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President's rule

Indian law of suspension of state government

Indian law of suspension of state government

In India, President's rule is the suspension of state government and imposition of direct Union government rule in a state. Under Article 356 of the Constitution of India, if a state government is unable to function according to Constitutional provisions, the Union government can take direct control of the state machinery. Subsequently, executive authority is exercised through the centrally appointed governor, who has the authority to appoint other administrators to assist them. The administrators are usually nonpartisan retired civil servants not native to the state.

When a state government is functioning correctly, it is run by an elected Council of Ministers responsible to the state's legislative assembly (Vidhan Sabha). The council is led by the chief minister, who is the chief executive of the state; the Governor is only a constitutional head. However, during President's rule, the Council of Ministers is dissolved, later on vacating the office of Chief Minister. Furthermore, the Vidhan Sabha is either prorogued or dissolved, necessitating a new election.

Prior to 2019, the constitution of the state of Jammu and Kashmir had a similar system of Governor's rule, under its Section 92. The state's governor issued a proclamation, after obtaining the consent of the President of India allowing Governor's rule for up to six months after which President's rule under Article 356 of the Constitution of India could be imposed. After the revocation of Article 370, President's rule applies to Jammu and Kashmir under section 73 (since Article 356 of Constitution of India does not apply to union territories) of Jammu and Kashmir Reorganisation Act, 2019.

Following the 1994 landmark judgment in S. R. Bommai v. Union of India, the Supreme Court of India restricted arbitrary impositions of President's rule.

Chhattisgarh and Telangana are the only states where the President's rule has never been imposed so far. Manipur is the state where it has been invoked the most frequently, currently under the rule since February 2025 for the eleventh time. The President's rule in force in Manipur since February was extended for a further six month with effect from 13 August 2025.

Imposition in state

In practice, President's rule has been imposed in a State under any one of the following different circumstances:

  • A state Assembly is unable to elect a leader as Chief Minister for a time prescribed by the Governor of that State, at the Will of Governor.
  • Breakdown of a coalition leading to the Chief Minister not having majority support in the Assembly; and the Chief minister fails/will definitely fail to prove otherwise, within a time prescribed by the Governor of that state.
  • Loss of majority in the Assembly due to a vote of no-confidence in the house.
  • Elections postponed for unavoidable reasons like war, epidemic, pandemic or natural disasters.
  • On the report of the Governor of the State that the State's constitutional machinery or legislature fails to abide by Constitutional norms.

If approved by both Houses, President's rule can continue for 6 months. It can be extended for a maximum of 3 years with the approval of the Parliament done every 6 months; however in extreme rare cases it can be extended repeatedly if the Election Commission of India recommends that elections are not possible. If the Lok Sabha is dissolved during this time, the rule is valid for 30 days from the first sitting of the new Lok Sabha provided that this continuance has already been approved by Rajya Sabha. The 44th Amendment Act of 1978 introduced a new provision to put a restraint on the power of Parliament to extend the President's rule in a state. According to this provision, the president's rule can only be extended over a year, under the following conditions:

  • There is already a national emergency throughout India, or in the whole or any part of the state.
  • The Election Commission certifies that elections cannot be conducted in the state.

President's rule can be revoked at any time by the President and does not need Parliament's approval.

Until the mid-1990s, President's rule was often imposed in states through the abuse of authority of Governors who were in collusion with the Union government. The Supreme Court of India in March 1994 established a precedent in S. R. Bommai v. Union of India, due to which such abuse has been drastically reduced.

Imposition in Union territories with a Legislative Assembly

Article 356 is not applicable to Union territories, so there are many ways by which President's rule can be imposed in different Union territories with a Legislative Assembly.

Jammu and Kashmir

Until the revocation of special status and bifurcation into two Union territories, President's rule applied after the application of Governor's rule under the erstwhile state's constitution for 6 months.

