The ruling marks a rare judicial reversal of a CBI closure report and reinforces the principle of constitutional accountability over executive immunity. It resonates with the Supreme Court’s earlier directives for transparent investigations into alleged extrajudicial killings in Manipur.
TFM Report
In a powerful judicial verdict that challenges the findings of the country’s premier investigative agency, a court in Manipur has ordered a full criminal trial against 17 personnel of the Central Reserve Police Force (CRPF) for the killing of 14 civilians during mass protests in 2001, rejecting a closure report filed by the Central Bureau of Investigation (CBI).
The Chief Judicial Magistrate (CJM) of Imphal West, Sorokhaibam Sadananda, termed the CBI’s conclusions “unsustainable” and highlighted severe procedural illegalities, including an orally issued curfew order and a pre-signed, blank requisition form for firing, in a scathing order that paves the way for a long-awaited trial in the 23-year-old case.
Day of Bloodshed and a Long Wait for Justice
The case stems from one of the darkest chapters in Manipur’s history. On June 18, 2001, the state was engulfed in violent protests against the extension of the ceasefire pact between the Government of India and the NSCN (IM) to areas “without territorial limits.” The move was perceived by the people of Manipur as a threat to the state’s territorial integrity.
During the agitations, which involved widespread clashes and arson, CRPF personnel opened fire on crowds at two key locations: the Southern Gate of the Raj Bhawan and near the Chief Minister’s Bungalow. The incidents resulted in the deaths of 14 civilians and injuries to many more.
The case re-gained national significance when the Supreme Court of India, in the EEVFAM vs Union of India case (2017-2018), directed the CBI to investigate a series of alleged extrajudicial killings in Manipur. Acting on this, the CBI’s Special Crime Branch re-registered the case in 2018 and took over the probe from the state police.
CBI’s Stance and the Families’ Fight-back
After its investigation, the CBI filed a closure report on August 17, 2020, exonerating the 17 accused CRPF personnel from the 81 and 121 Battalions. The agency contended that the force had opened fire to disperse an “unruly mob” that was attempting to storm the Raj Bhawan and the Chief Minister’s residence. The CBI claimed the firing was done in self-defence and in the discharge of official duties under valid requisition orders from an Executive Magistrate, and that there was no evidence to prove the force used was excessive.
This closure report was vehemently opposed by the families of the deceased and the Extra Judicial Execution Victim Families Association, Manipur (EEVFAM). They filed a “protest petition” alleging that the CBI had ignored the findings of the Upendra Enquiry Commission, which had earlier concluded that the firing was “indiscriminate and disproportionate.”
Court Exposes Critical Flaws in CBI Probe
After years of adjournments, the CJM’s court delivered its verdict on October 28, 2024, delivering a stinging rebuke to the CBI’s investigation. The court identified multiple critical inconsistencies and illegalities that the agency had overlooked:
Illegal Curfew Order: The court noted that the then-District Magistrate, Howdijam Imocha Singh, admitted to issuing the curfew order orally, which was only formalized in writing later. The court ruled this was procedurally illegal and violated Section 144 of the CrPC and Article 21 (Right to Life) of the Constitution.
Pre-Signed Firing Requisition: In a damning observation, the court highlighted the testimony of Executive Magistrate Md. Naziruddin Shah, who stated he had signed a blank requisition form for firing at 7:00 a.m. on June 18, 2001—hours before the actual violence unfolded. This, the court suggested, indicated premeditation.
Lack of Valid Written Orders: The court found that the CRPF personnel were not originally deployed for the security of the Raj Bhawan and had no valid written order under Section 130 of the CrPC authorizing the use of firearms.
Biased Investigation: The CJM criticized the CBI for relying solely on the statements of security personnel while ignoring civilian witnesses and the findings of the Upendra Enquiry Commission, rendering its conclusions “unsustainable and biased.”
The court categorically held that the CBI’s closure report lacked a sound legal and evidentiary basis, stating, “The investigation appears to have proceeded not as intended by the Hon’ble Apex Court. The closure is unsustainable as it overlooks vital contradictions and procedural violations.”
It further ruled that the accused could not seek protection under Section 197 CrPC (which requires sanction for prosecution) or the Armed Forces (Special Powers) Act (AFSPA), as their actions were neither lawful nor in the discharge of official duty.
The Path Forward for Justice
Taking cognizance of offences under Sections 302 (murder) and 34 (common intention) of the Indian Penal Code, the court ordered the registration of a criminal case against the 17 personnel, including Deputy Commandants Narinder Paul and Huidrom Premjit Meitei. The accused have been summoned to appear before the court on November 25, 2025, for committal proceedings.
The ruling marks a rare judicial reversal of a CBI closure report and reinforces the principle of constitutional accountability over executive immunity. It resonates with the Supreme Court’s earlier directives for transparent investigations into alleged extrajudicial killings in Manipur.
As the CJM powerfully stated in the order, “Judicial scrutiny is not an act of hostility against the State, but a reaffirmation of the Constitution’s supremacy over all instruments of coercive power.”
For the families who have waited for over two decades, the court’s order rekindles a fragile hope that justice for the victims of the 2001 firing may finally be within reach.