Substance Abuse And Analysis Of Anti-Drug Policy In Manipur - A Criminology Perspective

Author: LawSphereX

Category: General Law

Published: 2026-08-23T21:10:40.543462+00:00

Updated: 2026-08-26T17:06:08.727+00:00

SUBSTANCE ABUSE AND ANALYSIS OF ANTI-DRUG

POLICY IN MANIPUR: A CRIMINOLOGY PERSPECTIVE

Ajitesh Singh, University School of Law and Legal Studies, Guru Gobind Singh Indraprastha University, Delhi

ABSTRACT

The persistent drug crisis in Manipur presents a multifaceted challenge shaped by the region's socio-economic, political, and criminological realities. Situated near the infamous Golden Triangle, Manipur faces significant vulnerabilities to drug trafficking, substance abuse, and their associated consequences. This paper explores the underlying factors driving the drug epidemic in the state, such as unemployment, poverty, and political instability, and evaluates the application of criminological theories— including Strain Theory, Social Disorganization Theory, Routine Activities Theory, Differential Association Theory, and Labelling Theory—in understanding these dynamics.

Each theory provides a lens to analyze how socio-economic strain, weakened institutions, opportunities for criminal behavior, learned deviant behaviors, and societal stigmatization perpetuate the cycle of drug-related offenses. The analysis delves into the interplay between transnational drug trade networks, local socio-political conditions, and individual behaviors, underscoring the need for multi-stakeholder approaches to address this complex crisis. By connecting theoretical perspectives with practical realities, the study advocates for community-driven interventions, policy reforms, and targeted rehabilitation programs to dismantle the structural and cultural drivers of the drug problem in Manipur. Through this holistic understanding, the paper aims to contribute to the discourse on effective counter-narcotics strategies and sustainable social development.

Introduction Drug abuse is a worldwide issue that impacts not only individuals but also families and communities. Addiction brings about significant distress and suffering, and it contributes to rising crime and violence levels across the globe due to the widespread illegal production and distribution of drugs. No region is immune to the challenges posed by drug trafficking and addiction. India, too, is deeply affected by the growing problem of drug abuse and trafficking, which primarily targets the younger population, thereby disrupting productivity and hindering national progress. The range of abused substances is extensive, including natural drugs like opium and cannabis, semi-synthetic drugs derived from natural sources like heroin and cocaine, and synthetic drugs manufactured chemically, such as those produced illegally or through misuse of prescription medications.

The simultaneous abuse of multiple types of drugs complicates treatment and recovery efforts. Injecting drug use is a particularly concerning public health issue due to the heightened risk of transmitting infections such as HIV and Hepatitis B and C. Manipur, a state in northeastern India, is grappling with one of the highest rates of psychoactive substance abuse in the country. Its geographical position, bordered by Myanmar as part of the infamous "Golden Triangle," has rendered the state particularly susceptible to drug trafficking and related issues. This porous border enables a steady influx of illicit drugs, contributing to an escalating crisis of substance abuse that deeply affects the local population.

Alarmingly, reports indicate a rising trend in the use of multiple psychoactive substances, particularly among vulnerable groups, with young individuals, including women and children as young as 12, increasingly becoming affected. Over the past two decades, the prevalence of drug use among Manipur’s youth has intensified, leading to significant public health, social, and economic challenges. The state's struggle with drug abuse underscores the urgent need for targeted interventions, comprehensive policies, and community-driven solutions to protect its future generations from the devastating impacts of substance abuse. The definition of drug abuse is varied and one single definition will not represent the extensive scale that drug abuse entails.

Drugs are classified into licit drugs and illicit drugs; while licit drugs are legally allowed for consumption (alcohol) and prescription (pharmaceuticals), illicit drug are not and they fall under the Narcotic Drugs and Psychotropic Substances (NDPS) Act,

1985 of the country.

Manipur has long faced numerous socio-economic challenges that have stunted its overall growth. The state’s history is marked by political instability, including ongoing ethnic conflicts and insurgencies, which have significantly disrupted its social and economic structure. These issues have created and deepened developmental disparities among various communities and regions within Manipur. Despite economic activities, Manipur struggles with high Spread of HIV and other health levels of unemployment, poverty, and income inequality, issues especially among its youth. Its geographical location, sharing a border with Myanmar, has also intensified Drug Problem in Socioeconomic State Policies Manipur realities economic challenges, as Manipur has become a key route for illegal cross-border trade, including drugs.

This situation has further compounded socio-economic problems, Drug Trafficking particularly for the youth, who are vulnerable to the lure of the drug trade and its associated dangers. Figure 1: Drug Problem in Manipur Manipur’s proximity to the Golden Triangle—a region infamous for the production and trafficking of illicit drugs—has fuelled a persistent drug abuse crisis in the state. The easy availability of narcotics such as heroin, methamphetamine, and pharmaceutical opioids has significantly worsened the problem. This crisis has brought wide-ranging consequences for individuals and society. The prevalent use of injectable drugs has led to a rapid increase in infectious diseases, including HIV/AIDS, hepatitis, and tuberculosis. The societal and economic repercussions of drug abuse in Manipur are profound.

Rising crime rates, family breakdowns, and social instability are only a few of the serious consequences. Economically, the state bears heavy costs in terms of healthcare expenditures, law enforcement, and lost productivity due to substance abuse. Addressing the drug abuse crisis in Manipur is thus a complex, multifaceted challenge that demands a coordinated response from the government, healthcare providers, law enforcement agencies, and civil society organizations. Despite ongoing efforts by both state and central governments, the crisis remains, posing a substantial threat to the welfare and development of Manipur's youth. The State Government's commitment to eliminating the illegal use of psychoactive substances in Manipur has only strengthened, leading to the creation of the Manipur State Policy on Psychoactive Substances, 2019.

This policy provides comprehensive guidance for all stakeholders in the State to foster collective initiatives aimed at addressing substance abuse

issues. It seeks to tackle every dimension of psychoactive substance use within the region. The Government approaches psychoactive substance use as a complex psycho-socio-medical issue best addressed through community-based interventions. Their strategy encompasses awareness programs, early detection, treatment, rehabilitation, and ongoing support. Recognizing the critical role of treatment and rehabilitation, the policy specifically includes provision 11.11, which mandates the establishment or strengthening of treatment centers. Drug Prevalence Extent of Drug Abuse Despite a substantial amount of documentation Key Defini)ons: existing on the political history and social movements Current Use refers to using a substance at least once in the past 12 months. Unless specified, "use" typically refers to current use.

Dependence is defined as current use of a substance along with a score of more than 26 on the WHO ASSIST.

Quantum of Work combines the prevalence of Harmful Use and Dependence, represenFng substance use paGerns that require professional help and indicaFng substance use disorders.

Harmful Use is current use of a substance, a score between 4-26 on the WHO ASSIST (11-26 for alcohol), and experiencing harmful consequences within the past three months. in Northeast India, details on the health and social consequences of drug use, including alcohol, were difficult to obtain prior to the last 30 years. As part of a national study, an assessment of drug abuse, drug users, and drug prevention services in Dimapur, Nagaland, in Imphal, Manipur, in Guwahati, Assam, and in Shillong, Meghalaya was published only in 1989. In this study, data from addiction treatment centers was collected, and interviews were conducted with ex-drug users and in-depth interactions were carried out with informed persons such as pharmacists, government officials, school teachers, businessmen, lawyers, police officers, social workers, and religious leaders.

The widespread concern over drug use in Northeast India, however, only followed the outbreak of the HIV epidemic among local heroin injectors in Manipur in October 1989, which then attracted the attention of many national and international communities.

A report of the survey called ‘Magnitude of Substance Use in India, 2019’ revealed the

alarming degree of psychoactive substance use in Manipur as shown below:1 Table 1:Data on Drug Prevalence in Manipur Manipur's proximity to the Golden Triangle, along with its history of political instability and ethnic conflicts, has played a significant role in the state's ongoing struggle with drug abuse. Over the years, numerous studies have been conducted to investigate the patterns, trends, and root causes of drug abuse in the region. One of the first comprehensive studies on drug abuse in Manipur was carried out by the Centre for Social Development in the late 1990s. The research highlighted the widespread use of injectable drugs, especially heroin, and the alarming rates of HIV/AIDS among the drug-using population.