After the revocation and bifurcation, the reorganized union territory of Jammu and Kashmir is subject to the section 73 of the Jammu and Kashmir Reorganization Act, 2019, which is used to impose President's rule as the Article 356 is not applicable to Union Territories. The provision states:

(a) that a situation has arisen in which the administration of the Union territory of Jammu and Kashmir cannot be carried on in accordance with the provisions of this Act, or

(b) that for the proper administration of Union territory of Jammu and Kashmir it is necessary or expedient so to do,

the President may, by order, suspend the operation of all or any of the provisions of this Act for such period as he thinks fit and makes such incidental and consequential provisions as may appear to him to be necessary or expedient for administering the Union territory of Jammu and Kashmir in accordance with the provisions of this Act.}}

Delhi

In NCT of Delhi, President's rule is applied on the basis of Article 239AB of the Constitution of India (as the Article 356 is not applicable to Union Territories) which reads thus:

(a) that a situation has arisen in which the administration of the National Capital Territory cannot be carried on in accordance with the provisions of article 239AA or of any law made in pursuance of that article; or

(b) that for the proper administration of the National Capital Territory it is necessary or expedient so to do, the President may by order suspend the operation of any provision of Article 239AA or of all or any of the provisions of any law made in pursuance of that article for such period and subject to such conditions as maybe specified in such law and make such incidental and consequential provisions as may appear to him to be necessary or expedient for administering the National Capital Territory in accordance with the provisions of article 239 and article 239AA.}}

Puducherry

In the union territory of Puducherry, President's rule is applied on the basis of Article 51 of the Government of Union Territories Act, 1963. Which thus reads

(a) that a situation has arisen in which the administration of the Union territory cannot be carried on in accordance with the provisions of this Act, or

(b) that for the proper administration of the Union territory it is necessary or expedient so to do, the President may, by order, suspend the operation of all or any of the provisions of this Act for such period as he thinks fit and make such incidental and consequential provisions as may appear to him to be necessary or expedient for administering the Union territory in accordance with the provisions of article 239.}}

Misuse and criticism

Article 356 gives wide powers to the Union government to assert its authority over a state if civil unrest occurs and the state government does not have the means to end it. Though the purpose of this article is to give more powers to the Union government to preserve the unity and integrity of the nation, it has often been misused by the ruling parties at the centre, who used it as a pretext to dissolve state governments ruled by political opponents. Thus, it is seen by many as a threat to the federal state system. Since the adoption of the Indian constitution in 1950, the Union government has used this 134 times to dissolve elected state governments by imposing President's rule.

The article was used for the first time in Punjab on 20 June 1951. It was next used in the state of Patiala and East Punjab States Union (PEPSU) in 1953, and then in 1959 to dismiss the Communist Party of India–led government in Kerala in the aftermath of anti-communist protests. In the 1970s and 1980s, it was common for the Union government to dismiss state governments led by opposition parties. The Indira Gandhi regime and post-emergency Janata Party were noted for this practice. Indira Gandhi's government between 1966 and 1977 is known to have imposed President's rule 39 times in different states. Similarly, the Janata Party which came to power after the emergency issued President's rule in 9 states which were ruled by Congress.

The practice was limited only after the Supreme Court established strict guidelines for imposing President's rule in its ruling on the S. R. Bommai v. Union of India case in 1994. This landmark judgement has helped curtail the widespread abuse of Article 356. The judgement established strict guidelines for imposing President's rule. Subsequent pronouncements by the Supreme Court in Jharkhand and other states have further limited the scope for misuse of Article 356. Only since the early 2000s has the number of cases of imposition of President's rule has been drastically reduced.

Article 356 has always been the focal point of a wider debate of the federal structure of government in Indian polity. During debates in the Constituent Assembly of India regarding emergency provisions of the Constitution of India, B. R. Ambedkar argued for their inclusion under the assumption "that such articles will never be called into operation and that they would remain a dead letter". The Sarkaria Commission Report on Centre-State Relations 1983 has recommended that Article 356 must be used "very sparingly, in extreme cases, as a measure of last resort, when all the other alternatives fail to prevent or rectify a breakdown of Constitutional machinery in the state".

