Manorama’s Tragedy: State-Sanctioned Violence in India’s Conflict Zones

In the early hours of July 11, 2004, soldiers from the 17th Battalion of India’s Assam Rifles paramilitary force knocked on the door of a home in Bamon Kampu village, Imphal East, Manipur. They took away 32-year-old Thangjam Manorama Devi, signing an arrest memo that officially acknowledged her detention. Hours later, her body was found abandoned on the roadside – bearing bullet wounds in her lower body, signs of torture, and evidence of sexual assault. No soldier was ever prosecuted. What followed was one of the most powerful and painful acts of political protest in modern Indian history – and a case that still defines the debate over state-sanctioned violence against women in conflict zones.

The night Manorama was taken 🔗

According to her family’s account, documented in detail by Human Rights Watch, Manorama was dragged from her home while clutching her mother, screaming “Ima Ima Khamu” – “Mother, mother, please stop them.” She was tortured on her own front porch as her family was forced to watch. The Assam Rifles claimed she was a member of the separatist People’s Liberation Army (PLA) and that she had been shot while trying to escape.

The official story immediately unraveled under scrutiny. The arrest memo signed by soldiers contained no incriminating items – a grenade and weapons were only mentioned afterward. Her body showed six to seven bullet wounds concentrated in the lower half of her body. No blood was found near the location where soldiers claimed she tried to flee. The inquiry commission later established that a 4-foot-11-inch woman could not have escaped 13 armed, well-trained soldiers – and that the claim was, in its own words, “unconvincing.” Human semen was found on her clothing. The Upendra Commission, set up by the Manipur state government, concluded plainly in its report: Manorama was tortured and murdered.

AFSPA and the architecture of impunity 🔗

To understand why no one was held accountable for Manorama’s death, you have to understand the Armed Forces Special Powers Act (AFSPA) – a law that critics, scholars, and international bodies have consistently called a vehicle for state impunity rather than security.

AFSPA was first enacted in 1958, modeled directly on a British colonial ordinance used in 1942 to suppress the Quit India Movement. It grants Indian security forces sweeping powers in regions declared “disturbed areas” by the central government. Under Section 4 of the Act, officers can arrest without a warrant, enter and search premises without consent, and use lethal force on the basis of reasonable suspicion alone. Crucially, Section 6 states that no prosecution or legal proceedings can be initiated against security personnel operating under AFSPA without prior sanction from the central government – a sanction that is almost never granted.

Manipur has been under AFSPA since 1980. When Manorama’s family sought justice, the Assam Rifles immediately invoked this legal shield. They petitioned the Guwahati High Court, arguing that no inquiry commission could investigate their personnel without central government permission. The inquiry’s report – which confirmed rape and murder – was suppressed for years. When the Supreme Court finally directed the government to pay ₹10 lakh in compensation to Manorama’s mother, it amounted to an institutional acknowledgement of a custodial killing – but no soldier was identified, charged, or punished.

A law that violates its own constitution 🔗

AFSPA has been challenged repeatedly on constitutional grounds. Rights activists and legal scholars argue it directly violates Article 21 (right to life and personal liberty) and Article 14 (equality before law) of the Indian Constitution. The UN Human Rights Committee has stated that Section 4 of AFSPA is incompatible with Articles 6, 9, and 14 of the International Covenant on Civil and Political Rights. The UN Special Rapporteur on Extrajudicial Executions, during a 2012 visit to India, called AFSPA a “hated” and “draconian” law that “has no role to play in a democracy” and “clearly violates international law.”

The Women’s International League for Peace and Freedom (WILPF) has argued that AFSPA’s immunity provision creates a structural culture of injustice – one in which victims and families have no meaningful avenue of redress. The Justice J.S. Verma Committee, formed after the 2012 Delhi gang rape, went further: it explicitly stated that AFSPA legitimizes impunity for sexual violence in conflict zones and recommended its immediate review. None of those recommendations were implemented.

