PUCL’s reply to legal notice issued by All Manipur Working Journalists’ Union (AMWJU)

Dec 22, 2025
By Shahrukh Alam

Dear Sir, 

 

On instructions from our clients, the President and General Secretary of the People’s Union for Civil Liberties (PUCL), having office at 332, Ground Floor, Patparganj, Opp. Anand Lok apartments, Mayur Vihar – I, Delhi 110091, we are issuing to you the following reply to your notice dated 06.11.2025. 

  1. Our clients state that though the Notice sent by you is dated 06.11.2025, it was received in the National Office in Delhi only on 18.11.2025. 
  2. At the very outset our clients deny the allegations levelled by your client against them in the notice and your client is put to strict proof of the same. 
  3. Our clients who are office bearers of the People’s Union for Civil Liberties (henceforth referred to as PUCL), is one of India’s oldest voluntary human rights organisations which was founded by freedom fighters such as Jayaprakash Narayan, Acharya Kripalani and others, during the Emergency, the darkest period in the history of independent India. The PUCL has since been headed at the national level by stalwarts such as Justice V.M. Tarkunde, (former Judge of the Bombay High Court), Prof. Rajni Kothari (eminent Sociologist), Justice Rajinder Sachar (Retired Chief Justice of the Delhi High Court), eminent jurists like Mr. K.G. Kannabiran, Senior Advocate, and Mr. Ravikiran Jain, Senior Advocate and Prof. Prabhakar Sinha, (renowned academic). PUCL works through peaceful, non-violent actions to highlight issues of rights violations and demand for justice. It has been in the forefront of issues pertaining to civil liberties and democratic rights for the last 45 years. The PUCL is a completely voluntary body and members consist of lawyers, doctors, scientists, professors, teachers, journalists and others. PUCL uses dialogic and democratic tools of human rights and undertakes enquiry mechanisms like Fact Finding Teams and Tribunals to visit violence and conflict affected area, meet various sections of society affected by social and state violence and come out with reports bringing to public attention the facts uncovered by the Fact-Finding exercise. PUCL also works to create safe spaces for discussion and dialogue amongst people caught up in situations of gross human rights violations, caste and communal conflict, and works to find a way forward to bring about peace and reconciliation while at the same time demanding accountability of those in power.
  4. PUCL has filed several public interest litigations in the Supreme Court and in the High Courts, and many of the judgments are important landmarks in the development of human rights law in our country. Amongst the most significant rulings are cases related to fundamental right of speech and expression under Art. 19(1)(a), which is one of the key underpinning of democracy and rule of law. It is based on asserting the primacy of right to free speech, that PUCL won the case against illegal telephone tapping by the government, popularly known as the telephone tapping case (PUCL vs Union of India, 1997 (1) SCC 301). Again, in `PUCL vs Union of India’, 2003 (4) SCC 399, the SC expanded the right of citizens to free speech and expression to include the citizen’s “right to Know” about the antecedents of electoral candidates as an elementary part of the electoral system underlying republican democracy. 
  5. Our client states that in March, 2024, they constituted the `Independent People’s Tribunal (IPT) on the Ongoing Ethnic Conflict in Manipur’ against Kukis. Several hundred people were reportedly killed and tens of thousands displaced from their homes and villages. Over 60,000 people from both ethnic groups were living in IDP Camps. Houses were abandoned, especially in Imphal city, and the state was virtually divided into two halves: with the Meitei community living and confined to the Imphal valley and the Kukis living and confined in the Hills. A deep sense of hostility, distrust, suspicion and fear existed between the communities. What was striking about the prolonged state-wide violence was the total breakdown of constitutional governance in Manipur state amidst the allegation that the State Government was playing a partisan role. Police armouries were reportedly raided by some armed groups resulting in the theft of significant quantities of modern arms, weapons, ammunition and explosives which were reportedly used in the ethnic conflict.
