Central Bureau of Investigation v. Arun Khundongbam @ Nanao, & Connected Matter, Diary No. 22538-2026 & Dinganglung Gangmei v. Mutum Churamani Meetei and Ors. & Connected Matter, Diary No. 19206-2023 [Order dated July 24, 2026]
The Supreme Court on Friday indicated that it is considering the constitution of special courts for conducting day-to-day trials in cases arising out of the 2023 Manipur violence, while emphasising that investigations by the Central Bureau of Investigation (CBI) and the Special Investigation Teams (SITs) must reach a logical conclusion within a reasonable time.
During the hearing, the Bench of Chief Justice Surya Kant, Justice Joymalya Bagchi and Justice V Mohana reviewed the latest status reports filed by the CBI, SITs and the court-appointed monitoring mechanism, besides hearing submissions on issues relating to victims’ access to charge sheets, rehabilitation, compensation, missing persons and the reconstruction of vandalised places of worship.
The Court also directed counsel assisting victims to prepare a tabulated chart indicating the status of all pending cases where trials have commenced or are yet to commence, observing that such information would enable the Court to identify the number of judicial officers required for exclusive trials. Making its intent clear, the Bench observed:
“
“It may be true they might be facing some hardship in taking the ongoing investigation to a logical conclusion. Nevertheless, we are of the view that such pending investigations must reach a logical conclusion and must be completed within a reasonable time. We tentatively propose to constitute special courts, with the concurrence of the State of Manipur and the High Courts of Manipur and Gauhati, so that the trials can be taken up on a day-to-day basis, especially in light of the inordinate delay that has already taken place. This will be possible only when the CBI as well as the SITs are able to conclude the investigation and file their respective charge sheets. We therefore lay emphasis on both the agencies to do their best, irrespective of the impediments, and complete the investigation.”
The Bench further noted that complete details of all FIRs, investigations and charge sheets would assist it in assessing the number of special courts required and grouping similar cases for expeditious disposal.
On the issue of victim representation, counsel informed the Court that despite earlier directions, several victim families and legal aid counsel had not received copies of the charge sheets. Taking note of the concern, the Court sought a status update from the CBI while directing that a comprehensive chart of pending matters be prepared.
The hearing also witnessed submissions by the Christian Churches’ Council regarding the reconstruction of damaged places of worship. Counsel submitted that despite earlier directions issued in December 2023 and recommendations of the Justice Gita Mittal Committee, reconstruction had not commenced and instances of encroachment were continuing. He urged the Court to direct immediate eviction wherever encroachments had taken place and to appoint a nodal officer for verification and reissuance of title documents allegedly lost during the violence.
Key Observations
● Special Courts: The Court tentatively proposed constituting special courts, in consultation with the State of Manipur and the High Courts of Manipur and Gauhati, for day-to-day trials.
● Expeditious Investigation: CBI and SITs were urged to complete pending investigations and file charge sheets within a reasonable time.
● Trial Status Chart: Counsel were directed to prepare a comprehensive tabulated chart showing the status of trials to facilitate constitution of special courts.
● Victim Access to Charge Sheets: The Court sought clarification regarding non-supply of charge sheets to certain victims’ families and legal aid counsel.
● Church Reconstruction: The Bench agreed to consider issues relating to encroachment and reconstruction of places of worship after the pending bail matter is taken up on the next date.