By Paudi Renta
With growing concerns over the protection of indigenous identity, land, culture and customary rights, the Inner Line Permit (ILP) system under the Bengal Eastern Frontier Regulation (BEFR), 1873, continues to remain relevant in the Northeast even more than 150 years after its introduction.
The need for a balanced implementation of the BEFR and ILP system—one that protects indigenous interests without unnecessarily restricting economic activity, tourism, investment and development—emerged as a central theme at a two-day national seminar on the BEFR 1873 organised by the Inner Line Regulation Commission of the Naga Students’ Federation (ILRC-NSF) at Town Hall, Dimapur, on August 28 and 29.
Speaking on the concluding day of the seminar, Nagaland Chief Minister Neiphiu Rio called for the balanced, effective and humane implementation of the ILP system, asserting that the BEFR must serve as a safeguard for Naga identity, land, culture and indigenous rights.
Rio said the BEFR provides a measure of protection by regulating entry into protected areas and shielding indigenous communities from unregulated external economic and demographic pressures.
At the same time, he stressed that Nagaland could not isolate itself from the rest of the country.
“Economic integration, urbanisation and migration are realities,” Rio said, emphasising the need to welcome legitimate investors, workers and businesses while ensuring that the interests of indigenous communities are protected.
He maintained that the BEFR remains necessary in Nagaland but cautioned that its implementation must be properly regulated to prevent harassment of other Indian citizens.
“Tribals, which comprise minority, need some protection,” he said.
Referring to the protective provisions of the BEFR, Rio said outsiders could not purchase immovable property such as land and buildings, while artefacts, antiques and other valuable items associated with traditional culture were also protected. He said violations could attract a fine of Rs 1,000 and imprisonment of up to one year.
While calling for judicious use of the BEFR, Rio warned that its misuse or abuse could ultimately undermine the very interests it was intended to protect. He also pointed out that the continuation of the BEFR was retained by the signatories to the 16-Point Agreement.
Dimapur and the changing ILP landscape
Rio said the ILP was introduced in Nagaland in 1963, while the Dimapur area was initially excluded as a non-tribal belt. Dimapur was subsequently declared a tribal belt in 1979 through a government notification.
His remarks come in the wake of the June 16, 2026 judgment of the Gauhati High Court, which upheld the extension of the ILP regime to Dimapur, Chümoukedima and Niuland. The court held that the BEFR, 1873, continues to have the force of law under Article 372 of the Constitution and rejected challenges based on Articles 14 and 19.
Rio described the judgment as a “victory” for Nagaland.
“We have given a cut-off year of 1963 but for Dimapur area up to Chumoukedima we may have to consider up to 1979,” he said.
He also said the state government was attempting to identify the different categories of Indian citizens who had settled in Nagaland. Employers, he said, would have to register non-Nagas coming to the state for work for the purpose of obtaining ILPs.
Rio acknowledged that mistakes made over the years had complicated the government’s efforts to regulate the system.
“We should not impose ILP on ILP holders. We are given protection and we should not think of isolating ourselves but complement one another and how to bring out the best practices,” he said.
Maintaining that Nagaland was rich in natural resources but continued to remain economically poor, Rio said it was time for Nagas to come together to resolve outstanding issues and make better use of the state’s resources.
He called for a forward-looking approach to development, connectivity and migration, stressing that urbanisation could not be avoided. The student community, tribal leaders and other responsible sections of society, he said, must collectively work towards overcoming the challenges.
Concluding his remarks, Rio said the ILP should not remain merely a regulatory mechanism but should become an effective instrument for protecting identity while enabling Nagas to move towards progress and prosperity.
Rights, identity and the Constitution
Speaking on “Fundamental Rights and the BEFR 1873: A Constitutional Correlation,” senior Supreme Court advocate Prashant Bhushan said Nagaland’s rich tribal cultures, languages, cuisine and traditions should be preserved and celebrated.
However, he cautioned that cultural preservation should not result in isolation from other communities.
A community with a strong cultural identity, he argued, should have little to fear from interaction with other cultures and could instead influence and enrich them. Cultural identities, he said, were not necessarily threatened by the mere presence of outsiders, but could come under pressure when outsiders acquired political power and used it to suppress indigenous cultural or religious practices.
Bhushan also pointed out that complete isolation was impossible in an era of rapid communication, mobility and economic interdependence.
On the constitutional dimension, he referred to Article 29, which protects the right of communities to conserve their language, script and culture, and Article 19, which guarantees citizens, subject to constitutional restrictions, the right to move freely throughout India and practise a profession.
