Annexation of Manipur as the 19<sup>th</sup> State of India: The Status of the Territory of Manipur in International Law since 1949

Abstract

In international law, deprivation of a people or nation of its political independence takes place through conquest or military occupation and annexation or formal integration. The incorporation of Manipur into the Union of India in 1972 characterizes the ultimate official annexation of the former by the latter. Annexation brings in political implications on the status of people of the annexed territory such as obliterating their earlier historical existence while imposing a new sense of allegiance to a foreign rule. In this context, the present article re-examines the nature of Indian occupation and subsequent annexation of Manipur. It seeks to highlight the international status of the territory of Manipur beginning 1949 by offering analytical treatment to two co-related phenomenon of occupation and annexation of a territory in international law. It is argued that the prohibition of annexation resulting from occupation is not merely concerned with normativity of international law but represents the implications on the lives of the people whose territory has been annexed. A critical review of the normative standards of international law as embodied in the Charter of the United Nations, resolutions by UN bodies, and a summary analysis of decisions of the International Court of Justice rendered in cases such as Palestine, Western Sahara, East Timor, etc. shows three distinct features in the relationship between the Union of India and Manipur—first, occupation of Manipur by India since 1949; second, annexation or formal incorporation of the territory of Manipur into Indian Union in 1972; and third, Indian State has assumed the role of an administering Power over the territory of Manipur with the implication that Manipur continues to remain an occupied territory under international law.