What Happened
- Justice Ajai Lamba, former Chief Justice of Gauhati High Court and the head of the three-member Judicial Commission of Inquiry probing the ethnic violence that erupted in Manipur on May 3, 2023, resigned from his position citing "personal reasons."
- His resignation was formally accepted by the Central Government on February 26, 2026, effective February 28, 2026.
- The Central Government appointed Justice Balbir Singh Chauhan, a former Judge of the Supreme Court of India, as the new Chairperson of the Commission, effective March 1, 2026.
- The Commission is scheduled to submit its final report to the Central Government by May 20, 2026.
- The resignation raises questions about the pace and independence of the inquiry into one of India's most severe episodes of communal violence in recent decades, in which hundreds were killed, thousands displaced, and widespread arson and sexual violence were documented.
Static Topic Bridges
Commissions of Inquiry Act, 1952
The Commissions of Inquiry Act, 1952 (Act No. 60 of 1952) is the primary legislation enabling the Central or State Government to establish fact-finding commissions on matters of definite public importance. Such commissions are typically headed by sitting or retired judges of the Supreme Court or High Courts.
- Section 3: The appropriate government may, by notification in the Official Gazette, appoint a Commission to inquire into any definite matter of public importance.
- Section 4: Commissions have powers of a civil court for summoning witnesses, requiring document production, and receiving evidence on affidavit.
- Section 5: Governments may confer additional powers including seizure of documents.
- The Commission's report is not binding — it records findings and makes recommendations but has no power to enforce them or prosecute individuals.
- Section 8: Reports of Commissions of Inquiry are to be laid before each House of Parliament (if appointed by the Central Government) within six months of submission.
- A Commission under the Act is not a "judicial proceeding" in the strict sense — its findings cannot be used as evidence in criminal proceedings.
Connection to this news: The Manipur Commission was constituted under this Act in 2023. The leadership change mid-inquiry is legally permissible under the Act, but it risks disrupting institutional memory accumulated by the Commission over two years — particularly its knowledge of witness testimonies and documentary evidence.
Manipur Ethnic Violence 2023: Background and Constitutional Dimensions
The violence in Manipur beginning May 3, 2023 emerged from the intersection of tribal identity politics, land rights disputes, and demands for Scheduled Tribe (ST) status by the Meitei community. It pitted the predominantly valley-dwelling Meitei community against the Kuki-Zo tribal communities concentrated in the hill districts.
- The immediate trigger was a "Tribal Solidarity March" in hill districts on May 3, 2023, held in protest against the Manipur High Court's direction to consider granting ST status to Meiteis.
- The violence resulted in over 220 deaths, 60,000+ internally displaced persons (IDPs), and approximately 4,500 houses burned (as per government estimates by mid-2024).
- Manipur has a complex constitutional geography: the Imphal Valley falls under the general administration; hill districts have significant tribal autonomy through district councils established under the 6th Schedule of the Constitution (for Manipur Hill Areas).
- Article 355 of the Constitution obliges the Union to protect every State against internal disturbance — central security forces were deployed under this provision.
- The Supreme Court took suo motu cognizance of the violence in July 2023 and directed the Central and State Governments to submit compliance reports on relief and rehabilitation.
Connection to this news: The resignation of the inquiry commission's head and the appointment of a new chairperson less than three months before the report deadline raises concerns about whether a thorough, credible inquiry — essential for justice and long-term reconciliation — can be completed on schedule.
Judicial Commissions and Accountability in India
India has a long history of appointing judicial commissions to investigate major incidents of public concern — from the Sarkaria Commission (Centre-State relations, 1983) to the Liberhan Commission (Babri Masjid demolition, 1992–2009). Their effectiveness has been widely critiqued.
- Justice J.C. Shah Commission (1977): Inquired into excesses during the Emergency (1975-77) — its report formed the basis of subsequent legal actions.
- Liberhan Commission: Ran for 17 years before submitting its report in 2009 — widely cited as an example of inquiry fatigue.
- Justice B.N. Srikrishna Commission (1992): Inquired into Bombay communal riots after the Babri Masjid demolition — its report was not acted upon for over two decades.
- A key limitation is the absence of time-bound completion requirements in the Act itself; the 1952 Act has no statutory deadline for submission of reports.
- The National Commission for Women (NCW) and the National Human Rights Commission (NHRC) can be approached independently for cases involving sexual violence and human rights violations, which is significant given documented sexual violence in Manipur.
Connection to this news: The Manipur Commission's mid-tenure leadership change fits a pattern in which the credibility of such commissions is undermined by delays, resignations, and incomplete follow-through. The appointment of a former Supreme Court judge (Justice Chauhan) as replacement signals an attempt to restore institutional credibility.
Internal Security and Ethnic Conflict in the Northeast
The northeastern states of India present a unique internal security challenge due to the overlap of ethnicity, tribal identity, insurgency, and international boundaries. Manipur shares borders with Myanmar and has historically had a significant insurgent presence.
- Manipur has been under the Armed Forces (Special Powers) Act, 1958 (AFSPA) in varying geographic areas; AFSPA was progressively reduced in Manipur's valley districts in 2022 but retained in hill areas.
- The 6th Schedule of the Constitution (Article 244) provides for Autonomous District Councils in tribal areas of Assam, Meghalaya, Tripura, and Mizoram — but not Manipur, which is a source of grievance among Manipur's hill tribes.
- MGNREGS, PM-AWAS Yojana, and other central schemes have been disrupted in conflict-affected Manipur districts since May 2023.
- The Indo-Myanmar Free Movement Regime (FMR), which allowed residents within 16 km of the border to cross freely, was suspended by India in February 2023 — a context relevant to the ethnic conflict as cross-border movement of Kuki-Zo communities is a political flashpoint.
Connection to this news: The inquiry commission's work is not merely procedural — its findings will directly shape the state's reconciliation approach and any prosecution decisions. The leadership transition thus has implications for both justice delivery and long-term stabilization of a frontier state.
Key Facts & Data
- Manipur violence began: May 3, 2023.
- Commission constituted under: Commissions of Inquiry Act, 1952.
- Justice Ajai Lamba: Former Chief Justice, Gauhati High Court; resigned February 28, 2026.
- Justice Balbir Singh Chauhan: Former Judge, Supreme Court of India; appointed Chairperson March 1, 2026.
- Commission report deadline: May 20, 2026.
- Death toll (estimate): 220+ killed; 60,000+ displaced.
- Manipur borders: Nagaland, Assam, Mizoram (India); Myanmar (international).
- AFSPA status (as of 2026): In force in hill districts; withdrawn from valley districts in 2022.