  6. It was in such a fraught situation, that the `Independent People’s Tribunal’ (IPT)was constituted consisting of experts of eminence from different fields, who were independent of PUCL. The Tribunal Jury was headed by former Supreme Court judge, Justice Kurien Joseph. Justice Kannan, former Judge Punjab and Haryana High Court and Justice Anjana Prakash, former Judge, Patna High Court were other members. Other jury members included highly respected academics, journalists, former IAS/ IPS officers, lawyers, women’s right and human rights activists.The Terms of Reference of the IPT was to document in a detailed manner, the violations suffered by the people of Manipur including loss of life, sexual violence and violence suffered by vulnerable social sections, study and analyse the roots of the present conflict, examine the role of constitutional functionaries – the government officials, security forces and others, and to come out with recommendations “to repair the torn social, cultural and political fabric of the state”. (page 42).
  7. Our clients acted as the `Secretariat’ to the IPT along with other PUCL members and non-members, who volunteered to work on this issue. The Secretariat gathered written testimonies and reports from persons belonging to various communities, collected documents like FIRs, court documents, official reports, media accounts, research papers and so on and shared them with the IPT members, who were experts in different fields.
  8. Some members of the Tribunal and the Secretariat visited Manipur between 28th May to 4th June, 2024 and visited affected areas as also IDP camps in various districts; additionally sittings were held in Delhi on 6th and 7th July, 2024 where again jury members met persons from both communities, as also experts, journalists and others informed about Manipur and the conflict. Apart from this, a number of online meetings were also held for those who wanted to depose before the IPT Jury members. 
  9. The observations and findings of the tribunal are based on the voices of the survivors and deponents from various communities – Kukis, Meiteis, Nagas, Pangals and others – who deposed before the tribunal and the documents placed before the jury as also visits to various relief camps of both communities. The testimonies of the people have been relayed in the report in their purest form, to provide a fair chance to convey their truth. Of course, issues of confidentiality have been kept in mind and names of deponents anonymised. It is quite possible that different readers may have a different understanding of events and happenings, but what is very urgently required is an open and honest discussion amongst all sections of Manipur society about events, experiences and situations that had overtaken them in 2023-24.
  10. Our clients state that in effect the Tribunal ended up in becoming a platform for people from the affected communities to share their experiences of the strife and violence that they have been subjected to over the last 2 years; to talk about their “sense of insecurity in being uprooted and displaced while articulating the indignity, fears and insecurity they faced during their exile in relief camps … and their plea to be seen, heard and acknowledged by the rest of India and the world … and to honestly report both communities’ cry for justice and yearning for peace as also to spotlight the numerous acts of courage and compassion extended to members of the conflicting communities towards one another during the height of the violence and thereafter.” (pages 652-53 of the IPT Report). 
  11. Our clients state that both the Secretariat and also the IPT have striven to ensure that the opinions and testimonies of the witnesses before the Tribunal stay true to what was told to them. The methodology of the report has been described in the Report itself. A fuller explanation about the Methodology followed by the IPT has been detailed in a Note published by our clients titled “Moving beyond Revenge and Retribution to Truth, Justice and Reconciliation: How to Read the IPTs Report – An explainer” . 
  12. In keeping with the objectives of the IPT of documenting the violations suffered by the people of Manipur, examining and analysing the performance of responsibilities of the constitutional authorities, security agencies and government functionaries and existing documentation on the Manipur situation, the Tribunal members decided to meet with and record testimonies of local journalists, media professionals, social media content creators  and others conversant with and have written about the conflict in Manipur. (Chapter 7, pp. 350 to 366).