List of instances

StateTermDate of impositionDate of revocationDurationReason(s) to impose the President's rule
Andhra Pradesh1Breakdown of law & order due to [Jai Andhra Agitation](1972-jai-andhra-movement), in CM P. V. Narasimha Rao's tenure.
2Political impasse following the resignation of CM Kiran Kumar Reddy and several other congress party legislators from the Government as well as the Party, in protest against Indian Parliament passing Andhra Pradesh Reorganisation Bill to bifurcate united Andhra Pradesh and create a separate Telangana state. President's rule revoked from Telangana areas on 2 June 2014 and bifurcated Andhra Pradesh areas on 8 June 2014. President rule reimposed unlawfully by the President after the two months time limit without taking approval of the Parliament under Article 356.
Andhra State1url=https://web.archive.org/web/20240502122617/https://books.google.co.in/books?id=LmJlAAAAIBAJ&pg=PA7&article_id=1495,3303156&hl=en&sa=X&ved=2ahUKEwiPn8ChqOOFAxXXfWwGHarDDRQQ6AF6BAgKEAM#v=onepage&q&f=falsedate=2 May 2024 }}. *Indian Express*. 17 March 1970. p. 7. Retrieved 2 May 2024.
Arunachal Pradesh1Loss of majority following defections in a fluid political environment during Janata party rule at the centre.
226 days21 Congress MLAs joined hands with 11 of the BJP and two Independents, making the contemporary government a minority. Supreme Court declared the imposition of president rule as ultra vires and reinstated the dismissed Congress led government in the state. In a landmark judgement, it found fault with the unconstitutional role played by the Governor by interfering in the activities of legislatures and speaker of the Vidhan Sabha
Assam1'Assam Agitation' against illegal foreign nationals staying in Assam started to take roots under the leadership of the All Assam Students' Union (AASU). The violence fuelled by United Liberation Front of Asom (ULFA) resulted in breakdown of law and order.
2Congress (I) government led by Anwara Taimur representing immigrant minorities collapsed following intensification of 'Assam Agitation' against illegal foreign national staying in Assam.
3Congress (I) government led by Kesab Gogoi representing ethnic Asom people collapsed following continued violence in Assam.
4Government dismissed in spite of AGP CM Prafulla Mahanta enjoying majority support in Assembly. The dismissal was triggered apparently by the threat to internal security due to banned organisation ULFA's activities. During the president's rule, Operation Bajrang was launched to flush out ULFA militants.
Bihar1url=https://web.archive.org/web/20240613063656/http://14.139.58.199:8080/jspui/handle/123456789/317date=13 June 2024 }}. Simla: Indian Institute of Advanced Study. OCLC [7583232](https://search.worldcat.org/title/7583232). Retrieved 2 May 2024.
2pages=123–125}}
3pages=129–130}}
4url=https://web.archive.org/web/20240502122616/https://www.nytimes.com/1977/05/01/archives/constitutional-conflict-ends-in-india-as-acting-president-accepts.htmldate=2 May 2024 }}. *New York Times*. p. 4. Retrieved 2 May 2024.
5url=https://web.archive.org/web/20240502122626/https://www.indiatoday.in/magazine/indiascope/story/19800315-pm-indira-gandhi-dismisses-governments-in-nine-states-looks-to-put-congress-in-power-806503-2014-02-06date=2 May 2024 }}. *India Today*. Retrieved 2 May 2024.
6President's rule imposed for a brief period of one week to facilitate passage of vote on account (to permit day-to-day government expenses in Bihar) by Parliament while awaiting the results of Assembly elections held during the Chief Ministership of Lalu Prasad.
7Breakdown of law and order, killings of 11 Dalits at Narayanpur. The Vajpayee Government, revoked the president's rule within 26 days since the coalition did not have a majority in the Rajya Sabha.
8Indecisive outcome of elections. In a landmark judgement, Supreme Court ruled that the imposition of the president's rule without giving the chance to the elected legislatures to form new government is unconstitutional and mala fide act by the president.
Delhi1Arvind Kejriwal resigned as Chief Minister after failing to table the Jan Lokpal Bill in the Delhi Assembly.
Goa1C.M. resigned consequent upon his disqualification by High Court – No other Government found viable.
