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President's rule revoked in Manipur, Khemchand to be sworn in as new CM at 6 pm today

February 04, 2026 5 min read Polity & Governance GS2 (Polity Constitutional Provisions Centre-State Relations)
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What Happened

  • President Droupadi Murmu revoked President's Rule in Manipur on February 4, 2026, with immediate effect under Article 356(2) of the Constitution.
  • The revocation followed the successful formation of a new government by the BJP under Y. Khemchand Singh (also referred to as Yumnam Khemchand Singh), who was sworn in as Chief Minister.
  • President's Rule had been imposed in Manipur on February 13, 2025 — following the resignation of Chief Minister N. Biren Singh, who faced sustained criticism for the handling of the ethnic conflict between Meitei and Kuki-Zo communities that erupted in May 2023.
  • This was the 11th instance of President's Rule in Manipur — the highest count for any Indian state.
  • The revocation proclamation was issued on February 4, 2026, approximately one year after imposition.

Static Topic Bridges

Article 356 — President's Rule (Constitutional Emergency in States)

Article 356 of the Constitution empowers the President to assume the functions of a state government if the Governor reports (or the President is otherwise satisfied) that the constitutional machinery in the state has failed. It is popularly called "President's Rule" or "State Emergency."

  • Article 356(1): President issues a proclamation of state emergency on the basis of Governor's report or otherwise, if satisfied that state government cannot carry on in accordance with the Constitution.
  • Article 356(2): The proclamation can be revoked by a subsequent Presidential proclamation at any time — revocation does not require Parliamentary approval (unlike imposition, which requires Parliamentary approval within 2 months under Article 356(3)).
  • Duration: Initial proclamation lasts 2 months; can be extended by Parliament for 6 months at a time, up to a maximum of 3 years (with special conditions after 1 year — Article 356(4) and (5)).
  • Article 357: During President's Rule, Parliament can confer on the President the power to make laws for the state; laws made by Parliament or President for the state continue even after revocation until repealed.
  • Parliamentary approval: Both Houses must approve the proclamation within 2 months by simple majority. Unlike financial and national emergencies, no special majority is required for approval.
  • Manipur's 11th President's Rule is the highest for any state — a reflection of its recurring political instability and ethnic conflict history.

Connection to this news: The revocation on February 4, 2026, invoked Article 356(2) — the President can revoke President's Rule unilaterally without Parliament, making this constitutionally straightforward once a majority government is formed.

S.R. Bommai v. Union of India (1994) — Judicial Safeguards Against Misuse of Article 356

S.R. Bommai v. Union of India [(1994) 3 SCC 1] is the most consequential Supreme Court judgment on Article 356. A nine-judge constitutional bench held that the imposition of President's Rule is subject to judicial review and that a floor test in the Legislative Assembly is the only constitutionally valid method to determine majority.

  • Background: S.R. Bommai was Chief Minister of Karnataka when the Janata Dal government was dismissed by the Governor (1989) and President's Rule imposed, based on alleged defections — without any floor test.
  • Ruling on Judicial Review: The Court held that the Presidential Proclamation under Article 356(1) is not immune from judicial review; it can be examined on grounds of mala fide exercise of power, lack of any relevant material, or irrelevant considerations.
  • Floor Test Mandate: The Court categorically held that the Governor cannot decide a government's majority subjectively; only an Assembly floor test can determine it — this prevents pre-emptive imposition of President's Rule.
  • Secularism: The Court held that a state government acting against constitutional values (including secularism) can be dismissed — but the bar is high and judicial review remains available.
  • Impact: The judgment effectively curtailed the arbitrary use of Article 356 by the Centre. Between 1950 and 1994, President's Rule was imposed over 90 times; incidence fell sharply after the Bommai judgment.
  • A related protective mechanism: if a no-confidence motion is pending in a state assembly, the Governor cannot recommend President's Rule until the motion is decided on the floor.

Connection to this news: The Manipur floor test (conducted on February 6, 2026, after the new government was formed) directly follows the Bommai precedent — the floor of the House, not the Governor's subjective assessment, is the constitutional test of majority.

Tenth Schedule — Anti-Defection Law and Legislative Stability

The formation of the Manipur government involved coalition dynamics and the role of Kuki-Zo MLAs — making the Tenth Schedule (Anti-Defection Law) relevant as a static concept.

  • Tenth Schedule: Inserted by the 52nd Constitutional Amendment Act, 1985 — provides for disqualification of members of Parliament and state legislatures on grounds of defection.
  • Disqualification triggers: (a) Voluntarily giving up party membership; (b) Voting contrary to party directions without prior permission; (c) Abstaining from voting against party direction.
  • Exception (Para 4): A merger of at least two-thirds of the legislative party with another party does not attract disqualification.
  • Decision-maker: The Speaker (or Chairman) of the House decides disqualification — this decision is subject to judicial review (Kihoto Hollohan v. Zachillhu, 1992).
  • Relevance to Manipur: The Kuki-Zo community demanded a separate Union Territory — some Kuki-Zo MLAs joined the new government despite a "Lungthu Resolution" of their political body opposing participation. The Tenth Schedule is relevant where MLAs vote against party/community mandates.
  • The Kuki-Zo Council threatened a social boycott of MLAs who joined the government, raising questions about the interplay between community mandates and constitutional obligations of elected representatives.

Connection to this news: The floor test passed with the absence of Kuki-Zo MLAs from the House physically — raising constitutional questions about the nature of "participation" in parliamentary proceedings and the limits of community boycotts on elected legislators' constitutional duties.

Key Facts & Data

  • President's Rule in Manipur imposed: February 13, 2025; revoked: February 4, 2026
  • Constitutional basis: Article 356 (imposition), Article 356(2) (revocation)
  • New Chief Minister: Y. Khemchand Singh (BJP); sworn in February 4, 2026
  • Manipur has had President's Rule 11 times — highest for any Indian state
  • Ethnic conflict background: Meitei-Kuki-Zo violence began May 2023; over 200 deaths reported
  • S.R. Bommai v. Union of India (1994) — 9-judge bench — landmark judgment on Article 356
  • 52nd Amendment Act, 1985 — inserted Tenth Schedule (Anti-Defection Law)
  • Maximum duration of President's Rule: 3 years (requires Parliament approval every 6 months after initial 2 months; after 1 year, special conditions under Articles 356(4) and 356(5) apply)
  • Article 356(3): Both Houses must approve proclamation within 2 months by simple majority
  • Article 357: Laws made during President's Rule continue until repealed even after revocation
  • Kuki-Zo community demand: separate Union Territory with legislature (UT-L status)
  • Floor test conducted: February 6, 2026 — government passed; Kuki-Zo MLAs not physically present