Subsequent studies have further explored the drug abuse issue, providing insights into the various substances abused, the socio-demographic characteristics of users, and the underlying factors driving the crisis. For example, a study by the Manipur Directorate of Health Services in 2018 found that the abuse of pharmaceutical opioids, such as tramadol and codeinebased cough syrups, has become increasingly common among the state's youth. Researchers have also examined the health impacts of drug abuse, documenting high rates of HIV/AIDS, hepatitis, and other blood-borne infections among drug users. In addition, studies have highlighted the broader socio-economic effects of the crisis, including rising crime rates, family breakdowns, and the erosion of community cohesion. Despite the extensive body of research, drug abuse remains a persistent problem in Manipur.

The need for more effective interventions is critical. Many studies emphasize the importance of addressing the socio-economic and political factors that fuel the drug crisis, along with the need for a comprehensive, multi-stakeholder approach to tackle the issue. 1 Ministry of Social Justice and Empowerment, Magnitude of Substance Use in India (Nat’l Drug Dependence Treatment Centre, All India Inst. of Med. Scis. , 2019).

Geographical Factors Influencing Drug Abuse India shares a porous 1,643-km border with Myanmar, and the proximity of its northeastern states—Manipur, Mizoram, Nagaland, and Arunachal Pradesh—to this border makes it easier for drug smugglers, traffickers, and insurgent groups to operate. This ease of access contributes to the trafficking and distribution of illicit drugs in these regions, exacerbating both local and regional security concerns. Manipur is one of the eight northeastern states of India, bordered by Nagaland to the north, Assam to the west, and Mizoram to the south. To the east, it shares a 398-km international boundary with Myanmar. Geographically, Manipur is a landlocked state with a distinct topography. It is surrounded by the Naga and Lushai Hill ranges, which encircle the central plains known as the Imphal Valley.

After India gained independence in 1947, Manipur, which was a princely state, initially declared its independence. However, it was integrated into the Indian Union in October 1949 as a 'C' state. In 1956, it was designated a union territory, and in 1972, Manipur achieved full statehood. The state covers an area of 22,327 square kilometres and is divided into nine districts—four in the valley and five in the hills. The valley districts include Imphal West, Imphal East, Bishnupur, and Thoubal, while the hill districts are Churachandpur, Chandel, Ukhrul, Senapati, and Tamenglong. According to the 2011 Census, Manipur has a population of 2,855,794. The Meitei community is the largest ethnic group, primarily residing in the plains of the Imphal Valley, while the Nagas and Kuki-Chins are the other prominent communities, residing mainly in the hilly regions of the state.

In recent years, there has been a noticeable increase in drug seizures in India’s northeastern states bordering Myanmar. Between July 2022 and July 2023, the Manipur police confiscated contraband valued at approximately US93 million. In the fiscal year 2021-22, the value of seized drugs was US0. 17 million, while in 2020-21, it was US4. 36 million. Experts estimate that around 90 percent of drugs smuggled into the northeastern region of India (NER) originate in Myanmar. This trend has continued into 2024, as evidenced by ongoing drug seizure reports across several NER states. From January 1 to April 25, 2024, Mizoram's Excise & Narcotics Department arrested 2,297 individuals involved in drug trafficking and alcohol-related offenses. The department also seized 30 vehicles linked to these illicit activities. Among the confiscated substances were

26.494 kg of heroin, 384.1001 kg of marijuana, and 112.528 kg of methamphetamine.

Additionally, the department intercepted 5,127 vials of cough syrup, 1,678 alprazolam tablets, and 136 tramadol tablets. Golden Triangle Northeastern India is geographically close to the 'Golden Triangle' which encompasses Myanmar, Thailand, Laos, and China's Yunnan Province. This region is one of the world’s most significant sources of illicit heroin and opium. It is alleged that Myanmar’s military junta, which relies on the drug trade for revenue, sponsors the narcotics trade in the country. In the late 1970s and early 1980s, as countries like Singapore, Malaysia, and Indonesia took strong measures against drug trafficking passing through their territories, Manipur became an alternative route for traffickers due to its proximity to the Golden Triangle. By the late 1980s, although opium production was nearly non-existent in the region, Manipur had become a major user state.

Drugs, particularly ‘number 4’ (the Figure 2: Golden Triangle purest form of heroin), are readily available in the state at very low prices. The increased narcotics and drug trafficking through the India-Myanmar border presents severe challenges to regional security and societal well-being. Easy access to heroin and synthetic pharmaceuticals in the border region has led to heightened substance abuse among the local population, further complicated by the threat of the HIV/AIDS virus. The northeastern states sharing a border with Myanmar have the highest adult HIV prevalence rates, with 2. 70 percent in Mizoram, 1. 36 percent in Nagaland, and 1. 05 percent in Manipur.

The high prevalence of HIV associated with injection drug use in Nagaland and Manipur is combined with multiple social, political, and economic factors, including poverty, unemployment, low capital formation, and a lack of industrialisation, which contribute to ongoing conflict and growing drug use among the youth.

Heroin from Myanmar is transported through the town of Moreh in Manipur, which shares a border with the Burmese town of Tamu. The border area has seen virtually free movement of people and goods between the two towns. Moreh serves as a key transit point for goods, including Chinese and other foreign products, into the northeastern states of India. Most of the heroin passing through Moreh originates from the northeastern regions of Myanmar, including the Shan, Wa, and Kokang areas, as well as the Kachin region. 2 There is a threefold threat posed by the surge in drug trafficking to India, particularly its sensitive northeastern region. First, local consumption of drugs has •HIV infections, Heptatitis and other related issues. •Increase in crime rates and drug peddling. Local Consumption led to a sharp increase in HIV infections.

3 Second, the allure of •Involvement and arrest of military personnel. •Politicians and bureaucrats. Local Officials quick money has compromised local officials, with several military and paramilitary personnel arrested for •Protection to drug mafias. •Fundings for operations. Ethnic Separatists drug smuggling. Politicians, bureaucrats, and even security force officials have become embroiled in the Figure 3: Three-fold threat posed by drug trafficking. illicit drug trade. Third, ethnic separatists in the region are increasingly protecting drug mafias as a means to fund their operations, further fueling the problem. Manipur, located near key drug trafficking routes from Myanmar, particularly through the Shan Hills and Tiddim in Chin State, has become a significant transit hub for smuggling drugs to various parts of the world.

There are two primary trafficking routes from western Myanmar to India’s northeastern states—Manipur, Mizoram, and Nagaland. The more commonly used route begins in Mandalay, passing through Monywa and Kalewa, then splitting towards Tamu- Moreh on the India-Myanmar border, leading into Manipur, or southward through Rih- Champhai into Mizoram. Another route starts in Bhamo in Kachin State, travels down to Homalin in the Sagaing Region, and then enters Nagaland, continuing through Assam, Kolkata, 2 Sreeparna Banerjee, From Poppy Fields to Black Markets: Understanding the Drug Trade Across India and Myanmar, Occasional Paper No. 450 (Observer Research Found. , Oct. 2024). 3 Khrieketou Suohu et al. , Understanding the Association Between Injecting and Sexual Risk Behaviors of Injecting Drug Users in Manipur and Nagaland, India, 9 Harm Reduction J. 40 (2012), available at http://www.

harmreductionjournal. com/content/9/1/40 (last visited Oct. 14, 2024).

and across India. The India-Myanmar border is highly permeable, primarily due to four key factors, which complicate the security and governance of the region: • Superimposed Border: The boundary, drawn by the Pemberton Line, divides ethnic communities and separates tribes such as the Nagas, Kukis, Mizos, and Chins. Despite this artificial division, these tribes maintain strong social and economic connections across the border, prioritizing clan and ethnic ties over national borders. These deeprooted trans-border relationships have hindered the nation-building process and delayed the establishment of a definitive international border. • Free Movement Regime (FMR): The FMR has further complicated the delineation of the India-Myanmar border.

Understanding that many border communities share common socio-economic interests, both countries have allowed tribespeople to move up to 16 kilometres into each other’s territory without documentation. While this arrangement facilitates the maintenance of long-standing cultural and economic ties, it has also been exploited by insurgents. Indian militants, for instance, have used the FMR to cross into Myanmar for arms training, establish safe havens, and re-enter India to conduct subversive activities. Moreover, the FMR has facilitated the flow of illicit drugs across the border. The route has been closed since the pandemic and the escalating violence in Myanmar, but it continues to play a significant role in regional security dynamics, particularly with the influx of over 70,000 Myanmar nationals between

2021 and May 2024.4

Geography: The challenging topography of the border, with high mountains in the north, hills, and river channels in the south, and dense forests throughout, further exacerbates security concerns. The difficult terrain impedes the development of infrastructure, including roads and communication links, making the border region sparsely populated and underdeveloped. This lack of infrastructure hinders effective policing and border control, enabling the easy smuggling of opium, heroin, and synthetic drugs. As a result, the northeastern region (NER) has become both a transit hub and a destination for drug trafficking. 4 Illegal Immigration from Myanmar to Manipur, India Today, https://www.indiatoday.in/india/story/illegalimmigration-from-myanmar-to-manipur-2416334-2023-08-04 (last visited Nov. 14, 2024).