2Loss of majority and no alternate claimant to form next government.
3Government dismissed after controversial confidence vote secured in the Assembly by CM Pratap Sinh Rane.
Goa, Daman and Diu1The Union Territory of Goa's Assembly was dissolved to conduct an opinion poll to determine whether Goa should be merged with Maharashtra.
2Loss of majority following split in the ruling MGP Party.
Gujarat1Loss of majority following vertical split in Congress during [1969 presidential election](1969-indian-presidential-election).
2Chimanbhai Patel led Congress government resigned due to Navnirman Movement Anti-Corruption protests. The protesters forced MLA's resignations, forcing dissolution of assembly.
3"Non-Passage" of budget leading to collapse of government.
4Government dismissed in spite of Babubhai J Patel enjoying majority support in the Assembly
5Government dismissed following a controversial confidence vote. The Assembly was placed in suspended animation, which led to subsequent installation of Vaghela government, supported by Congress.
Haryana1Government dismissed in spite of having a tenuous majority.
2Government dismissed in spite of B D Gupta enjoying majority support in Assembly.
3url=https://web.archive.org/web/20240502122614/https://news.google.com/newspapers?id=eX1lAAAAIBAJ&sjid=uJ0NAAAAIBAJ&pg=1026,2190952date=2 May 2024 }}. *Indian Express*. 7 April 1991. p. 1. Retrieved 2 May 2024.
Himachal Pradesh1Government dismissed in spite of Thakur Ram Lal enjoying majority support in Assembly.
2Government dismissed in the aftermath of the destruction of Babri Masjid-Ram Janmasthan in Uttar Pradesh.
Jammu and Kashmir
(State)1Sheikh Abdullah led National Conference government bowed out after being reduced to a minority following withdrawal of support by the Congress Party.
2Loss of majority.
3Increased Militancy, Exodus of Kashmiri Hindus & breakdown of law & order
5Loss of majority following collapse of coalition. CM Gulam Nabi Azad's decision to transfer land for Amarnath pilgrimage led to PDP pulling out of coalition Govt.
6Failure of Government formation after fractured verdict in Assembly elections. BJP & PDP reached an understanding to form an alliance to form Government in J&K.
7Death of chief minister Mufti Mohammad Sayeed.
8Resignation of the Chief Minister following loss of coalition partner. On 31 October 2019, Jammu and Kashmir state was split into two union territories, UT of Jammu and Kashmir and UT of Ladakh.
Jammu and Kashmir
(Union Territory)1Imposed under section 73 of Jammu and Kashmir Reorganisation Act, 2019 (Article 356 does not apply to Union Territories)
Jharkhand1url=https://web.archive.org/web/20240502201244/https://economictimes.indiatimes.com/news/politics-and-nation/presidents-rule-imposed-in-jharkhand/articleshow/4002015.cms?from=mdrdate=2 May 2024 }}. *The Economic Times*. 19 January 2009. Retrieved 2 May 2024.
2Loss of majority.
3Loss of majority BJP's ruling coalition partner JMM withdrew its support to the government pushing it into a minority. Chief Minister Arjun Munda resigned and sought dissolution of the state Assembly.
Karnataka1pages=392, 395–396}}
2Government dismissed in spite of Congress CM Devraj Urs enjoying majority support in Assembly.
3Loss of majority of CM S. R. Bommai, followed by dissolution of Assembly. On an appeal by S. R. Bommai, in a landmark judgement delivered in 1994, the Indian Supreme Court laid out the procedure to be followed before dissolving an elected assembly. The historic ruling in this case reduced the scope for misuse of Article 356 by future central governments and governors.
4Government of Veerendra Patil dismissed by Prime Minister V. P. Singh and state was placed under president's rule with the assembly placed in suspended animation until next chief Minister was elected.
5url=https://web.archive.org/web/20230411040857/https://economictimes.indiatimes.com/news/politics-and-nation/presidents-rule-imposed-in-karnataka/articleshow/2444200.cms?from=mdrdate=11 April 2023 }}. *India Today*. 10 October 2007. Retrieved 2 May 2024.
