Recently, Manipur Chief Minister N. Biren Singh resigned and the State was put under President’s Rule. 

Background of President’s Rule

• Article 355: According to Article 355 of the Indian Constitution, It shall be the duty of the Union to protect every State against external aggression and internal disturbance.
• Article 356: The President, under Article 356, is empowered to make a proclamation when he is satisfied that the government of a state cannot be carried on in accordance with the provision of the Constitution.
  • By such proclamation, the President may assume to himself all or any of the functions of the executive of the State and declare that the power of the legislature of the State shall be exercisable by or under the authority of Parliament. 
• Article 365:  Article 365 in the Constitution states that  Effect of failure to comply with, or to give effect to, directions given by the Union. 
  • Where any State has failed to comply with or to give effect to any directions given in the exercise of the executive power of the Union under any of the provisions of this Constitution.
  • It shall be lawful for the President to hold that a situation has arisen in which the Government of the State cannot be carried on in accordance with the provisions of this Constitution.

Constitutional Provisions regarding Presidents Rule

• Imposition: President’s Rule is invoked under Article 356 of the Indian Constitution in case of the failure of the constitutional machinery in a state.
  • It empowers the President to assume control of a state’s government, taking over its functions and powers, transferring them to the Union government.
• Powers: The powers of the State Assembly are shifted to Parliament under this provision.
• Conditions for Imposition: Governor’s report or other inputs may lead to the imposition of President’s Rule. 
  • The President issues a Proclamation, which must be laid before Parliament and is valid for two months unless ratified by both Houses. President’s Rule can be extended for three years, with renewals every six months. 
  • Post-first year, renewal requires specific conditions: an Emergency declaration or inability to hold elections in the state.
• Limitations of President’s Rule: The President cannot assume any powers vested in a High Court.
• Constitutional Ambiguities: Article 356 does not list specific circumstances under which President’s Rule can be imposed.  The President’s judgment, based on advice from the Union Council of Ministers, plays a key role in determining the necessity of this provision.
• Situations Leading to President’s Rule: According to the Lok Sabha Secretariat’s 2016 report, President’s Rule has been invoked in cases like:
  • Defections by MLAs
  • Break-up of coalitions
  • No-confidence motions
  • Resignations of Chief Ministers
  • Absence of legislatures in newly formed states
  • Public agitations leading to instability
• S.R. Bommai Case: The 1994 S.R. Bommai vs Union of India case outlined scenarios in which President’s Rule could be imposed. 
  • The Supreme Court made it clear that the list provided was not exhaustive, and the final decision rests with the President based on the specific circumstances of each case.
•  A Shift in Judicial Approach: The Bommai judgment (1994) marked a significant shift in the judicial approach to President’s Rule. A nine-judge Bench held that courts had the authority to review the President’s proclamation.
  • Courts could examine whether the proclamation was issued based on relevant material and not issued in a mala fide manner.
  • This means that a proclamation could be struck down if deemed unconstitutional, providing a deterrent to the government.
• Legal and Political Impact: According to former Attorney-General Soli Sorabjee, the judgment ensures that the exercise of power under Article 356 is not arbitrary.
  • P.D.T. Acharya, a former Lok Sabha Secretary General, noted that the judgment created a clear deterrence against the misuse of this power.

Historical Instances of President’s Rule

• Total Instances: 135 instances of President’s Rule have been imposed across 35 States and Union Territories, including regions that no longer exist.
• First Instance: In June 1951, President’s Rule was imposed in Punjab after Chief Minister Gopi Chand Bhargava resigned due to internal party conflicts in Congress.
  • Punjab has spent over a decade under President’s Rule, primarily due to terrorist and separatist activities causing law and order instability.
• J&K: Jammu and Kashmir (J&K) holds the record for the longest duration under President’s Rule, with nearly 15 years of central control (including its status as a Union Territory). 
  • The longest continuous periods of President’s Rule in J&K were from 1990 to 1996 and from 2019 to 2024.
• Manipur: Manipur has now experienced President’s Rule for the 11th time.
• Uttar Pradesh: Uttar Pradesh follows closely with 10 instances of President’s Rule.
• Frequency from 1950 to 1994: Between 1950 and 1994, President’s Rule was imposed 100 times, averaging 2.5 times per year.
• Post-1994: Over the past three decades, the frequency has decreased, with 30 instances of President’s Rule, averaging about once a year. The Manipur imposition in 2025 marks the first instance since Puducherry in February 2021.
• President’s Rule Under the NDA Government:  Since the Modi-led NDA government came to power in 2014, President’s Rule has been imposed 11 times, including four times in Jammu and Kashmir (J&K). The courts have struck down two instances of President’s Rule during this period:
  • Arunachal Pradesh
  • Uttarakhand

Political Instances of Imposing President’s Rule

• Opposition vs. Central Government: It is more common for President’s Rule to be imposed in states where the ruling party is in opposition to the Central Government.
• President’s Rule Under the Same Party: Despite the usual opposition dynamics, President’s Rule has been imposed even when the same party governs both the Centre and the State. Notable instances include:
  • Andhra Pradesh in 1973
  • Assam in 1981
  • Gujarat in 1974
  • Karnataka in 1990
  • Manipur in 2025
• Era of Janta Party: In 1977, the Morarji Desai government imposed President’s Rule on nine Congress-ruled states, claiming these states had lost the confidence of the electorate that voted out Congress at the Centre.
• Era of Indira Gandhi: When Indira Gandhi returned to power in 1980, she imposed President’s Rule in nine states for similar reasons, mirroring the actions of her predecessor. The Supreme Court at the time chose not to interfere in these political actions.

Suspended Animation

• About: When a state is placed under President’s Rule, its legislative assembly can either be dissolved or kept in suspended animation. 
  • In suspended animation, the Assembly remains intact, but its functions are temporarily suspended. It can be revived once the President’s Rule is revoked and a popular government can be formed.
• Comparison with Dissolution: Historically, in 111 cases of President’s Rule until 2015, the Legislative Assembly was dissolved simultaneously with the proclamation 53 times. In the remaining cases, the legislature was kept in suspended animation.
• Legal Perspective: In the Bommai case, the Supreme Court held that placing the Assembly in suspended animation temporarily suspends its constitutional functions.
  • Constitutional lawyer Abishek Jebaraj noted that once President’s Rule is revoked, the suspension ends, and the Assembly is revived.
  • The court also cautioned that granting the President unfettered powers of dissolution would go against the Constitution’s original intent, as the framers never envisioned such power under Article 356.
• Criticism: P.D.T. Acharya, a former Lok Sabha Secretary General, argued that the concept of suspended animation has no constitutional basis.
  • He questioned its necessity, stating that if Parliament takes over all legislative functions, there seems to be no point in keeping the Assembly in existence in a suspended state.
  • He considered it unconstitutional, as it lacks clear sanction in the Constitution.

Conclusion

President’s Rule allows the Union to take control of a state in cases of constitutional failure, but its imposition is subject to judicial review. Landmark rulings like SR Bommai and Rameshwar Prasad curbed its misuse. Despite this, its application remains politically controversial.

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