Reports from 2023 indicate that, amid the growing conflict in Manipur, drug traffickers from Assam and Mizoram used excavators to carve out a 10-km pathway from the international border to the nearest settlement in Myanmar’s Chin State, enabling the uninterrupted flow of narcotics across the border. Opium produced illicitly along the Indo-Myanmar border, particularly in Manipur, is transported to Myanmar to be processed into heroin, which is then smuggled back into India. Additionally, medicinal preparations are trafficked from India to Myanmar using similar routes. 5 The growing networks between drug mafias and kingpins connecting Manipur and Myanmar for smuggling poppy into the Golden Triangle, as well as the conversion of opium into heroin, pose significant challenges for Manipur.

These include combating poppy cultivation within the state and preventing the illegal trafficking of drugs. 6 Manipur’s porous border with Myanmar, combined with associated security concerns, has raised alarms among Indian authorities. There are growing fears that this region could become a hub for drug production. The Chief Minister of Manipur, Biren Singh, has attributed the increase in poppy cultivation to the influx of Myanmar nationals following the 2017 Rohingya exodus and the 2021 military coup in Myanmar. However, local residents dispute this claim, asserting that there is no concrete evidence linking these events directly to the rise in drug trafficking and poppy farming in the region. 7

5 Rs 5 Crore Party Drugs Seized in Manipur's Tengnoupal; 1 Held, Times of India,

https://timesofindia.indiatimes.com/city/imphal/rs-5-crore-party-drugs-seized-in-manipurs-tengnoupal-1held/articleshow/93827388.cms.

6 Vivekananda Int’l Found., Nexus Between Insurgency and Narco-Trafficking,

https://www.vifindia.org/article/2024/april/26/Nexus-between-Insurgency-and-Narco-Trafficking (last visited Nov. 14, 2024).

7 Behind India’s Manipur Conflict: A Tale of Drugs, Armed Groups and Politics, Al Jazeera,

https://www.aljazeera.com/economy/2024/4/16/behind-indias-manipur-conflict-a-tale-of-drugs-armed-groupsand-politics..

Table 2: District-wise Data on Destruction of Illicit Poppy Fields Illicit Poppy Cultivation: A Contributor to the Drug Menace Drug trafficking is not a new trend in the state; however, the unprecedented rise of poppy cultivation raises a red signal that adversely impacts the northeast regions (NER) and the rest of India. India is the only country in Asia that licenses farmers to cultivate opium gum for medical and scientific purposes. Legal cultivation is regulated in Madhya Pradesh, Rajasthan, and Uttar Pradesh. The Central Bureau of Narcotics (CBN) issues licences to farmers, who must meet specific yield requirements and sell their entire opium harvest to the government. This regulated market contrasts sharply with the illegal cultivation and trafficking activities in the northeastern states.

Manipur has seen an unprecedented rise in illicit poppy In recogni*on of efforts to combat poppy cul*va*on, the Chief Minister, N. Biren Singh, rewarded a village in Ukhrul district with a cash prize of Rs 10 lakh for voluntarily destroying poppy plants in 2021. cultivation during the past five years. The cultivation of poppy, locally known as kaani, has taken over the hilly regions of the state, populated mostly by Schedule Tribes. The widespread cultivation of illegal poppies in remote districts of Ukhrul, Senapati, Kangpokpi, Kamjong, Churachandpur, and Tengnoupal in Manipur has been fuelled by significant investments from drug cartels. This

boom in poppy farming has led to a urea shortage in the state, as the demand for fertilizers rises.8 To combat the growing drug trade, the Manipur Narcotics and Affairs of Border (NAB) Department reported the detention of 963 drug traffickers, including 768 men and 195 women, between April 27 and June 2019, under the Narcotic Drugs and Psychotropic Substances (NDPS) Act. Additionally, law enforcement agencies destroyed 1,420 acres of poppy plantations between

2020 and February 2021. However, despite these efforts, the issue persists, indicating that such

coercive measures may not be sustainable in the long term unless the root causes of poppy cultivation are addressed. 9 Potential Reasons Socio-economically, many of the Jhum cultivation - individuals engaged in poppy readily available farming belong to the most land marginalized communities in the state. They often lack access to basic amenities and face extreme Illicit Poppy Cultivation Armed conflicts and Prevalent poverty poverty, which drives them to insurgency cultivate poppies. For these farmers, poppy cultivation becomes a lucrative option, as it is easy to Better education for children and grow alongside other crops and lifestyle requires relatively cheap labour. It serves as a "magic potion" to escape Figure 4: Reasons for Illicit Poppy Cultivation poverty, with the funding for these operations largely coming from powerful drug kingpins.

10 Poppy is cultivated mainly in rural areas of Manipur, where people predominantly adhere to jhum cultivation. As land is readily available to jhumias, it is easier to cultivate poppy with

8 Id.

9 Lemongrass to Replace Illegal Poppy Farming in Manipur, Times of India,

https://timesofindia.indiatimes.com/city/imphal/lemongrass-to-replace-illegal-poppy-farming-inmanipur/articleshow/58237749.cms. 10 Ningthoujam Koiremba Singh & William Nunes, Drug Trafficking and Narco-Terrorism as Security Threats: A Study of India's Northeast, 69(1) India Q. 65, 65–82 (2013), available at

https://www.jstor.org/stable/45072708 (last visited Nov. 14, 2024).

other crops. The driving force to cultivate poppy in rural villages is the prevalent poverty, which has its origins in the failure of state machinery, to some extent. Decades of armed conflicts, insurgency problems, and ethnic violence have crippled the state, hitting the economy and in turn the poor, the hardest. Despite the implementation of various rural development programmes, it falls short in delivering to the last mile. Moreover, the desire to provide better education to children and to possess modern appliances and technology has been accorded high priority in today's society. Involvement of Political Actors The nexus between politicians, law enforcement, and drug kingpins, exemplified by the case of Lukhosei Zou, remains a crucial concern.

This collaboration has created an environment where drug smuggling networks operate with impunity, shielded by those meant to dismantle them. As a result, the flow of narcotics continues to undermine law enforcement efforts and fuel instability in the region, making it challenging to address the root of the problem. Lukhosei Zou Zou, a former politician in Manipur, was arrested in June 2018 with heroin and amphetamines and went missing from medical care during his legal proceedings that same year. 11 He reappeared in 2020, surrendered to the court, and claimed that he had been abducted by an underground Kuki group and taken to Myanmar. However, no evidence was found to support his story. After his surrender, Zou was placed in judicial custody, granted interim bail for medical reasons, and ultimately acquitted by a Special Court in Manipur at the end of 2020 due to insufficient evidence.

His acquittal sparked protests from civil societies, particularly those opposing drug trafficking. In 2022, the Manipur government came under scrutiny by the Supreme Court for delaying its appeal against Zou's acquittal. The state subsequently filed an appeal in the High Court, but as of August 2024, no significant legal action has reversed the acquittal. The case remains a focal point for concerns about the involvement of political figures in the region's drug trade.

11 Manipur Court Acquits Former ADC Chairman in Multi-Crore Drug Seizure Case, 2 Convicted, Morung

Express, https://morungexpress.com/manipur-court-acquits-former-adc-chairman-in-multi-crore-drug-seizurecase-2-convicted (last visited Nov. 14, 2024).

Other Notable Political Actors One of the case studies deals with a woman from Manipur who uses heroin anally. While most women who use drugs in northeast India either inject or chase heroin (inhale the vaporized form), the field research team of the UNODC idenEfied a 40-year-old woman who had been administering heroin through her rectum for four years. In addiEon, she had been injecEng heroin for the past six months. ALer developing a painful case of piles, she had been advised by a friend to insert heroin powder through the rectum to relieve pain. Having found good relief, she conEnued the pracEce over Eme and currently administers heroin through her rectum several Emes daily. Manipur has a longstanding history of political involvement in the drug trade, dating back to the 1980s when Khun Sa of the Shan State Army used Manipuri politicians as couriers for his heroin operations.

