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Three years on, justice eludes 2 Kuki-Zo women who were stripped, paraded, gang-raped in Manipur

March 15, 2026 6 min read Internal Security Social Issues GS2 GS3
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What Happened

  • Nearly three years after the Manipur ethnic violence began in May 2023, the two Kuki-Zo women who were stripped, paraded naked, and gang-raped on May 4, 2023, still await justice.
  • Three accused in the viral video case remain absconding; two others are out on bail; the bail application of another accused is pending before the Supreme Court.
  • A special CBI court (presided over by Justice Chatra Bhukhan Gogoi) has been conducting trial proceedings, with those on bail required to appear physically at hearings.
  • In a related case, a Kuki-Zo woman abducted and gang-raped at the age of 18 in the early days of the violence died on January 10, 2026, in a Guwahati hospital after suffering severe and irreversible injuries, including uterine damage and chronic infections — more than 500 km from her home in Manipur.
  • Amnesty International characterised her death as evidence of "systemic impunity for sexual violence in Manipur."

Static Topic Bridges

Manipur Ethnic Conflict — Background and Trigger

The Manipur ethnic violence began on May 3, 2023, triggered by a protest rally by tribal communities against a Manipur High Court order of April 14, 2023, that appeared to recommend Scheduled Tribe status for the dominant Meitei community. Unfounded rumours of Kuki-Zo attacks on Meiteis spread rapidly that evening, leading to widespread inter-community violence. The conflict has broadly pitted the Meitei community (predominantly valley-dwellers, around 53% of population) against the Kuki-Zo tribal communities (predominantly hill-dwellers, covered under Scheduled Tribe status).

  • The Meitei demand for ST status was the proximate cause; underlying tensions relate to land rights, poppy cultivation allegations, and political representation.
  • Kuki-Zo communities demanded a "Separate Administration" from May 18, 2023, onward, citing inability to coexist.
  • Manipur is under the Fifth Schedule (not the Sixth), meaning tribal areas are governed by the Governor's powers under Article 244(1) rather than Autonomous District Councils.
  • AFSPA (Armed Forces Special Powers Act 1958) was extended to parts of Manipur during the violence period; hill districts remain under AFSPA while valley districts had seen partial withdrawal prior to 2023.
  • The Supreme Court termed the situation an "absolute breakdown of law and order" and took up suo motu cognizance of the violence.

Connection to this news: The ongoing impunity in sexual violence cases reflects the deeper governance failure the Supreme Court flagged — when the state apparatus itself is seen as complicit or ineffective, survivors face near-insurmountable barriers to justice.

Supreme Court's Role in Monitoring Serious Crimes

The Supreme Court of India can take suo motu cognizance of matters involving gross violation of fundamental rights (Article 32) and can constitute Special Investigation Teams (SITs) or monitor CBI investigations directly. In the Manipur cases, the Supreme Court intervened in August 2023, ordered CBI investigation into multiple cases of sexual violence, and established a monitoring committee.

  • The Supreme Court has the power under Article 142 to pass any order necessary for complete justice.
  • In the Manipur sexual violence cases, the Court directed that trials be conducted in a designated special CBI court with CJM-level jurisdiction.
  • Cognizance of offences was taken under IPC Sections 376 (rape), 370 (trafficking), 307 (attempt to murder), and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.
  • The SC/ST (PoA) Act, 1989 provides for special courts, mandatory investigation within 30 days, and enhanced penalties for atrocities against SC/ST persons — particularly relevant for Kuki-Zo victims who hold ST status.

Connection to this news: Despite Supreme Court monitoring, the gap between judicial direction and ground-level enforcement remains stark — three accused are still absconding after nearly three years, pointing to failures in state police cooperation with CBI.

AFSPA and the Question of Accountability

The Armed Forces (Special Powers) Act, 1958 (AFSPA) grants armed forces personnel the power to search, arrest, and use lethal force in "disturbed areas" declared under Section 3 of the Act. Crucially, Section 6 of AFSPA requires prior sanction from the Central Government before any prosecution of armed forces personnel for actions taken under the Act, creating a near-absolute shield from prosecution.

  • AFSPA was originally enacted in 1958 for Northeast India; a separate version (AFSPA, 1990) covers Jammu and Kashmir.
  • "Disturbed area" status is declared by the Central Government or Governor under Section 3.
  • Section 4 of AFSPA empowers officers (even non-commissioned) to fire upon and kill in "disturbed areas" if "reasonably necessary."
  • Section 6's sanction requirement has been the primary mechanism through which accountability is blocked — courts have repeatedly held that prosecution without sanction is not maintainable.
  • The Supreme Court in Extra Judicial Execution Victim Families Association v. Union of India (2016) held that AFSPA does not grant blanket immunity and fake encounters can be prosecuted.
  • Manipur's hill districts remain "disturbed areas" under AFSPA; the ongoing ethnic conflict has intensified debate about whether AFSPA impedes justice for civilian victims.

Connection to this news: Though the perpetrators in the May 4 case appear to be non-state actors (civilian mob, not armed forces), the broader AFSPA environment and the culture of impunity it fosters in conflict zones create conditions where accountability for all forms of violence — including by civilians — is weakened.

SC/ST (Prevention of Atrocities) Act and Sexual Violence Provisions

The Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, with its 2015 amendment, specifically criminalises sexual assault on SC/ST women, provides for speedy trial in special courts, and mandates that the state provide rehabilitation to victims including housing, financial assistance, and legal aid.

  • Section 3(1)(w) of the PoA Act (inserted by 2015 amendment) specifically covers sexual assault on SC/ST women.
  • The Act shifts the burden of proof in certain circumstances and prohibits anticipatory bail in atrocity cases.
  • Special courts must be set up in each district for PoA trials; the judge must be of Sessions Court level.
  • Despite these provisions, the Manipur cases illustrate how the provisions remain aspirational when state-level enforcement cooperation is absent.

Connection to this news: The charges in the Manipur sexual violence cases include PoA Act sections — the failure to ensure speedy trial and prevent bail in some cases represents a failure of the mandatory provisions of this Act, which will likely be examined by the Supreme Court at the March 2026 hearing.

Key Facts & Data

  • Incident date: May 4, 2023 (viral video surfaced July 19, 2023)
  • Victims: Two Kuki-Zo women (aged approximately 44 and 21 at the time)
  • Case status (March 2026): 3 accused absconding, 2 on bail, 1 bail plea pending in Supreme Court
  • Special CBI court presided by Justice Chatra Bhukhan Gogoi
  • A third Kuki-Zo rape survivor died on January 10, 2026, in Guwahati hospital from injuries sustained during the violence
  • Manipur conflict has killed over 200 people since May 3, 2023, and displaced approximately 60,000
  • Manipur is a Fifth Schedule state (not Sixth Schedule) — no Autonomous District Councils
  • AFSPA remains in force in Manipur's hill districts
  • SC/ST (PoA) Act, 1989 (amended 2015) applies; Section 3(1)(w) covers sexual assault on ST women