6url=https://web.archive.org/web/20240503184948/https://www.hindustantimes.com/delhi/karnataka-again-under-president-s-rule/story-GIcAU9ce7fzGanaVtnSH7M.html?utm_source=admitad&utm_medium=442763_3CejPAogEAC0eSZbHqLcRYB4mYpaVRWGp1R3Ds4522Y7rk&utm_campaign=606e39ba96429fa5195df7cfcc966937&tagtag_uid=606e39ba96429fa5195df7cfcc966937date=3 May 2024 }}. *Hindustan Times*. 20 November 2007. Retrieved 2 May 2024.
Kerala1Government dismissed in spite of Communist CM EMS Namboodiripad enjoying majority support in Assembly.
2pages=173–174}}
3pages=194–195}}
4Loss of majority.
5Loss of majority due to withdrawal of support by Congress(S) and Kerala Congress(M).
6Loss of majority following defection of Lonappan Nambadan.
Madhya Pradesh1Government dismissed in spite of Shyama Charan Shukla enjoying majority support in Assembly.
2Government dismissed in spite of Sundar Lal Patwa enjoying majority support in Assembly.
3Govt. dismissed in the aftermath of Babri Masjid-Ram Janmasthan destruction in Uttar Pradesh.
Maharashtra1Govt. dismissed in spite of Sharad Pawar enjoying majority support in the Assembly.
2Govt. dismissed since Congress Separated from its allies NCP and Others.
311 daysNo party could form a government after a fractured election verdict and Shiv Sena broke the pre-poll alliance it had with the BJP. See also: [2019 Maharashtra political crisis](2019-maharashtra-political-crisis).
Manipur1url=https://web.archive.org/web/20221218053746/https://news.google.com/newspapers?nid=P9oYG7HA76QC&dat=19671026&printsec=frontpage&hl=endate=18 December 2022 }}. *Indian Express*. 26 October 1967. p. 1. Retrieved 2 May 2024.
2pages=206–207}}
3pages=208-209}}
4Collapse of Government following defections.
5Discontent within Janata Party Government and corruption charges led to dismissal of government and dissolution of Assembly.
6Incumbent Government fell following defections. Governor did not permit an alternate government to be formed by People's Democratic Front on the basis of his assessment regarding stability of the proposed ministry.
7url=https://web.archive.org/web/20240502175314/https://news.google.com/newspapers?nid=P9oYG7HA76QC&dat=19920108&printsec=frontpage&hl=endate=2 May 2024 }}. *Indian Express*. 8 January 1992. p. 1. Retrieved 2 May 2024.
81000 persons died in Naga-Kuki clashes and continued violence.
9Loss of majority.
1013 February 2025OngoingChief Minister N. Biren Singh resigned following the [2023–2025 Manipur violence](2023-2025-manipur-violence) amidst a crisis of possible no-confidence motion. Assembly put under suspended animation.
Meghalaya1The Centre imposed president's rule in Meghalaya in the wake of a political crisis after the then Speaker PR Kyndiah suspended five MLAs, mostly independents, on grounds of defection.
2Government dismissed after controversial confidence vote secured in the Assembly by CM Donkupar Roy.
Mizoram1Mizo Union Ministry led by Chief Minister Chhunga resigned in May 1977, ostensibly to facilitate the progress of peace talks.
2Chief Minister Sailo's refusal to grant undue favours caused dissension in his party which led to the fall of his government and imposition of president's rule.
3Defections reduced the Government to minority.
Nagaland1pages=230-231}}
2The state was under a brief spell of central rule again after the Hokishe Sema-led Congress government was reduced to a minority. The decision was challenged in the Supreme Court in held to be invalid in 1994.
3Fluid party position and deteriorating law and order situation.
4Government dismissed after controversial confidence vote secured in the Assembly by CM Neiphiu Rio.
Odisha1Harekrishna Mahtab led Congress-Gantantra Parishad Minority Government resigned on 21 February 1961 due to differences in the Congress Party. President's rule was imposed on 25 February 1961.
2pages=239–244}}
3pages=245–247}}
4Chief Minister Nandini Satpathy was forced out and assembly placed under suspended animation. A new Congress government was sworn in after revocation of president's rule.
5Government dismissed in spite of Binayak Acharya enjoying majority support in Assembly.
6Government dismissed in spite of Nilamani Routray enjoying majority support in Assembly.
Patiala and East Punjab States Union1President's rule was invoked in the erstwhile PEPSU (Patiala and East Punjab States Union ) State when the Akali Dal government, led by Gian Singh Rarewala, was dismissed.