The first politician implicated was former Deputy Speaker Ngurdinglien, who was killed before a defamation case against him could conclude. 12 Later, the family of former minister (Late) Md Hellanuddin became embroiled in the drug trade after his son was murdered by militants over allegations linked to drugs. Okram Henry Singh, the nephew of former Chief Minister Okram Ibobi Singh, was also “I had piles for a long 1me and the pain was difficult to tolerate... a friend from the police service suggested that I apply heroin powder through my anus to get relief from the pain. I put the heroin on a wet piece of co;on and inserted it into my anus. I was relieved of the pain and that made me con1nue using it. I buy heroin regularly and now need to apply it up to eight 1mes daily. Without this, I’d have to go through excrucia1ng pain.

” implicated in a drug racket, but a CBI investigation delayed any legal action. Henry has since been elected to the Legislative Assembly, with occasional news coverage as the CBI probe progresses. Although many influential politicians and officials have avoided arrest, several officials were arrested between 2019 and 2022, though the exact number remains unclear. 13 Prevalence among Women Currently, it is common to see female injecting drug users in the states of Manipur, Mizoram, and Nagaland. However, intervention programs have yet to adequately address this issue, and addiction treatment facilities for women, as well as other risk-reduction interventions, remain limited.

Cross-sectional studies from the late 1980s and early 1990s that recruited injecting drug users (IDUs) from communities, addiction treatment centers, remand homes, and jails 12 Different Faces of Manipur's War on Drugs Through the Decades: Some in Brutal Earnest, Some Theatrically Banal, Imphal Reviews, https://imphalreviews. in/different-faces-of-manipurs-war-on-drugs-through-thedecades-some-in-brutal-earnest-some-theatrically-banal/ (last visited Nov. 14, 2024)..

13 Assam: Two Assam Police Constables Arrested in Drug Trafficking Case, The Sentinel Assam,

https://www.sentinelassam.com/north-east-india-news/assam-news/assam-two-assam-police-constablesarrested-in-drug-trafficking-case-669756 (last visited Nov. 14, 2024)..

revealed that, while 5% of IDUs in Manipur and Nagaland were women, the proportion was as high as 15% in Mizoram.14 A later study examined the link between drug use and sex work in Imphal. Based on interviews

conducted by outreach workers with 69 women who were both drug users and sex workers, the study found that: • Thirty-eight women (55%) were injecting drug users. • Eighty percent of the respondents had sexual relationships with non-regular partners. • Two-thirds of both injectors and non-injecting drug users reported engaging in sex work in exchange for money or drugs. For non-injectors, alcohol was the primary substance of choice, while injectors mostly used a purer form of heroin, locally known as "Number 4" or "white sugar. " A smaller group of female IDUs initially used cannabis, nitrazepam tablets, or codeine-based cough syrup before switching to injecting drugs. Most female IDUs reported using alcohol, specifically a locally brewed rice beer known as "sekmai" and heroin injections.

HIV prevalence was found to be 57% among female IDUs in this study, compared with 20% among non-IDUs, representing a statistically significant difference. 15 The report, Women Who Use Drugs in Northeast India, sheds light on the unique and layered challenges faced by female drug users in Manipur, underscoring the severe social, health, and economic vulnerabilities of this group. The report was published by the United Nations Office on Drugs and Crime (UNODC), Regional Office for South Asia. 16

14 United Nations Office on Drugs and Crime, Executive Summary,

https://www.unodc.org/pdf/india/drug_use/executive_summary.pdf (last visited Oct. 18, 2024). 15 Sapna Desai, HIV and Domestic Violence: Intersections in the Lives of Married Women in India, 8(2) Health & Hum. Rts. 140, 140–68 (2005), available at https://www.jstor.org/stable/4065337 (last visited Oct. 14, 2024). 16 Dr. M. Suresh Kumar et al., Women Who Use Drugs in Northeast India (Project RAS/H13: Prevention of Transmission of HIV Amongst Drug Users in SAARC Countries, UN Office on Drugs & Crime, Regional Off. for S. Asia, 2015).

The mean age of female drug users in the region is around 29, and while 60. 5% have attained middle or higher secondary education, only 0. 7% hold formal employment. Without viable job opportunities and with a social stigma that isolates them, more than half are compelled into survival strategies, including selling drugs or engaging in sex work. The Meira Paibis, or "Women Torchbearers," are a grassroots women's movement in Manipur, India, founded in the 1970s. IniFally formed to address issues like alcoholism and drug abuse, the movement later expanded to advocate for human rights, parFcularly in protest against the Armed Forces (Special Powers) Act (AFSPA), which has been linked to widespread military abuses. The women organize night vigils, carrying torches as symbols of protecFon and resistance.

Beyond combaFng social issues, the Meira Paibis also fight for gender equality, women's rights, and social jusFce, becoming a powerful symbol of resilience and acFvism in Manipur and beyond. Substance use for many women begins with opioids like Proxyvon or Heroin, often consumed in noninjecting forms around the age of 20, and later transitioning to injection by approximately 22. This transition reflects broader trends in Manipur, where the proximity to drug trafficking routes and the scarcity of accessible drug rehabilitation services creates an environment conducive to high-risk behaviours. As a result, Manipur has become part of a high HIV burden region, with 28. 2% of women drug users injecting drugs, a practice that increases exposure to HIV and other infections due to prevalent needle sharing.

Alarmingly, nearly half of those injecting report using previously used needles, a major contributor to the spread of HIV, hepatitis, and other infectious diseases. The health challenges faced by these women are severe and multifaceted. A quarter report poor health, with many grappling with hepatitis, tuberculosis, and injection-related injuries, such as abscesses and collapsed veins. The health risks go beyond infectious diseases; many women in Manipur who use drugs suffer from untreated mental health conditions, often Table 3: Percentage of Women who Inject Drugs exacerbated by trauma from physical and

sexual abuse. Substance use, in some cases, serves as self-medication to cope with these unresolved issues. Violence is a persistent reality, with nearly 62% of women reporting physical abuse by non-sexual partners, while 73% face regular abuse from intimate partners, police, and community members. Additionally, sexual violence affects 43% of female drug users who inject. In such an environment, sexual and reproductive health practices suffer, with inconsistent contraceptive use among primary partners (only 22. 9% report regular condom use), and even in casual relationships, over half of the women report inconsistent condom use, heightening the risk of sexually transmitted infections and unintended pregnancies. Healthcare access is a critical barrier for these women.

High treatment costs, geographical isolation, and the lack of women-friendly services leave one-fourth unable to obtain drug treatment, while only 40% receive some form of intervention for drug disorders. This lack of support is compounded by societal and institutional stigma, which discourages many from seeking help, forcing them to manage their dependency largely alone. Even for those able to access treatment, services are rarely tailored to meet the needs of female drug users, especially those with caregiving responsibilities. Legal and criminal justice challenges add yet another layer of difficulty. Over 20% of women have been incarcerated at least once, with more than half experiencing repeat incarcerations. In prison, many continue drug use under unsupervised conditions, increasing health risks.

The criminal justice system’s punitive approach to drug use exacerbates trauma and stigmatization, making social reintegration post-incarceration particularly difficult. For pregnant women, these risks compound significantly. Of those who become pregnant, 59% continue drug use during pregnancy, while only 28% cease following childbirth, exposing a critical gap in prenatal and postnatal support for women with substance use disorders. Limited healthcare services fail to meet these women’s unique needs, leading to adverse outcomes for both mothers and children. Effective support must extend beyond harm reduction, including broader social and economic assistance to promote stability, reduce drug dependency, and mitigate associated risks.

Coordinated interventions involving community leaders, law enforcement, and healthcare providers are crucial to establishing a supportive environment where women can seek help without fear of stigma or punishment. Such an approach could provide a pathway to improved health, greater social integration, and reduced intergenerational impacts of substance abuse, ultimately fostering a stronger, more resilient community.

