Manipur Assembly Constitutional Deadlock

State Assembly: Manipur Legislative Assembly, 60 members.
Last Sitting: 12 August 2024.
Constitutional Requirement: Article 174(1) mandates that no more than six months may elapse between two sittings of a State Legislature.
Critical Date: The next session had to be convened on or before 11 February 2025.
Governor’s Action: On 9 February 2025, the Governor declared the summoning order null and void, cancelling the session.
Petitioner’s Relief Sought: Dissolution of the 12th Manipur Assembly under Article 174.
Judicial Response: Manipur High Court referred the matter to the Chief Justice for listing before a Division Bench, citing a substantial constitutional question.

The resignation of the Chief Minister in early February 2025 created a political vacuum.
The Governor, exercising discretionary powers, cancelled the scheduled assembly session just two days before the constitutional deadline.
The cancellation prevented a floor test that could have clarified the majority, paving the way for the central government to invoke President’s Rule under Article 356.

Federalism: The episode tests the balance between state autonomy and central authority, highlighting potential misuse of gubernatorial powers.
Constitutional Morality: It underscores the need for constitutional actors to adhere to both the letter and spirit of the Constitution.
Precedent: A judicial pronouncement on Article 174 could set a benchmark for future disputes involving the summoning, prorogation, and dissolution of state legislatures.
Political Stability: Unlawful dismissal of a duly elected assembly can erode public confidence in democratic institutions.

Article 174(1): Requires the Governor to summon the Legislative Assembly at least once every six months.
Article 174(2) & (3): Empower the Governor to prorogue or dissolve the Assembly.
Article 356: Allows the President to impose President’s Rule if the constitutional machinery in a state fails.
Article 163: Stipulates that the Governor shall act on the advice of the Council of Ministers, except in matters where the Constitution permits discretion.
Judicial Review: The High Court’s referral reflects the judiciary’s role in interpreting constitutional provisions and checking executive excess.