional supervision continue to operate within the federal framework of the Union.
Situated within this federal design, the constitutional framework governing Manipur assumes particular significance. The state presently operates under Article 371C of the Constitution of India introduced through the Constitution (Twenty-seventh Amendment) Act, 1971 in the context of Manipur’s transition to full statehood in 1972. At that time Parliament adopted a distinct constitutional approach through Article 371C rather than extending the Sixth Schedule, thereby integrating safeguards for hill areas within the structure of the State Legislature and executive oversight. Article 371C provides for the constitution of a Hill Areas Committee within the Manipur Legislative Assembly composed of members elected from the hill constituencies. The arrangement represents a legislative-centred model of institutional protection for the hill areas and operates through representation and oversight within the State Legislature rather than through territorially autonomous institutions. Complementing this arrangement the Manipur (Hill Areas) District Councils Act, 1971 established Autonomous District Councils as statutory institutions of district-level governance. In constitutional terms Article 371C and the Sixth Schedule represent two distinct mechanisms through which the Constitution addresses governance in tribal or hill regions, the former operating within the legislative framework of the State while the latter establishes territorially defined institutions of autonomous administration.
The institutional role of the Hill Areas Committee under Article 371C further illustrates the legislative-centred model presently operating in Manipur. The Committee is composed of members of the Legislative Assembly elected from the hill constituencies and functions as a specialised deliberative body within the State Legislature. Under the constitutional scheme and the accompanying Presidential Order relating to the administration of hill areas in Manipur, certain categories of legislation affecting the hill districts are required to be referred to the Committee for consideration before enactment. The Governor is also entrusted with a special responsibility to ensure that the administration of the hill areas proceeds in accordance with these constitutional safeguards. While this mechanism introduces an element of institutional protection within the legislative process, its operation remains dependent upon the broader structures of the State Legislature and executive administration rather than upon territorially autonomous institutions vested with constitutionally defined legislative authority.
Within the institutional framework of Manipur the functioning of district-level governance under the Manipur (Hill Areas) District Councils Act, 1971 has revealed structural limitations that have periodically generated debate regarding the adequacy of the existing arrangement. Unlike councils constituted under the Sixth Schedule these district councils derive their authority from ordinary state legislation and remain subject to alteration through legislative procedure. The distinction between statutory and constitutional authority becomes significant in questions of institutional continuity. Constitutional entrenchment provides greater stability by insulating institutional structures from frequent legislative alteration. Their legislative competence remains limited and their fiscal capacity modest relying largely on transfers from the State Government. Periodic disruptions in electoral cycles and phases of bureaucratic administration have also influenced institutional continuity and local democratic participation.
Beyond textual provisions, the administrative realities of the hill districts inform the discussion. The region is characterised by mountainous terrain and recurrent landslides that periodically disrupt essential transport corridors such as National Highway-37 affecting mobility supply chains and access to public services. The Tupul landslide of June 2022 highlighted the vulnerability of infrastructure corridors in these areas. These geographical conditions impose distinctive demands upon governance structures in the hill districts. In regions characterised by complex terrain and dispersed settlements, decentralised governance structures can facilitate infrastructure planning that is more closely aligned with local environmental conditions and settlement patterns. Administrative institutions operating in geographically remote and environmentally fragile regions often require greater proximity to local conditions in order to function effectively.
The practical implications of institutional design become particularly evident in fiscal governance. In November 2024 the Government of India sanctioned ₹104.66 crore for strengthening healthcare infrastructure in Manipur’s hill districts under the Prime Minister’s Development Initiative for North East Region, including the provision of super-speciality healthcare services. The project was to be implemented by the Government of Manipur through the Department of Health and Family Welfare. However, the impact of these initiatives remains scarcely visible on the ground. Fiscal allocations in geographically remote regions must therefore be accompanied by clear administrative channels of implementation. Institutional clarity ensures that developmental expenditure translates into tangible public services. The effectiveness of such allocations depends not merely on funding but on coherent institutional frameworks capable of ensuring implementation and accountability across multiple administrative levels.
Administrative coordination remains a further dimension of the enquiry. Under the existing statutory arrangement the State Government retains supervisory responsibilities concerning finance cadre deployment and coordination with district councils. Operation of the Sixth Schedule provides clearer allocation of functions within a defined constitutional structure. Clearly demarcated competences reduce administrative overlap and promote coherent policy execution. Enumerated subjects would be exercised by constitutionally recognised district institutions within their defined jurisdiction subject to gubernatorial oversight and judicial review.