The protest that shocked the world 🔗

On July 15, 2004 – four days after Manorama’s body was found – twelve middle-aged women gathered in front of the historic Kangla Fort in Imphal, the headquarters of the 17th Assam Rifles. They stripped off their clothes, held up banners made of white cloth painted in red, and stood there – naked, furious, and deliberate. The banners read: “Indian Army Rape Us” and “Take Our Flesh.”

It was not a spontaneous act of grief. It was a calculated, devastating confrontation with state power – using the very bodies the state had targeted as weapons of dissent. These women belonged to the Meira Paibi, meaning “women with bamboo torches,” a Manipuri women’s organization that had initially formed to address social problems like alcoholism and drug abuse. As armed conflict deepened in Manipur, the Meira Paibi evolved into a frontline resistance organization, mobilizing under an identity of collective motherhood – the Imas, or mothers – to challenge militarized violence.

The protest made national news and forced the state government to establish the Upendra Commission of Inquiry. It also led to the formation of Apunba Lup, a coalition of 32 civil society organizations that took the campaign for AFSPA repeal directly to then-Prime Minister Manmohan Singh in Delhi. The subsequent Jeevan Reddy Committee was set up to review AFSPA and ultimately recommended its repeal – a recommendation the government quietly shelved.

Irom Chanu Sharmila: the hunger striker 🔗

Manorama’s case was not the starting point of Manipuri women’s resistance to AFSPA – it was a flashpoint within a longer struggle. Since November 2000, Irom Chanu Sharmila had been on a continuous hunger fast demanding the repeal of AFSPA, initially sparked by the killing of ten civilians at a bus stop in Malom by Assam Rifles. She was repeatedly arrested under Section 309 of the Indian Penal Code – which criminalizes attempted suicide – and force-fed through a nasal tube for 16 years, making her one of the world’s longest hunger strikers. Together, Sharmila’s sustained personal resistance and the Meira Paibi’s collective actions illustrated the range and depth of women-led resistance to AFSPA – and the lengths the Indian state went to suppress it.

Feminist critique of state violence in conflict zones 🔗

Manorama’s case is not just a story about one woman’s murder. Feminist scholars read it as a case study in how state violence operates – and who it targets, and why.

In conflict zones, sexual violence against women is rarely incidental. It functions as a tool of domination – an attack not just on the individual, but on the community she represents. Scholars have noted that sexual violence in these contexts is used as an attack on the “collective honor” of communities, particularly those framed by the state as insurgent or suspect. When security forces rape women in conflict zones, they are communicating a message of power – that the bodies of women in these communities are available, accessible, and unprotected by law.

AFSPA makes this violence structural, not incidental. As feminist analysts have pointed out, the Act creates a “shroud of invisibility” – it removes legal accountability while simultaneously increasing military presence in already vulnerable communities. When perpetrators know prosecution requires central government sanction that will almost certainly never come, the law itself becomes an enabler. The impunity is not a bug in the system. For critics, it is the system.

The gendered logic of “disturbed areas” 🔗

The term “disturbed area” is itself a political construction. Feminist scholar Swati Parashar has argued that India’s “excessive militarism” in these regions reflects a postcolonial anxiety in which secessionist movements and ethnic conflicts are met with military suppression rather than political engagement. The logic of security – protect the nation from internal threats – consistently overrides the rights of the very civilians the state claims to protect.

Women bear a disproportionate cost in this logic. They are targeted by security forces as a method of punishing communities deemed threatening. They are then denied justice through legal immunity granted to those forces. And they are often erased from mainstream national discourse because their regions are geographically and politically peripheral. Feminist scholar Dolly Kikon, who conducted fieldwork in conflict-affected northeastern communities, describes the normalization of sexual violence as one of the most troubling outcomes of long-term militarization – a normalization so deep that survivors would give testimony of assault while simultaneously going about daily life, because the violence had become simply part of existence.