Substance Use Trends and Commonly Abused Drugs In recent years, drug seizures have surged in India’s northeastern states, particularly those bordering Myanmar. Between July 2022 and July 2023, the Manipur police confiscated contraband worth around US93 million. In FY 2021-22, seizures amounted to US0. 17 million, and in 2020-21, the value was US4. 36 million. Experts estimate that 90% of the drugs smuggled into the Northeast Region (NER) come from Myanmar. This trend continues into 2024, as drug seizure reports from several NER states reflect a similar pattern. Between 1 January and 25 April 2024, the Excise & Narcotics Department of Mizoram apprehended individuals involved in drug trafficking and alcohol-related activities; 2,297 individuals were arrested and 30 vehicles linked to these illicit activities were seized.

The department confiscated large amounts of illicit substances, including 26. 494 kg of heroin,

384.1001 kg of marijuana, and 112.528 kg of methamphetamine. Additionally, the department

intercepted 5,127 vials of cough syrup, 1,678 tablets of alprazolam, and 136 tablets of tramadol. Drug trafficking in Northeast India features the following Classification dimensions: of Drugs Ø The illicit cultivation of opium and cannabis. Narcotics: Opium, Heroine, Morphine The smuggling of heroin and amphetamines into Northeast India from Myanmar in small quantities. Depressants: Ø The trafficking of pharmaceutical opioids from other parts Barbiturates, Tranquilizers of the country into Northeast India and their smuggling to neighbouring countries. Stimulants: Amphetamine, Ø The trafficking of ephedrine and pseudoephedrine Cocaine (precursors for the manufacturing of amphetamines) from Halluinogens: India to Myanmar.

LSD, Charas, Ganja, Mescaline Figure 5: Classification of Drugs Unemployment Rate According to an article from the Indian Express, data from the annual Periodic Labour Force Survey (PLFS) for 2021-22, the latest nationwide employment survey, shows Manipur to be among the states with the highest unemployment rate for the age group of 15 years and above, at 9 per cent — more than double the national unemployment rate of 4. 1 per cent in 2021-22,

and higher than other states in the Northeast. 17 The unemployment rate in the state’s rural areas, the predominantly hilly regions where the Kuki and Naga tribal populations are concentrated, was estimated to be 9. 5 per cent in the PLFS for 2021-22, while the unemployment rate in the urban areas, where much of the Meitei population lives, was marginally lower at 7. 6 per cent. Nearly 65 per cent of men in the state were reported as self-employed in rural areas, compared to the all-India rate of 59 per cent. Demographics As per a study, drug abuse among youth in Manipur paints a concerning picture of both the prevalence and the profound consequences of substance use. 18 The sample consisted of 50 youth participants, aged 15-29, with a notable gender imbalance—63. 3% male, reflecting the broader demographic trends within the drug abuse population in the state.

Educationally, the participants were diverse, with 35% having completed secondary education, 28% holding higher secondary qualifications, and 37% having only primary education or no formal schooling. Socio-economic conditions also varied, with 42% of respondents coming from households earning less than INR 15,000 per month, highlighting the economic challenges that could contribute to the crisis. Ethnically, the sample mirrored Manipur's diversity, with 45% Meitei, 30% Naga, and 15% Kuki, indicating that drug abuse affects multiple communities across the state. The study revealed a range of drugs commonly abused, with heroin (54. 3%), pharmaceutical opioids (47. 1%), and methamphetamine (41. 2%) being the most frequently reported substances. Injectable drugs, particularly heroin, were notably prevalent, with nearly half (48. 6%) of participants using needles and syringes.

This pattern reflects the accessibility and euphoric appeal of these drugs. The study also uncovered a growing trend of polydrug use, with 39. 2% of participants reporting the concurrent use of multiple substances, which poses additional health risks. The reasons for drug abuse were found to be multifaceted, with many participants citing a desire to "escape from reality" (57. 4%), peer pressure (41. 8%), and emotional distress or trauma as significant triggers for their drug use. Social and environmental factors also played a key role, with the normalization of drug use in communities and lack of 17 Indian Express, Explained: Slowdown Hits Hard, Manipur’s Jobless Rate Twice National Average, Indian Express (May 25, 2023), https://indianexpress. com/article/explained/slowdown-hits-hard-manipurs-jobless-ratetwice-national-average-8598920/ (last visited Nov. 14, 2024).

18 Vikash Haorungbam, A Study of Scenario of Drug Abuse Among the Adolescent of Manipur, 9(5) Int’l J. Novel Rsch. & Dev. (2024).

parental guidance contributing to the initiation and continuation of substance abuse. The region's political and economic instability, including limited educational and employment opportunities, also emerged as important drivers of drug use, creating a sense of hopelessness among the youth. The frequency and duration of drug abuse were alarmingly high, with 42. 2% of participants reporting daily drug use, and 27. 3% using drugs several times a week. Many respondents (38. 7%) had been using drugs for over five years, with 29. 5% using drugs for 2-5 years, indicating that a significant portion of youth are dealing with long-term substance use disorders. This prolonged exposure increases the risks of chronic addiction and serious health complications. Younger participants (aged 15-22) were more likely to engage in frequent drug use, suggesting heightened vulnerability in this age group.

Manipur ATS (In Ephedrine Ganja (in Heroin Morphine Opium Total Arrested Kg) (in Kg) Kg) (in Kg) (In Kg) (In Cases Kg) 30. 87 47. 14 255. 49 113. 19 746. 62 235. 15 213. 55 701. 68 196. 45 31. 49 213. 23 62. 32 819. 17 254. 55 629. 5 515. 7 15. 72 143. 5 163. 9 79. 42 Manipur Ketamine Morphine Opium Poppy Injection

CBCS

Tablets Tablets (in Kg) (Liters) (In (In (In No.) (Bottles) (In Kg) (In Nos.) Kg) Kg) 255.49 8.34 1460267 2.2 235.15 108.05 7129088 196.45 61.42 1876402

26. 5 819. 17 29. 86 515. 7 328. 51 79. 42 113. 47 Table 4: Data on Substances Procured from 2018-2023 in Manipur (Data presented in Rajya Sabha)19 The health consequences were severe, with nearly half (46. 9%) of participants reporting physical health problems, including overdose, organ damage, and the transmission of infectious diseases such as HIV and hepatitis C. The high rates of HIV (37. 5%) and hepatitis C (28. 2%) among users, particularly those using injectable drugs, further strain the healthcare system. Mental health issues were also prevalent, with over half (52. 3%) of respondents reporting symptoms of depression, anxiety, and other disorders, often exacerbated by the drugs themselves. The use of methamphetamine and sedatives, in particular, was linked to psychotic episodes and suicidal ideation.

These health issues, coupled with cognitive impairments and chronic pain, underscore the urgent need for targeted health interventions. Socio-economically, drug abuse had a crippling impact on education and employment. Nearly 42. 6% of participants dropped out of school or college, and 38. 4% had difficulty maintaining steady jobs, perpetuating a cycle of poverty and limiting their socio-economic mobility. The family dynamics of drug users were also severely affected, with 53. 8% of respondents reporting strained or broken family relationships due to their drug use, leading to social isolation. Additionally, 47. 2% of participants admitted to engaging in illegal activities such as theft or drug dealing to sustain their habits, contributing to rising crime rates in their communities. The psychological and behavioural consequences of drug abuse were similarly devastating.

Over half of the participants (58. 4%) met the diagnostic criteria for substance use disorders, significantly impairing their cognitive function, emotional regulation, and decision-making. Many youths also suffered from co-occurring mental health disorders like depression (52. 3%) and anxiety (47. 6%), with a considerable portion (32. 1%) experiencing post-traumatic stress disorder (PTSD). The interaction between drug abuse and mental health issues created a vicious cycle, intensifying both conditions and leading to further deterioration of the youth's overall

19 Year-Wise Details of Drugs Seized in State of Manipur Reported by Drug Law Enforcement Agencies

(DLEAs), Data.gov.in, https://www.data.gov.in/resource/year-wise-details-drugs-seized-state-manipur-reporteddrug-law-enforcement-agencies-dleas.

well-being. Risky behaviors, such as sharing needles (48. 6%) and unprotected sexual activity (41. 2%), also put participants at greater risk for infectious diseases, while criminal involvement further disrupted their lives and communities. State Policies and Criminal Justice System NDPS Act, 1985 The Narcotic Drugs and Psychotropic Substances Act of 1985 (NDPS Act) provides the legal framework for drug law enforcement in India, with the National Narcotics Control Bureau (NCB) serving as the coordinating agency for its implementation. A key focus of India’s counter-narcotics strategy is the identification and eradication of illicit cultivation and the wild growth of cannabis and opium poppy. Engaging in the illegal cultivation of opium, cannabis, or coca is a serious offense, carrying severe penalties, including imprisonment of up to ten years and fines of up to ₹1,10,000.

