Manipur High Court
State Of Manipur & 7 Ors vs Pheiroijam Heramani & 16 Ors on 16 April, 2026
Author: A. Guneshwar Sharma
Bench: A. Guneshwar Sharma
KHOIROM Digitally
KHOIROM
signed by
BIPINCHAN BIPINCHANDRA Item No. 2 - 12
SINGH
DRA SINGH Date: 2026.04.17
06:40:33 +05'30'
IN THE HIGH COURT OF MANIPUR
AT IMPHAL
MC(REVIEW PET.) No. 2 of 2026
State of Manipur & 7 Ors.
... Applicants
- Versus -
Pheiroijam Heramani & 16 Ors.
... Respondents
With MC(REVIEW PET.) No. 27 of 2025
With MC(REVIEW PET.) No. 28 of 2025
With MC(REVIEW PET.) No. 29 of 2025
With MC(REVIEW PET.) No. 3 of 2026
With REVIEW PET. No. 33 of 2025
With REVIEW PET. No. 34 of 2025
With REVIEW PET. No. 35 of 2025
With REVIEW PET. No. 37 of 2025
With REVIEW PET. No. 38 of 2025
With REVIEW PET. No. 39 of 2025
BEFORE
HON'BLE THE CHIEF JUSTICE MR. M. SUNDAR
HON'BLE MR. JUSTICE A. GUNESHWAR SHARMA
O R D E R
[M. Sundar, CJ]
16.04.2026
[1] Mr. R. Venkataramani, learned Attorney General for
India instructed by Mr. Kartikay Agrawal, learned counsel, Mr. Lenin
Hijam, learned Advocate General of Manipur instructed by Mr. O.
Ratankumar, learned State counsel, Mr. Dimalkumar Haobam,
learned State counsel, Mr. I. Amri, learned State counsel, Ms.
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Sharmila Rahman, learned State counsel, Mr. S. Chittaranjan,
learned Additional Advocate General of Manipur for State of Manipur
and Mr. Ch. Momon, learned standing counsel for State Election
Commissioner, Manipur are before this Court (Physical Court).
[2] Mr. HS. Paonam, learned senior counsel instructed by
Mr. A. Arunkumar, learned counsel on record for respondent Nos. 1,
2, 3 & 6 in Review Petition No. 33 of 2025, Ms. Ayangleima, learned
counsel on record for respondent Nos. 11 to 17 in Review Petition
No. 33 of 2025 and Mr. S. Biswajit, learned senior counsel instructed
by Mr. Sanatomba, learned counsel on record and Mr. H.
Pravirkumar, learned counsel on record for petitioners in Review
Petition No. 37 of 2025, Review Petition No. 38 of 2025 and Review
Petition No. 39 of 2025 are before this Court (Physical Court).
[3] Learned Attorney General for India continued and
concluded his submissions.
[4] The following 2 (two) points which are relevant to legal
drill at hand emerge:
(i) there is an amendment to ‘Manipur Panchayati
Raj Act, 1994 (26 of 1994)’ (‘said Act’ for the
sake of brevity and convenience). In and vide
this amendment 30 Sections i.e., Sections 110 to
139 have been added to the said Act and the
same have been slotted under Chapter – VI.
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These 30 Sections kicked in i.e. came into force
on or from 22.02.2023;
(ii) adverting to our earlier proceedings made in the
listing on 13.03.2026, more particularly
paragraph No. 5 thereat, learned Attorney
General for India on instructions submitted that
State Election Commissioner has since been
appointed vide an order dated 15.04.2024
bearing reference No. Com-3/2/2026/SEC-LAW.
A scanned reproduction of this order placed
before this Court is as follows:
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[5] The following 3(three) points unfurled in the hearing:
(i) as regards MC(REVIEW PET.) No. 2 of 2026 taken
out by State, learned Advocate General of
Manipur on instructions submitted that in limb No.
(iii) of the prayer the expression ’till the conduct
of fresh election’ is not being pressed and that
the same can be treated as deleted. This
submission is recorded and MC(REVIEW PET.) No.
2 of 2026 will now be considered on this basis;
(ii) adverting to sub-paragraph No. (x) of paragraph
No. 64 of order dated 29.08.2025 (order sought
to be reviewed), it was submitted by Mr. Ch.