  13. These experienced journalists who have covered and witnessed many conflict situations in the last 30 years and more, were unequivocal about the fact that the entire ethnic conflict that has engulfed Manipur since 3rd May, 2023, was not spontaneous or organic, but reflected the results of deliberate stoking of hate, fear, anger, hostility and sense of revenge or retribution and a planned outbreak of violence. A common refrain from many of them is worth repeating: “The clue to understanding the current conflict lies in asking the hard questions: `Who gains by allowing the conflict to keep festering? Who benefits by the non-resolution of the conflict? What is the advantage by forcing tens of thousands of Manipuris from various sides to live in IDP camps? What does the Central Government gain by allowing the present leadership (under Biren Singh) to continue and not seriously do anything to stop the conflict? The answers to these questions will provide the clue to understanding the present conflict.” (page 366).
  14. The key role that the media can play in bringing about truth, justice and reconciliation was briefly revealed in the incident of 2 Air Hostesses of Manipur, one Meitei and another Kuki, who died in the tragic Air India crash in Ahmedabad on 12th June, 2025.  The Report highlights, “Shared grief surfaced at the tragic deaths of two young Manipuri air hostesses. A senior journalist noted that when the news broke, the state mourned both as Manipuris, not divided by community. There was even a gesture from the Meitei leadership urging that the Kuki family bring their daughter’s body back to Imphal. But fear won out. Instead, the family chose to travel from Ahmedabad to Dimapur, and from there to their current shelter in Kangpokpi. Their home in Imphal, once in the heart of Lambulane, remains abandoned. This, according to the journalist, is the tragedy of Manipur: brief glimpses of unity, followed by reversion to division. Unless both communities can move past victim and perpetrator roles, unless they meet in truth and reconciliation, the status quo will persist”. (page 691).
  15. The IPT Report concludes in the `Epilogue’ section pointing out that what is absent is what people crave the most: a process of truth, justice, and healing – the will to face the pain honestly, the courage to meet across the lines, the humility to accept that both sides have suffered, and that peace, if it is to last, must be just, inclusive, and real. The Report points out, “In Manipur, if the government only focuses on short-term political management (negotiations, military deployment or even autonomy deals) without addressing past violence and grievances, the conflict may resurface periodically …. (and) any long-term solution must go beyond political elite discussions and involve village-level reconciliation, inter-community dialogues and truth-telling mechanisms …… Without genuine reconciliation efforts, cycles of violence and distrust will continue, regardless of who is in power”. (page 622).It is this task that the Report points out that needs to be urgently addressed. 
  16. Our clients state that they have clarified several times that neither they nor the jury members of the IPT had or have the intention of dividing communities in Manipur in any way or thwart, put hurdles and prevent the peace process in Manipur or to paint one community as victims and another as perpetrator or to keep the hatred and cycle of violence to keep simmering without resolution. To the contrary they, and the PUCL remain committed to the process of truth, accountability and justice as a means to helping build durable peace and reconciliation in Manipur. PUCL always believes in the intrinsic goodness and `humaneness’ of all people in general, and believes that even in situations of hostility, bitterness and conflict it is possible to find common ground to bring about rapprochement and harmony through a process of finding the truth, building on peace, initiating dialogue and strengthening reconciliation.
  17. It is in the spirit of moving beyond revenge and retribution to `Truth, Justice and Reconciliation’ that the Report called upon the media,  to undertake this crucial task along with civil society groups, human rights and women’s organizations and concerned citizens.