The institutional framework contemplated under the Sixth Schedule may also serve to strengthen the administrative effectiveness of the State Government by facilitating a structured form of decentralised governance in regions characterised by complex terrain and diverse social institutions. By entrusting Autonomous District Councils with defined responsibilities over certain local matters, the constitutional arrangement enables governance functions relating to customary land management, village administration and local social practices to be addressed closer to the communities concerned. Such decentralisation can assist the State Government in ensuring more responsive administration and more effective implementation of development programmes in the hill districts while allowing the Government to concentrate on broader responsibilities of state-wide policy, infrastructure development, economic planning and law and order. At the same time, the authority of the State Government remains fully preserved, as the councils operate within the constitutional framework of the State and their enactments require the assent of the Governor. In this manner, the Sixth Schedule framework may function as a supportive institutional mechanism that complements the role of the State Government, strengthens cooperative governance and enhances the capacity of the State to deliver development and public services across all regions of Manipur.
Institutional clarity also carries democratic implications. Authority conferred directly by the Constitution carries defined responsibility to the electorate within the district jurisdiction. Decentralised institutions enable governance decisions to be taken closer to the communities directly affected by them. Such proximity strengthens participatory accountability and enhances the responsiveness of public administration. Legislative competence exercised under constitutional mandate operates within a transparent framework of review assent and oversight while preserving state-wide coherence.
Administrative stability fosters public confidence. Predictable allocation of authority clarity in fiscal responsibility and defined jurisdiction contribute to effective governance. The Constitution provides mechanisms through which differentiated governance may be accommodated within the federal framework. The Sixth Schedule represents one such mechanism. The operation of such a framework would necessarily continue within the constitutional authority of the State Government whose responsibilities for law and order state-wide planning and administrative coordination remain integral to the functioning of the federal system.
Within India’s federal framework, state governments play a central role in strengthening governance and development through sustained administrative efforts, public policy initiatives and programmes aimed at improving infrastructure, connectivity, healthcare services and public welfare. State governments continues to bear primary responsibility for maintaining law and order, coordinating development planning and ensuring equitable delivery of public services across diverse geographical areas. In the context of ongoing discussions concerning decentralised governance in the hill districts, any institutional arrangement would necessarily operate in close partnership with the State Government and under its broader policy direction. The administrative experience and coordinating authority of the State remain essential for aligning local governance institutions with state-wide development priorities and ensuring that decentralised mechanisms contribute to stability, balanced regional development and effective public administration.
The foregoing examination situates the question of decentralised governance in Manipur within the discipline of constitutional design and sustained institutional analysis. In a federation as vast and diverse as India, institutional arrangements operate as structured mechanisms through which governance responds to complex social, geographical and historical realities. Administrative systems that recognise these realities strengthen public confidence and deepen the relationship between citizens and institutions of the State. Constitutional design therefore functions as a stabilising framework through which differentiated governance arrangements develop in an orderly and disciplined manner. Article 244 of the Constitution establishes such a framework for the administration of tribal areas, under which the Sixth Schedule provides for Autonomous District Councils and Regional Councils in certain tribal regions of the North-Eastern states. These councils exercise limited legislative, administrative and financial authority over specified local subjects including land management other than reserved forests, village administration, inheritance of property, social customs and shifting cultivation. Laws enacted by these councils receive the assent of the Governor before acquiring legal effect, ensuring constitutional supervision within the federal structure. This institutional design reflects the capacity of the Indian federal system to accommodate diverse administrative realities within a unified constitutional order and advance the broader objectives of social justice and constitutional justice. In regions characterised by mountainous terrain, dispersed settlements and administrative remoteness, decentralised governance arrangements bring governance closer to the doorstep of citizens living on the geographical and administrative periphery and strengthen participatory administration consistent with the principles of natural Justice.
The constitutional framework simultaneously preserves the integrity of the State within the federal structure of the Union. Autonomous districts established under the Sixth Schedule remain within the executive authority of the State Government. Core functions of governance including law and order, policing, state-wide development policy and territorial administration remain vested in the State. Decentralised institutions operate as complementary mechanisms within the broader constitutional authority of the State and strengthen coordinated governance across different administrative levels. The constitutional architecture of India demonstrates a durable capacity to reconcile unity with diversity through principled institutional design. Constitutional mechanisms applied with clarity and discipline reinforce democratic legitimacy and strengthen the institutional foundations of the Republic. The ultimate question before any constitutional system concerns the condition of the ordinary citizen. The welfare of the common man stands at the moral centre of constitutional justice and the idea of India itself. Institutions derive legitimacy through their capacity to reach the lives of citizens who reside far from administrative centres and at the margins of governance. Through such calibrated arrangements the constitutional system sustains a governance framework that advances social justice, strengthens democratic accountability and promotes inclusive development while safeguarding both the integrity of the states and the unity and sovereignty of the Republic.
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