He consequently questioned how the ILP system, which restricts entry into Nagaland and other states where the regime operates, should be reconciled with these fundamental rights.
On the question of indigenous land ownership, Bhushan suggested that restrictions on land purchase by outsiders could be retained while allowing greater social interaction and economic participation.
NSF seeks autonomous regulatory commission
Earlier, the Naga Students’ Federation submitted a representation to the Chief Minister seeking the constitution of an autonomous Inner Line Regulation Commission for Nagaland.
The NSF proposed that the commission be vested with adequate powers to formulate rules and regulations for the stringent and effective enforcement of the BEFR, 1873.
The representation further called for an autonomous institutional mechanism capable of taking decisions and introducing measures necessary for a robust, smooth and balanced implementation of the Inner Line Regulation.
The NSF assured the government of its fullest cooperation in implementing such a mechanism.
BEFR across the Northeast
During the technical sessions, Prof. Nani Bath of Rajiv Gandhi University, Arunachal Pradesh, spoke on “Enforcement of the BEFR 1873 in Arunachal Pradesh.”
Prof. Ch. Priyoranjan Singh of Manipur University spoke on “Enforcement of the BEFR 1873 in the State of Manipur,” while ILRC-NSF chairman Senchumo NSN Lotha spoke on “Enforcement of the BEFR 1873 in Nagaland.”
A presentation on “Enforcement of the BEFR 1873 in Mizoram: A Success Story” by Prof. Lallianchhunga of Mizoram University was read out at the seminar.
Senior Supreme Court advocate Shamona Khanna spoke on “The BEFR 1873: Protection and Safeguarding the Rights of the Hill Tribes.”
The seminar concluded with an epilogue on “The BEFR 1873: A Mainland Indian Perspective vis-à-vis the Constitutional Safeguards of Indigenous Peoples with Special Reference to Nagaland,” led by Prof. Shantanu Chakravarty of Cotton University, Assam.
The seminar sought to examine how a regulatory framework originating in the nineteenth century continues to operate within the constitutional, social, political and economic realities of contemporary India.
It also examined the continuing enforcement of the BEFR from legal and institutional perspectives and explored practical, legally sound and institutionally workable measures for strengthening the regulatory framework.
What is the Inner Line Permit?
The Inner Line Permit (ILP) is a special travel document required by Indian citizens from outside a state to enter and, depending on the applicable rules, stay in areas covered by the ILP regime. It is not a visa and does not apply to foreign nationals; the entry of foreigners is governed by separate laws and regulations. The ILP derives its legal basis from the Bengal Eastern Frontier Regulation, 1873, a colonial-era regulation that created the concept of an “Inner Line.”
The original regulation empowered the government to prescribe an Inner Line and prohibit certain persons from crossing it without a pass. The system emerged in the nineteenth century as part of the British administration of the eastern frontier, where the colonial government sought to regulate movement, settlement and commercial activity in areas inhabited by hill communities. The Inner Line consequently became both an administrative boundary and an instrument for controlling interaction between the plains and the frontier hills.
After Independence, the regulation was retained and adapted rather than abolished. Over time, its rationale evolved from a colonial frontier-management mechanism into an instrument associated with the protection of indigenous land, customary practices, culture and demographic interests.
The Union government has stated that the ILP system originated with the BEFR in 1873 and is subject to periodic review. It is currently in operation in Arunachal Pradesh, Manipur, Mizoram and Nagaland.
Manipur became the fourth state covered by the BEFR framework in December 2019, when the Union government extended the Regulation to the state. The Manipur government subsequently issued its ILP Guidelines, 2019, under Sections 2 and 4 of the BEFR.
The ILP therefore represents an unusual constitutional and administrative arrangement: it places a restriction on the movement of Indian citizens while operating within a broader framework of constitutional rights, state-specific protections and the historical circumstances of the Northeast.
Its contemporary relevance lies in the difficult balance between two legitimate but sometimes competing objectives—protecting indigenous identity, land and customary rights on the one hand, and ensuring mobility, economic integration, employment, investment and interaction among citizens on the other.
The recent debate in Nagaland, particularly following the extension of the ILP to Dimapur, Chümoukedima and Niuland and the Gauhati High Court’s June 2026 judgment upholding that extension, has brought this century-and-a-half-old regulatory framework back into sharp focus.
The larger question, therefore, is no longer simply whether the ILP should exist, but how a nineteenth-century frontier regulation can be implemented in the twenty-first century without turning protection into isolation or integration into dispossession.
(Paudi Renta is a Dimapur based senior journalist and Chief Contributor for TFM, Nagaland.)