Issue-wise Rebuttal

  1. Given the understanding of the spirit and purpose underlying the IPT’ Report, we provide an issue wise rebuttal to your legal notice dated 06.11.2025. At the outset before adverting to the specific claims in your notice dated 06.11.2025, our clients categorically deny that they have published malicious, unsubstantiated allegations against your client. Your client is put to strict proof of the same.
  2. In Part `A’ of your notice dated 06.11.2025, which is titled as ‘Character assassination and defamation’, you have extracted the following portion from page 362 of the Report –

“A Meitei Journalist said: “We have a journalists’ Union, All Manipur Working Journalists Union. This Union has a decisive role in how to carry a story, how to kill a story. It operates like a Godi media and they are pro-Biren Singh”.

  1. Our clients deny that these statements are defamatory. As stated above, the intention of the IPT and our client was to enable different voices within Manipur to have an opportunity to voice their opinions. Our client submits that the above extract is merely that, an opinion received by the IPT during its hearings which it had a duty to record and report as authentically as possible. The reporting of the same is not a determination of fact but to create an opportunity for critical voices to engage with those with power like your client. It is rather unfortunate and ironic that your client, instead of using this as an opportunity to have critical discussions with its members, is instead resorting to attempts to muzzle free speech and freedom of expression.
  2. Thus, our client submits that the above extract was a justified publication in larger public interest and is hence not defamatory in action or by law.
  3. Our clients state in your notice dated 06.11.2025, in Section B –‘False Imputations of threat and coercion’, you have referred to statements recorded in page 362 of the IPT report where journalists have stated that they were warned, threatened and gun put to their head if they did not follow the “consensus”. Your client has then refuted these allegations and stated that they have not participated in any such actions and such imputations are deeply malicious and false.
  4. Our clients submit that upon a perusal of those statements, it is clear that those statements have been made generally and are not imputed or attributed to your client in any form or manner. Therefore, your client’s claim for defamation is denied for the simple reason that it is not in reference to your client.
  5. Similarly, our clients submit that in `Section C’ of your notice dated 06.11.2025 titled ‘Misrepresentation of media and ownership’,  your client has given an explanation about its membership and the laws that govern media. Our client appreciates this explanation regarding the membership criteria followed by your client. However, it is denied that these statements are defamatory in either form or intent for the simple reason that these statements are once again not regarding your client but general statements made about the media industry. 
  6. Our clients submit that even with reference to Section D of your notice dated 06.11.2025, titled ‘Mischaracterisation of “Imphal based media” and irresponsible framing”, the reference made to statements recorded at Page 363 of the report are not about your client in either fact or implication. Those are general statements of an individual that has been recorded. Therefore, your client cannot claim defamation in either action or intent and the same is categorically denied.
  7. Thus, our clients state that the portions of the IPT report which have been referred to by your client are not defamatory in content or intent. Therefore, your client’s claim of defamation is categorically denied and they are put to strict proof of the same. 
  8. Our clients have been advised that the Hon’ble Supreme Court of India has time and again held that all persons (and institutions) who are in the public sphere should not be too sensitive and react to public criticism. With regard to the statements impugned in your notice dated 06.11.2025, only one statement has been made critical of your client which is a justified publication in public interest. The other three statements impugned are not in reference to your client. While your client may disagree with the opinions recorded in those statements, a difference of opinion is not cause for legal action of any kind including claims of defamation. 
  9. It is rather unfortunate and deeply ironic that your client, being a union of journalists, is seeking to muzzle opinions with which it disagrees through the threat of defamation thereby thwarting the right to free speech, a guaranteed fundamental right under Art. 19(1)(a) of the Constitution. Such tactics is recognised world over as being a form of SLAPP (Strategic Litigation Against Public Participation) which has particularly been used by those in power to silence critical journalists and publications. SLAPP recognizes that the threat of litigation and costs causes many critical voices to silence themselves for fear of legal action or costs. SLAPP is a tool by which public issues are turned into private disputes ensuring that the critical discussions are removed from the public forum and into the courts, effectively preventing society from addressing these issues for itself. PUCL has in fact time and again called upon the judiciary to take punitive action against such litigation since they are an abuse of the court process. 
  10. Our clients state that it is not the intention of the PUCL to defame or to publish false and unverified statements. All conclusions in the report are based on testimony by the deponents before the Tribunal. However since our client’s intention is the promotion of peace between the communities and not to inflame feelings, any clarification of facts which you can provide will be considered. 
  11. In light of the above, we therefore call upon you to withdraw your notice dated 06.11.2025 immediately. If your client wishes to proceed with any further proceedings, our client will be constrained to seek punitive compensation and action for malicious prosecution, which will be at the cost of your client.