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Justice Matrix · Case profile

Nandita Haksar v State of Manipur and Others, W.P.(Crl.) No. 6 of 2021

IndiaHigh Court of Manipur at Imphal2021Asia
FavorableHigh precedentVerified
Needs review

Machine-found from the cited source, not yet confirmed by a human. Open the source before relying on it.

Strategic issue

What was at stake

Whether Myanmar nationals, including journalists and children who entered India without documents after the Myanmar coup, could be protected long enough to approach UNHCR.

Facts

What happened

Myanmar nationals, including journalists and children, fled to India without documents following the February 2021 military coup in Myanmar. They were detained or at risk of deportation in Manipur. Nandita Haksar filed a writ petition seeking protection for these individuals and safe passage to Delhi to enable them to approach the United Nations High Commissioner for Refugees (UNHCR).

Key holding

What the court decided

The Manipur High Court held that Article 21 protects foreigners and that non-refoulement is encompassed within the right to life and personal liberty, subject to security concerns, then ordered safe passage to Delhi to approach UNHCR.

Reasoning

How the court got there

The Manipur High Court held that Article 21 of the Constitution, which guarantees the right to life and personal liberty, applies to all persons within Indian territory regardless of citizenship. The court found that the principle of non-refoulement—prohibiting the return of persons to countries where they face persecution—is implicit in Article 21. While security concerns may be considered, they must be balanced against fundamental rights. Accordingly, the petitioners were granted protection and ordered to be provided safe passage to Delhi to approach UNHCR.

Authorities

Statutes and cases cited

Statutes & treaties
  • § Article 21 of the Constitution of India
  • § 1951 Refugee Convention
  • § 1967 Protocol Relating to the Status of Refugees
Cases cited
  • MMAIF v. Union of India (M70/2011)
Issue areas

Categories

refugeeasylumimmigrationnon-refoulement
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