The state’s accountability gap 🔗

The structural accountability gap that AFSPA creates runs directly counter to India’s international commitments. India has ratified CEDAW (the Convention on the Elimination of All Forms of Discrimination Against Women) and has voted in support of UN Security Council Resolution 1325 on Women, Peace and Security – a resolution that affirms the importance of protecting women’s rights in conflict and including women in peace processes. Yet India’s domestic policies in its own conflict zones directly contradict these commitments. The gap between international advocacy and domestic practice is where women like Manorama fall – unseen, unprotected, unavenged.

In 2022, the Indian government partially withdrew AFSPA from some districts in Nagaland and the Northeast, citing improved security conditions. But Manipur, as of the most recent extensions, continues to be designated a disturbed area. For Manorama’s mother, Khumanleimai Devi, the ₹10 lakh payment from the Supreme Court was not justice – it was at most an admission. The soldiers who took her daughter have never been named. The case remains, formally, unresolved.

Why Manorama’s case still matters 🔗

More than two decades later, the case of Thangjam Manorama Devi remains a definitive reference point in Indian human rights discourse – not because it was unique, but because of the extraordinary resistance it unleashed. The Supreme Court’s own admission of a “custodial killing,” the Upendra Commission’s detailed findings, and the naked protest at Kangla Fort together form a body of evidence and testimony that refuses to be forgotten.

For feminist scholars and activists, the case illustrates a core argument: that state violence in conflict zones is not gender-neutral. Women are targeted in specific ways – through sexual violence that weaponizes their bodies – and then denied justice through legal frameworks that protect perpetrators. The Meira Paibi understood this. Their protest was not simply grief; it was an indictment of a system that rendered women’s bodies simultaneously objects of violence and invisible before the law. They made that invisibility impossible to sustain, even if only for a moment.

The broader lesson that emerges from Manorama’s story is that laws like AFSPA do not exist in a vacuum. They are products of political decisions about whose security matters and whose rights can be suspended in the name of order. When a state grants its security forces the power to kill, arrest, and search without accountability, it is making a choice – and the people who pay the price for that choice are disproportionately those who were already most vulnerable.

What do you think? When a state law grants immunity to security forces for actions committed against civilians in conflict zones, at what point does the law itself become the human rights violation – and what does justice actually look like for communities like Manipur where no soldier has ever been prosecuted? How do you think the Meira Paibi’s choice to use their own bodies as protest speaks to the relationship between women’s bodies, state power, and visibility in conflict zones?

References

1. https://www.hrw.org/report/2008/09/29/these-fellows-must-be-eliminated/relentless-violence-and-impunity-manipur
2. https://en.wikipedia.org/wiki/Thangjam_Manorama
3. https://www.thepolisproject.com/read/manipurs-long-wait-for-justice-remembering-1528-cases-and-the-murder-of-thangjam-manorama/
4. https://voelkerrechtsblog.org/indian-women-v-indian-armed-forces/
5. https://ohrh.law.ox.ac.uk/right-to-justice-deprived-by-state-case-of-manorama-vs-afspa-from-manipur-india/
6. https://www.wilpf.org/advocacy_documents/armed-forces-special-powers-act-in-north-east-india/
7. https://blogs.lse.ac.uk/wps/2021/09/02/militarised-violence-and-womens-resistance-in-manipur-india/
8. https://sites.google.com/site/saheliorgsite/violence/state-violence-repression/afspa-down-down-remembering-manorama-in-solidarity-with-sharmila
9. https://www.internationalaffairs.org.au/australianoutlook/promises-reality-indias-conundrum-advocate-women-peace-security-agenda/
10. https://feminisminindia.com/2015/04/22/afspa-the-armys-right-to-rape-from-manorama-to-karbi/
11. https://www.boell.de/en/2020/10/20/if-you-are-not-engaging-shut-up