For licensed opium farmers, embezzling opium attracts even harsher penalties, with prison sentences ranging from 10 to 20 years and fines of ₹1,10,000 to ₹2,20,000. In Manipur, there has been a significant rise in poppy cultivation in recent years. Between 2017 and 2023, law enforcement agencies in the state uprooted 18,664. 5 acres of poppy fields. During this period, 2,817 individuals were arrested, and 2,243 cases were registered under the NDPS Act. However, most of the individuals convicted were mules or couriers, with no convictions of major drug lords due to inadequate investigations. The conviction rate remains low, as many officials responsible for drug seizures and arrests lack proper training in evidence handling and seizure protocols, resulting in mishandling of evidence and poor prosecution. This remains a significant loophole that needs to be addressed.

Additionally, political pressure to release arrested individuals, remains a concern for law enforcement agencies. 20 State Policies Manipur’s state government has initiated campaigns, such as Nisha Thadoklasi and War on Drugs in 2018 and War on Drugs 2. 0 in 2022, to combat illegal poppy cultivation and disrupt its distribution and trade. Despite these campaigns and operations to seize illicit drugs, the issue remains persistent and complex. The state has also utilised methods such as spraying herbicides using drones. Manually cutting down poppy plants requires significant work force. Drones and

20 The Menace of Alcoholism and Drug Abuse in Manipur, Frontier Manipur,

https://thefrontiermanipur.com/menace-of-alcoholism-drug-abuse-in-manipur/ (last visited Nov. 14, 2024)..

real-time satellite imagery are also used to identify poppy plantations in the hills. Manipur's state government is also drafting a comprehensive State Drug Policy21, which is nearing its final stages, aimed at strengthening the legal and enforcement framework against drug abuse. In addition, new guidelines for TRUST (Tobacco and Drug Rehabilitation and Supportive Treatment) centres were introduced in 2024 to enhance the rehabilitation and support services for drug-affected individuals across the state. 22 Nisha Thadoklasi The Nisha Thadoklasi campaign, launched on International Day Against Drug Abuse and Illicit Trafficking in 2018, is a key initiative in Manipur aimed at combating drug abuse and promoting a drug-free society.

23 The campaign is part of the state government's broader effort to address the growing drug menace in the region and is named after Nisha Thadoklasi, symbolizing a commitment to raise awareness about drug abuse prevention. Key features of the Nisha Thadoklasi campaign include:

1. Drug-Free Schools: The campaign focuses on creating "drug-free campuses" in

schools. A target has been set to identify and transform 80 schools into drug-free zones, with senior students and teachers receiving training to establish counselling centers for drug abuse prevention.

2. Public Awareness: The initiative includes public awareness campaigns designed to

educate the masses about the dangers of drug abuse and to encourage community involvement in tackling drug trafficking and addiction.

3. Community Engagement: The campaign emphasizes community-driven efforts,

including the launch of community policing initiatives by the police to target drug peddlers and illegal substances.

4. Rehabilitation and Support: Recognizing the importance of rehabilitation, the

campaign advocates for the rehabilitation of drug abuse victims, with a focus on integrating them back into society. The government has also partnered with existing

21 Government of Manipur, Draft Manipur State Drug Policy (2019).

22 Government of Manipur, Guidelines for Setting-Up Treatment & Rehabilitation of Users for Social

Transformation (TRUST) Centres in Manipur (effective August 2022). 23 Nisha Thadoklasi, "Manipur Govt Declares War on Drugs", MyGov Blog, https://blog.mygov.in/nishathadoklasi-manipur-govt-declares-war-on-drugs/.

Integrated Rehabilitation Centres to provide comprehensive services for substancedependent individuals.

5. Collaborative Effort: The campaign stresses the need for collaboration between

various sectors, including health, education, and social welfare, to create a holistic approach to eradicating drug abuse in the state. The Nisha Thadoklasi initiative is an integral part of the Manipur government's ongoing efforts to combat the drug crisis and build a drug-free society, aiming to safeguard the future generation by addressing both prevention and rehabilitation. War on Drugs Manipur's War on Drugs initiatives, launched in 2018 and expanded in 2022 as War on Drugs 2. 0, represent a comprehensive approach to combat the growing drug abuse and illicit drug trade in the state. The 2018 campaign focused on tackling the rampant issue of illegal poppy cultivation, disrupting drug trafficking networks, and curbing drug abuse through a combination of law enforcement and public awareness efforts.

One of its key actions was the destruction of poppy plantations, both manually and using aerial methods like herbicide spraying with drones. The initiative also included large-scale drug seizures, with significant amounts of heroin, ganja, and other illicit substances confiscated, and the arrest of hundreds of individuals involved in the trade. The state set up Fast Track Courts to expedite drug-related cases, and schools were targeted with the Nisha Thadoklasi campaign, aimed at creating drugfree campuses and educating students about the dangers of drug abuse. In 2022, the War on Drugs 2. 0 initiative took a more robust and expanded approach, leveraging modern technology such as satellite imagery and drones to more effectively identify and destroy poppy plantations.

The focus shifted towards enhanced surveillance of trafficking routes, especially those connected to Myanmar, and increased efforts to intercept drug shipments. The initiative also placed greater emphasis on community policing, involving local communities in prevention efforts and supporting rehabilitation programs. To strengthen support for drug-affected individuals, TRUST centers (Tobacco and Drug Rehabilitation and Supportive Treatment) were established, with new guidelines introduced in 2024 to improve rehabilitation services. The War on Drugs 2. 0 also included efforts to improve the coordination between law enforcement, rehabilitation centers, and community organizations to create a multi-dimensional approach to the drug crisis. By 2023, the initiative had led to the destruction of over 1853 acres of poppy plantations and the seizure of significant quantities of illegal

substances. Furthermore, 222 drug-related cases were registered, and 264 people were arrested, underscoring the ongoing efforts to curb the drug menace. Moving forward, the state is working on finalizing its State Drug Policy, which will further strengthen the legal framework and provide more effective enforcement and rehabilitation mechanisms in the fight against drugs. The government of Manipur has implemented various initiatives to address the drug abuse crisis in the state, with a focus on both demand reduction and supply control measures. On the demand reduction front, the state government has established a network of Integrated Rehabilitation Centres for Addicts (IRCAs), which provide free-of-charge, comprehensive treatment and rehabilitation services for individuals struggling with substance use disorders.

These centers offer a range of interventions, including detoxification, counselling, vocational training, and follow-up support. Additionally, the state government has implemented schoolbased prevention programs, aimed at educating the youth about the dangers of drug abuse and promoting healthy lifestyle choices. These programs involve the dissemination of awareness materials, the training of teachers and counsellors, and the establishment of peer support groups within educational institutions. 24 To enhance the capacity of the healthcare system in managing substance use disorders, the government has also trained and deployed a cadre of community-based outreach workers, known as "Barefoot Counselors," who serve as the first point of contact for individuals seeking help with their drug-related issues.

25 On the supply control front, the Manipur Narcotics Control Bureau (MNCB) has intensified its efforts to disrupt the drug trafficking networks operating within the state. This has included the implementation of stricter law enforcement measures, the seizure of illicit drugs and precursor chemicals, and the strengthening of crossborder cooperation with neighboring states and countries. While these government initiatives have had some positive impact, the study's findings suggest that their overall effectiveness in curbing the drug abuse crisis in Manipur remains limited. Participants highlighted the need for more sustained and comprehensive approaches that address the underlying socio-economic and political factors driving the problem. Guidelines on TRUST Centres (Tobacco and Drug Rehabilitation and Supportive

24 Manipur Crisis Related to War on Drugs: CM N. Biren Singh, Imphal Free Press,

https://www.ifp.co.in/manipur/manipur-crisis-related-to-war-on-drugs-cm-n-biren-singh#google_vignette (last visited Nov. 14, 2024). 25 June 2018 Report on the Drug Problem in Manipur, E-Pao, https://e-pao.net/GP.asp?src=13..270618.jun18 (last visited Nov. 14, 2024).

