Gauhati High Court granted bail to Thangminlen Mate, citing lack of prima facie evidence and procedural lapses in the NIA’s case against him.
BY PC Bureau
September 27, 2025, 1:00 PM IST — In a landmark ruling on September 25, 2025, the Gauhati High Court granted bail to Thangminlen Mate (@Lenin Mate), a 28-year-old Kuki community member arrested by the National Investigation Agency (NIA) in connection with violent clashes in Moreh, Manipur, on January 17, 2024. Delivered by Justices Michael Zothankhuma and Anjan Moni Kalita, the decision overturned a lower court’s rejection of Mate’s bail application, highlighting procedural lapses, evidentiary weaknesses, ethnic contradictions, and investigative inconsistencies.
This analysis explores the judicial reasoning in detail, incorporating the additional grounds cited by the bench to justify Mate’s bail, and examines the broader implications for law enforcement in Manipur.
The Case: A Tale of Two FIRs
Mate’s legal journey began with his arrest on May 19, 2025, by the NIA under FIR RC-05/2024/NIA/IMP, linked to the deaths of two Manipur Police Commandos during an early morning attack on an Indian Reserve Battalion (IRB) post in Moreh. He was granted bail on June 18, 2025, by the Special NIA Court in Guwahati, only to be re-arrested the next day under FIR RC-06/2024/NIA/IMP, alleging involvement in a related incident that killed another commando.
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Both cases, initially registered as FIR Nos. 26(1)/2024 and 25(1)/2024 by Moreh Police, were transferred to the NIA, invoking stringent laws including the Unlawful Activities (Prevention) Act (UAPA), the Arms Act, and the Explosive Substances Act.
A critical procedural lapse identified by the High Court was the NIA’s failure to disclose RC-06 during Mate’s RC-05 bail hearing. The bench noted, citing Uday Chand vs. Sk. Mohd. Abdullah (1983), that:
“If after the order of bail passed by us the authorities of the State considered it fit to arrest any of the petitioners for any other offences, it was their bounden duty to apprise this Court before taking these persons in custody.”
This omission undermined the judicial process and weighed heavily in Mate’s favor.
Judicial Reasoning: Multiple Grounds for Bail
The 16-page judgment detailed several reasons for granting bail:
Lack of Prima Facie Evidence
- The court found no corroborating evidence linking Mate to the attacks. Analysis of his mobile phone messages, Call Detail Records (CDRs), and social interactions revealed nothing to suggest involvement in the gunfire. The bench remarked:
“There is nothing in the messages to show that the petitioner was involved in the exchange of gunfire held on 17.01.2024.”
2. Duplication and Inconsistencies in FIRs
The NIA’s narrative claimed Mate, a Kuki, collaborated with Waikhom Rohit, a Meitei, in the attacks. However, FIRs listed only one death each, implying possible duplication. The court observed:
“It prima facie appears to us that the Manipur Police has made two FIRs out of one and the same incident,” citing T.T. Antony vs. State of Kerala (2001), which prohibits multiple FIRs for a single occurrence.
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3. Ethnic Improbability
Given the Kuki-Meitei ethnic conflict, the court accepted Mate’s counsel’s argument that a joint attack by members of rival communities was “remote and nigh to impossible.” The bench noted:
“When the entire conflict in the State of Manipur has been between the Meitei and Kuki community… we fail to understand how the petitioner could have been said to be involved in the same incident.”
HC Sets Aside NIA Court Order, Releases Kuki Leader on Bail https://t.co/rCC7ILOi8l #ThangminlenMate #GauhatiHighCourt #NIA #ManipurViolence #MorehClashes #UAPA #Judiciary
— POWER CORRIDORS (@power_corridors) September 26, 2025
4.Contradictory Witness Statements
Witness testimonies were inconsistent regarding the identities of attackers and the sequence of events. The bench criticized investigative oversight:
“It is disturbing to find that the enforcement agencies have presented conflicting accounts without reconciling the facts, thereby creating a misleading picture against the petitioner.”
5. Procedural Violations in Arrest and Detention
The court highlighted lapses under Section 43D(5) of the UAPA. Arrests made without disclosure of other pending cases violate the principles of due process. Quoting Kamal Dutta vs. Union of India (2015), the bench said:
“Arrests in separate cases without disclosure to the court are wholly unacceptable and undermine the sanctity of judicial oversight.”
6. Excessive Reliance on Circumstantial Factors
The NIA emphasized Mate’s presence in Moreh and his communications as proof of involvement. The court held this evidence insufficient:
“Proximity and messages alone cannot substitute for credible, direct evidence linking the petitioner to the alleged criminal act.”
8. Legal Standards and Bail Grant
Under Section 43D(5) of the UAPA, bail is barred unless the court finds no reasonable grounds to believe the accusation is prima facie true. The High Court concluded:
“There is no reasonable ground for believing that the accusation made against the petitioner is prima facie true.”
Mate was granted bail on conditions: a Rs. 2,00,000 bond with one surety, regular reporting to the NIA, and non-interference with witnesses or evidence.
This ruling exposes systemic issues in Manipur’s law enforcement amid ethnic tensions. Duplication of FIRs, conflicting evidence, and procedural lapses suggest either investigative overreach or pressure to secure convictions in a volatile region. As the bench noted:
“The duty of the Courts is to consider the grant of bail… in accordance with law, even under stringent statutes like the UAPA.”
The verdict signals that judicial scrutiny can counterbalance security narratives and protect individual rights. For Mate, it offers relief but not resolution; the NIA’s appeal on RC-05 remains pending.
Thangminlen Mate’s bail underscores the judiciary’s emphasis on due process, evidentiary rigor, and contextual understanding. The case sets a precedent for handling sensitive situations in conflict zones, balancing security concerns with the rights of individuals caught in ethnic and political turmoil.