Momon, learned standing counsel for State
Election Commissioner, Manipur that election for
local bodies will positively be conducted within 6
(six) months from today i.e. on or before
16.10.2026. In this regard, it was further
submitted by learned standing counsel that
elections will be so conducted as per amended
said Act more particularly the amendment qua
tiers (3 tiers). It was also submitted by learned
standing counsel for State Election Commissioner,
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Manipur that determination of elected members
as per Section 99 of the said Act would be done
on the basis of 2011 Census. This submission
made on instructions by learned standing counsel
for State Election Commissioner, Manipur is
recorded as a undertaking given to this Court. Be
that as it may, learned standing counsel
volunteered to file an affidavit of undertaking in
this regard;
(iii) adverting to sub-paragraph No. (xi) of paragraph
No. 64 of the order that is sought to be reviewed
i.e. common order dated 29.08.2025 in W.A. No.
9 of 2024, W.A. No. 10 of 2024 and W.A. No. 11
of 2024, learned Attorney General for India
submitted on instructions that as regards the
liberty given to State Government qua
appointment of Administrative Committees for
Gram Panchayats and Administrators for Zilla
Parishads inter-alia vide Sections 22 and 92
respectively of said Act, the State Government has
embarked upon the exercise and would complete
the exercise as expeditiously as possible.
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[6] As regards other aspects of the matter, adverting to
proceedings made on 15.12.2025, more particularly Paragraph No.
4 thereat, it was submitted by learned Attorney General for India
that though it was earlier submitted that the review is confined to
four Sub-paragraphs of Paragraph No. 64 namely, sub-paragraph
Nos. (viii) to (xi), it is now confined to sub-paragraph No. (x) besides
touching upon sub-paragraph No. (xi) which read as follows:
‘[64] In view of the above findings, observations and
directions, we hold and direct as follows:
i) ……………………………………………………………………
…………………………………………………………………..
…………………………………………………………………..
…………………………………………………………………..
ix) …………………………………………………………………..
x) The State Govt. is directed to conduct fresh election
within a period of 6 months.
xi) Till the next election is conducted as directed in para
(x) above, the State Govt. is at liberty to appoint fresh
Administrative Committee for the Gram Panchayat
and Administrator for Zilla Parishad in terms of the
provisions of Section 22, Section 92 and Section 109
of the Manipur Panchayati Raj, Act 1994 for a period
not exceeding 6 months.’
[7] After conclusion of submissions of learned Attorney
General for India and Mr. Ch. Momon, learned standing counsel for
State Election Commissioner, Manipur, Mr. HS. Paonam, learned
senior counsel instructed by Mr. A. Arunkumar, learned counsel on
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record very fairly submitted that with regard to conduct of elections
to local bodies within 6 (six) months from today about which there
is allusion elsewhere supra in this order, he is on the same page and
he supports the submissions made by learned standing counsel for
State Election Commissioner, Manipur and this submission is
recorded. To be noted, in this regard, Mr. S. Biswajit, learned senior
counsel instructed by Mr. Sanatomba, learned counsel on record
submitted that he also supports the submissions made by Mr. Ch.
Momon, learned standing counsel for State Election Commissioner,
Manipur and this submission is also recorded.
[8] Mr. HS. Paonam, learned senior counsel submitted that
with regard to the liberty given to State Government vide Sub-
paragraph No. (xi) of Paragraph No. 64 of the order sought to be
reviewed and the exercise which State Government has embarked
upon, he has some submissions to be made. Be that as it may,
learned senior counsel submitted that the review itself is not
maintainable and pressed into service oft quoted, celebrated
‘Padma Sundara Rao & Ors. -vs- State of Tamil Nadu & Ors.’
[(2002) 3 SCC 533] and adverted to paragraph 15 thereat
regarding cases on issues and as to when cases on issues which is a
construction principle can be supplied by Court. ‘Inderchand Jain
-vs- Motilal’ [(2009) 14 SCC 663] was also relied upon and
Page 7|8
paragraph 33 thereat was adverted to five principles propounded by
Hon’ble Supreme Court regarding review jurisdiction.
[9] Thereafter the learned senior counsel expressed
difficulty at his end in continuing submissions today/tomorrow and
requested for rescheduling the captioned matter to another date.
[10] In the next listing, the affidavit alluded to supra in this
order shall be filed by Mr. Ch. Momon, learned standing counsel for
State Election Commissioner, Manipur and Mr. HS Paonam, learned
senior counsel will continue and conclude his submissions followed
by Mr. S. Biswajit, learned senior counsel and reply, if any, on behalf
of State.
[11] List under cause list caption ‘PART HEARD’ on
28.04.2026.
JUDGE CHIEF JUSTICE
Bipin
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