Treatment) Guideline 4 includes provision of free treatment: Para 11. 13 of the Manipur State Policy on Psychoactive Substances, 2019 lay emphasis on the need to provide free treatment to clients who cannot afford. TRUST centres shall reserve at least 1(one) client/bed per course for 30 bedded centre and 2 (two) clients/beds per course for 50 bedded centres for providing free treatment to clients who belong to economically weaker section of the society. Some Judgments/Case Studies Thoubalmayum Rafique v. Special Secretary (Home), Government of Manipur26 In the case of Thoubalmayum Rafique v. Special Secretary (Home), Government of Manipur, the High Court of Manipur ultimately set aside the detention order issued against the petitioner.

The petitioner, who was arrested for his alleged involvement in drug trafficking (specifically the sale of heroin and the possession of significant amounts of cash), challenged a preventive detention order issued under Section 3(1) of the Prevention of Illicit Traffic in Narcotic Drugs and Psychotropic Substances Act (PIT-ND & PS), 1988. The court ruled that the detention order, passed under the Prevention of Illicit Traffic in Narcotic Drugs and Psychotropic Substances Act (PIT-ND & PS), 1988, was invalid due to unexplained delays in the disposal of the petitioner's representations by both the State and Central Governments. The court found that the second representation by the petitioner had not been considered at all, and the first representation had been delayed for 20 days without any adequate explanation.

Based on the constitutional safeguards concerning personal liberty and the right to a speedy review of detention orders, the court held that such procedural lapses violated the petitioner's rights. Order: The detention order was quashed, and the petitioner was to be released from detention, unless he was required in connection with any other case. The court emphasized that the detention order could not be upheld in the absence of timely and justifiable action on the representations, which were central to the legal process in preventive detention cases. Pukhrimayum v. Special Secretary (Home), Government of Manipur27 In the case of Pukhrimayum v. Special Secretary (Home), Government of Manipur (W. P. (Crl. ) No. 48 of 2022), decided on January 20, 2023, the petitioner challenged her preventive

26 2023 SCC OnLine Mani 43

27 2022 SCC OnLine Mani 496

detention under the Prevention of Illicit Traffic in Narcotic Drugs and Psychotropic Substances Act, 1988. The detention order was issued by the Special Secretary (Home), Government of Manipur, on October 4, 2022. The primary ground for challenge was the unexplained delay in the disposal of the petitioner's representation against the detention. The representation, made on October 19, 2022, was rejected by the State Government only on November 11, 2022, despite the petitioner's representation being forwarded to the relevant authorities on October 20, 2022. The delay was explained by the State Government as being due to the high volume of work in the Home Department. However, the Court found this explanation insufficient, emphasizing that such delays in handling representations undermine the constitutional safeguards of the detenu's right to liberty.

The Court referenced several Supreme Court rulings, including Rajammal v. State of T. N. (1999) and Professor Khaidem Ibocha Singh v. The State of Manipur (1972), highlighting that delays in considering a detenu’s representation can invalidate the detention order. It further emphasized that procedural safeguards must be followed strictly, especially when preventive detention laws are invoked, to protect the constitutional rights of individuals. Although the "War on Drugs" initiative by the Government of Manipur was acknowledged as a positive step to combat illicit drug trafficking, the Court ruled that procedural due process cannot be compromised in the process. The delay and lack of urgency in dealing with the petitioner's representation were considered fatal to the legality of the detention order.

Order: The Court set aside the detention order and directed the immediate release of the petitioner, unless she was required for any other lawful detention. The Court also instructed the Chief Secretary, Government of Manipur, to ensure better adherence to procedural norms in future preventive detention cases. The petition was allowed without any order as to costs. Zam Zam v. Special Secretary (Home), Government of Manipur28 In the case of Zam Zam v. Special Secretary (Home), Government of Manipur, decided on December 20, 2022, the petitioner challenged the detention order issued by the Special Secretary (Home), Government of Manipur, under Section 3(1) of the Prevention of Illicit Trafficking in Narcotic Drugs and Psychotropic Substances Act, 1988 (PIT-NDPS Act). The petitioner had been arrested in connection with the seizure of 222. 85 kg of heroin (brown sugar)

28 2020 SCC OnLine Mani 164

from her mother's residence, and the authorities sought to detain her under preventive detention laws to prevent her from continuing illicit drug trafficking. The primary ground for challenging the detention order was that the detaining authority failed to provide adequate material to support the opinion that the petitioner was likely to be released on bail. The petitioner had filed a bail application, but the detaining authority did not consider the applicability of Section 37 of the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act), which imposes strict conditions for granting bail in cases involving commercial quantities of narcotics. Section 37 of the NDPS Act requires that the Court be satisfied that there are reasonable grounds to believe the accused is not guilty of the offence and will not commit further offences while on bail.

The Court found that the detaining authority's reliance on the mere filing of a bail application was insufficient to establish that the petitioner was likely to be granted bail, especially given the involvement of a commercial quantity of heroin. The Court cited the Supreme Court’s judgment in Sayed Abul Ala v. Union of India (2007) 15 SCC 208, emphasizing that the detaining authority must apply its mind to the specific restrictions on bail under Section 37 of the NDPS Act and must provide reasoned justification for the likelihood of the detenu being released on bail. The Court concluded that the detaining authority had not properly considered these factors and had issued the detention order in a routine manner, without adequate reasoning or application of mind.

Despite recognizing the Government of Manipur's efforts to combat drug trafficking, the Court underscored the importance of adhering to procedural safeguards in preventive detention cases. The Court ruled that the detention order was invalid, setting aside the order and directing the immediate release of the petitioner, unless she was required for any other lawful detention. Order: The detention order and all consequential proceedings were set aside, and the petitioner was directed to be released unless her continued incarceration was required in another case. Community Network for Empowerment v. State of Manipur29 In the Public Interest Litigation (Community Network for Empowerment v. State of Manipur, PIL No.

32 of 2020), decided on July 21, 2020, the petitioners, a registered society, sought judicial intervention to address the lack of regulation and monitoring of private drug rehabilitation centers in the state of Manipur. The petitioners raised concerns about the growing

29 2021 SCC OnLine Mani 265

drug abuse problem in the state, highlighting that while there were 21 state-funded Integrated Rehabilitation Centres for Addicts (IRCAs), these were insufficient to meet the needs of the population, especially given the rising number of drug users. The petitioners pointed out that approximately 54 private/self-run drug rehabilitation centers in the state were operating without government oversight, leading to serious issues such as human rights violations, unscientific rehabilitation practices, poor sanitation, and instances of abuse and deaths within these centers. The petitioners requested the Court to issue a writ of mandamus directing the state to bring all private rehabilitation centers under state supervision and to establish minimum standards and guidelines for their operation.

The petitioners emphasized the need for proper regulation to ensure that these centers provide effective, humane, and scientifically backed rehabilitation services. The State, through the Advocate General, referred to several official communications, including a letter dated June 6, 2019, from the Directorate of Social Welfare, which acknowledged the problem and called for urgent government intervention to regulate private drug rehabilitation centers. The government was in the process of formulating a Manipur State Drug Policy to define minimum standards for these centers. The State assured that efforts were underway to draft regulations and establish a monitoring framework for private IRCAs. The Court, after reviewing the matter, did not find fault with the State's actions but emphasized the urgency of the situation.

The Court directed the government to frame regulations for the management and monitoring of private rehabilitation centers within three months, ensuring the implementation of proper standards and oversight. The PIL was disposed of with the expectation that the State would take necessary actions expeditiously to address the grievances raised by the petitioners in the interest of public health and social welfare. Order: The Court directed the Government of Manipur to frame regulations for private rehabilitation centers within three months and to take steps to address the issues of drug abuse and rehabilitation services in the state. The PIL was disposed of in favor of ensuring state action in the matter. Lunkhomang Haokip v.

Union of India30 This bail application pertained to the accused, Lunkhomang Haokip, who is charged under the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act) following the seizure of

30 2022 SCC OnLine Mani 348

Methamphetamine tablets. A pivotal issue raised is the interpretation of Section 43 of the NDPS Act, which permits officers of certain departments to seize narcotics in public places or while in transit. The lack of clear punctuation in Section 43 gives rise to two possible interpretations: (1) that any officer within the specified departments may seize or arrest without explicit empowerment, or (2) that only officers duly empowered under Section 42 may exercise these powers under Section 43 as well. Relevant precedent, including State of Punjab v. Balbir Singh and Roy V. D. v. State of Kerala, underscores the requirement that only authorized officers may conduct seizures or arrests under Sections 41 and 42 of the NDPS Act.

