Involvement of Appellant in Possession of Looted Arms and Mobilisation of Youths in Ethnic Conflict is Prima Facie True : Delhi High Court Denies Bail to Alleged PLA Member Accused of Transnational Conspiracy in Manipur Violence

Delhi High Court dismissed the appeal of Moirangthem Anand Singh seeking bail in a case involving allegations of being part of a larger transnational conspiracy to wage war against India during the ethnic conflict in Manipur. The Court held that “The appellant appears to have played a leadership role, having mobilized youths, received training from proscribed PLA cadres, and was found with prohibited arms looted from government armouries. A prima facie case is made out under Section 18 of the UAPA.” 
 
The case arose during the 2023 ethnic conflict in Manipur, where massive looting of government armouries took place. The appellant was arrested on September 17, 2023, while wearing camouflage resembling Manipur Police commandos and carrying multiple sophisticated weapons, including an INSAS rifle, SLR, and .303 rifles, all later confirmed to be part of the cache looted from the Manipur Police Training College and other armouries. 
 
Rejecting the appellant’s plea that he was merely a village volunteer protecting locals, the Court observed, “The nature of arms, the fact that they were looted from state armouries, and the evidence of prior militant association with the People's Liberation Army (PLA) support the prosecution's case.” 
 
 The Court relied on the settled position under Section 43D(5) of the UAPA, observing, “Unlike the conventional approach where bail is the rule and jail the exception, the legislative intent under UAPA is inverted — jail is the rule and bail the exception.” Referring to Gurwinder Singh v. State of Punjab (2024) 5 SCC 403 and National Investigation Agency vs. Zahoor Ahmad Shah Watali, the Court reiterated that courts must be satisfied that the accusations are not prima facie true before even applying the normal bail considerations. 
 
The High Court held, “The conspiracy charge is substantiated by the appellant's own disclosure about participating in weapons training camps with 80-90 youths, assisting in battle drills, and mobilizing youths during the ethnic unrest.” The Court also found that Call Detail Records (CDR) confirmed “163 regular and constant calls between the appellant and his coaccused during the peak of the Manipur ethnic strife”, revealing the appellant's active role. 
 
Dismissing the argument regarding selective arrest, the Court emphasized, “The appellant's role was distinct due to his leadership position and prior criminal antecedents.” The Bench noted that “The Manipur FIR and the NIA FIR are distinct, one dealing with the specific incident of arms seizure and the other with a broader transnational conspiracy involving PLA and other outfits to destabilize India.” 
 
The Court concluded that the appellant failed both prongs under Gurwinder 
Singh test — the prima facie involvement in UAPA offences and the tripod test under Section 439 CrPC (flight risk, influencing witnesses, and tampering evidence). The Court observed, “There is credible apprehension that if released on bail, the appellant could influence witnesses and destabilize the fragile law and order situation in Manipur.” 
Accordingly, the appeal was dismissed and the interim bail was declined. 

Date of Decision: April 2, 2025