The Supreme Court, in these cases, clarified that only empowered officers could lawfully exercise the powers under the NDPS Act, thereby setting a strict standard for the protection of individual rights due to the Act’s stringent penalties. Applying a harmonious interpretation of the NDPS Act, the court concluded that Section 43 should be read to require duly empowered or authorized officers for seizure or arrest, even in public or transit settings. In the present case, Gajender Singh, a Subedar in the Assam Rifles without necessary empowerment or authorization under the NDPS Act, effected the seizure and arrest of the applicant. This procedural lapse is fatal to the prosecution’s case, as it undermines the legality of the arrest and seizure.

Additionally, there remains an element of uncertainty regarding the applicant’s knowledge of the concealed narcotics, compounded by his lack of any prior criminal record and his role as a hired driver for the vehicle. Order: The Court granted bail to the applicant, directing his release in Special Trial No. 54 of 2019 before the Special Court (ND & PS) in Manipur. The terms include a personal bond of Rs. 50,000 with one surety, along with a restriction on leaving the State of Manipur without prior court permission and refraining from any inducement or threats to individuals involved in the case. Mohd. Tamijur Rahaman v. Lilong Police Station31 In a recent judgment, the High Court of Manipur denied anticipatory bail to two Assistant Sub- Inspectors (ASIs) of police accused of involvement in drug trafficking and of accepting bribes to facilitate the release of detained suspects.

The court reviewed prima facie evidence suggesting that the ASIs had exploited their positions to aid drug smugglers, violating Sections 8(c) and 22 of the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act). These

31 2024 SCC OnLine Mani 239

provisions prohibit the unauthorized manufacture, transport, possession, and sale of narcotics, with penalties designed to deter and penalize drug-related offenses, reflecting the Act’s intent to curb societal harm from drug abuse and trafficking. The Court’s decision drew on Section

438 of the Criminal Procedure Code (Cr.P.C.), which allows for anticipatory bail but cautions

against its use except in exceptional cases. Citing the Supreme Court’s guidance in Nathu Singh v. State of Uttar Pradesh (2021), Siddharam Satlingappa Mhetre v. State of Maharashtra (2011), and Jai Prakash Singh v. State of Bihar (2012), the Court underscored that anticipatory bail should be narrowly tailored, particularly in cases where public officials might misuse their influence to interfere with investigations or tamper with evidence. Additionally, the Court referenced Gurudev Singh v. State of Punjab (2021), which recognized drug offenses as grave societal hazards, impacting countless vulnerable lives and undermining public welfare. Given the petitioners’ roles as law enforcement officials within the Narcotics Cell, the Court found it imperative to deny anticipatory bail, as the petitioners posed a risk to the integrity of the investigation and might misuse their authority.

Finally, in light of the rise in drug trafficking within the state, the Court directed the Government of Manipur to establish a State Level Committee led by a Senior IPS officer and District Level Committees under the Superintendent of Police to monitor drug-related cases. The case is scheduled for further orders on September 19, 2022, to ensure compliance with these directions aimed at intensifying the State’s anti-drug efforts. Order: The anticipatory bail applications of the petitioners, Assistant Sub-Inspectors of Police, were dismissed. The interim pre-arrest bail was vacated, and the petitioners were directed to surrender before the investigating officer within one week. The court found no exceptional circumstances to grant anticipatory bail, citing the petitioners’ involvement in drug-related offenses and potential interference with the investigation.

Additionally, the Government of Manipur was directed to form a Special Committee, headed by a senior IPS officer, to monitor drug-related cases at the state level, with district-level sub-committees, within two weeks. Korimayum Ruksana v. Nambol Police Station32 In the case involving Korimayum Ruksana, the Court carefully reviewed the allegations presented by the prosecution and concluded that the respondent state had failed to establish a prima facie case against the accused. The allegations, while suggesting involvement in the drug

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offense, did not provide direct evidence linking Ruksana to the crime or indicating her prior involvement in similar offenses. Notably, Ruksana was a young student at D. M. College and an O. T. T. trainee at Langol View and Research Institute, which her counsel emphasized as part of her defense. Key arguments included the release of similarly situated co-accused, the fact that the seized contraband weighed only 238 grams, which fell under the category of intermediate quantity according to the law. As such, the appropriate legal provision to apply was Section 439 of the CrPC, rather than Section 37 of the NDPS Act, which would typically apply to larger quantities. Furthermore, Ruksana’s counsel pointed to Section 21 of the NDPS Act, which prescribed lesser penalties for offenses involving intermediate quantities.

The defense also cited several rulings from the Supreme Court, including State of Punjab v. Baldev and Bhagirathsinh Judeja v. State of Gujarat, asserting that in the absence of a prima facie case, detention should not be used as punishment and that the focus should be on whether the accused would be available for trial. The counsel also referenced the Suaibo Ibow Casamma v. Union of India case from the Bombay High Court, which emphasized constitutional protections and argued that Ruksana's detention violated those safeguards. Order: Taking all arguments into account, the Court found that the Special Judge, Bishnupur, had passed the impugned order without adequate consideration of the facts and legal principles. Consequently, the Court set aside the order and granted Ruksana bail, subject to the furnishing of a surety bond of Rs. 1,00,000/- (Rupees one lakh). Ebem v.

State of Manipur33 In the case of Ebem v. State of Manipur, the petitioner, Ebem, the second wife of the main accused in FIR under Section 21(b) of the ND & PS Act, sought anticipatory bail under Section

438 of the Cr.P.C. The FIR initially involved Shahabuddin Shah, who was accused of running

a drug business for over ten years. During police interrogation, Shahabuddin disclosed that he procured heroin powder from a supplier in Moreh and sold it for profit. He also implicated his second wife, Ebem, stating that she was involved in the drug business, along with their son, Md. Shajid, who assisted in selling drugs. The Investigating Officer, however, had not conducted a thorough investigation nor seized any contraband from Ebem at the time of filing the petition. Order: The Court, after considering the statement made by the main accused and the lack of direct evidence or seizure from the petitioner, granted anticipatory bail. The conditions

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included the execution of a surety bond of Rs. 25,000/- to the satisfaction of the Special Judge, ND & PS, and the requirement for the petitioner to report daily to the Investigating Officer at 10:30 AM. The Court also directed the petitioner not to tamper with witnesses or interfere with the ongoing investigation. Analysis from a Criminology Perspective The drug problem in Manipur, like in many other regions, is a complex issue with social, economic, political, and criminological dimensions. To understand this issue more effectively, criminological theories can be applied to explain the underlying causes and consequences of drug trafficking and substance abuse in the region.

Theories such as Strain Theory, Social Disorganization Theory, Routine Activities Theory, Differential Association Theory, and Labelling Theory provide valuable insights into the dynamics of the drug trade and its impact on the society of Manipur. Strain Theory (Robert Merton) Strain Theory posits that crime arises when individuals or groups are unable to achieve socially approved goals through legitimate means, leading them to resort to deviant behaviors, such as drug trafficking or drug use, to achieve success34. In the context of Manipur, strain theory can explain why many individuals, especially the youth, turn to drug trade or abuse as a way of coping with the socio-economic pressures they face. The prolonged political instability, unemployment, poverty, and lack of economic opportunities in the region exacerbate feelings of frustration and hopelessness among the population.

These conditions create a strain, pushing individuals to engage in illicit activities, such as drug trafficking, as a means of survival or achieving material success. The lack of legitimate avenues to achieve financial security or social recognition compels individuals to resort to illegal drug trading. This theory helps to explain how the combination of socio-economic adversity and lack of access to legitimate means leads to the proliferation of drug-related crimes in Manipur. Social Disorganization Theory (Shaw and McKay) Social Disorganization Theory asserts that crime occurs when social institutions (such as family, education, and law enforcement) fail to function properly in a community, leading to a breakdown in social control and an increase in criminal activity. 35 This theory is especially

34 Robert K. Merton, Social Structure and Anomie, 3 Am. Sociological Rev. 672 (1938).

35 Shaw & McKay, Social Disorganization Theory: Key Concepts in Criminology, in Crime in Cities: Patterns and Problems (Clifford Shaw & Henry McKay eds., 1942).

relevant to Manipur, a region that has long experienced political instability, ethnic conflict, and insurgency. The breakdown of family structures and community ties, combined with the state's weak infrastructure and law enforcement, creates an environment where criminal activity, including drug trafficking, can thrive. The theory suggests that areas marked by poverty, instability, and a lack of social cohesion tend to experience higher crime rates, as individuals in these areas are less likely to adhere to social norms. In Manipur, insurgent groups and transnational crim