Puducherry1url=https://web.archive.org/web/20240503084728/https://news.google.com/newspapers?nid=P9oYG7HA76QC&dat=19680919&printsec=frontpage&hl=endate=3 May 2024 }}. *Indian Express*. 19 September 1968. p. 1. Retrieved 2 May 2024.
2Assembly dissolved after fall of DMK government following decision of two ministers to join newly formed AIADMK.
3Fall of coalition government of AIADMK, Congress(O) following division of votes by Congress(R) and DMK. The Assembly was dissolved.
4Fall of government due to political instability.
5978-81-7099-325-4}}. Retrieved 2 May 2024.
6DMK Government dismissed in spite of having a majority in the Assembly.
7Congress Government resigned due to loss of majority and no alternate claimant to form next government.
Punjab1Prime Minister Jawaharlal Nehru kept the Punjab Assembly in suspension for nine months and 28 days to help the state Congress government get its act together.
2pages=282–283}}
3pages=286–287}}
4Following poor performance in March, [1971 Lok Sabha Elections](1971-indian-general-election), incumbent Chief Minister advised dissolving state assembly and holding fresh elections to state legislature.
5Government dismissed in spite of Giani Zail Singh enjoying majority support in Assembly.
6Government dismissed in spite of Parkash Singh Badal enjoying majority support in Assembly.
7Many Khalistani separatist groups announced the creation of Khalistan.
8url=https://web.archive.org/web/20240925223310/https://news.google.com/newspapers?id=sIJlAAAAIBAJ&sjid=up4NAAAAIBAJ&pg=1723%2C1327693date=25 September 2024 }}. *Indian Express*. p. 1. Retrieved 2 May 2024.
Rajasthan1pages=281, 285–287}}
2Government dismissed in spite of Hari Dev Joshi enjoying majority support in Assembly.
3Government dismissed in spite of Bhairon Singh Shekhawat enjoying majority support in Assembly.
4Government dismissed in spite of Bhairon Singh Shekhawat enjoying majority support in Assembly.
Sikkim1Loss of majority following split in Kazi Lhendup Dorji led Janata Party government. The central government imposed president's rule and followed up with electoral reforms before ordering fresh elections.
2Congress Government formed following induced collapse of Nar Bahadur Bhandari Sikkim Janata Parishad Government was dismissed as it did not enjoy a majority in the Assembly.
Tamil Nadu1The government headed by former chief minister M. Karunanidhi was dismissed by former prime minister Indira Gandhi in spite enjoying majority in the legislative assembly, due to charges of corruption while the Sarkaria Commission was set up to probe the allegations.
2The government headed by former chief minister M. G. Ramachandran was dismissed by former prime minister Indira Gandhi in spite enjoying majority in the legislative assembly.
3The government headed by former chief minister V. N. Janaki Ramachandran was dismissed by former prime minister Rajiv Gandhi after controversial confidence vote secured by her in the legislative assembly.
4url=http://www.thehindu.com/news/national/congress-had-no-role-in-dismissing-dmk-govt-in-1991/article8475243.ecetitle=Congress had no role in dismissing DMK govt in 1991work=The Hindudate=14 April 2016access-date=25 June 2016archive-date=10 December 2016archive-url=https://web.archive.org/web/20161210211324/http://www.thehindu.com/news/national/congress-had-no-role-in-dismissing-dmk-govt-in-1991/article8475243.eceurl-status=live }}
Travancore-Cochin1978-0-333-90186-1}}
Tripura1page=320}}
2page=322}}
3Elections postponed from 15 February 1993 to 3 April 1993 on account of deteriorating law and order situation. Caretaker CM resigns.
Uttar Pradesh1pages=326–327}}
2pages=338–341}}
3pages=44–45}}
4Congress Government of H N Bahuguna tendered resignation due to infighting within the party.
5Government dismissed in spite of N D Tiwari enjoying majority support in Assembly.
6Government dismissed in spite of Banarasi Das enjoying majority support in Assembly.
7Government dismissed in the aftermath of the destruction of Babri Masjid-Ram Janmasthan.
8Loss of majority following collapse of coalition followed by indecisive outcome of fresh elections.
9Indecisive outcome of elections.
Uttarakhand1Collapse of CM Harish Rawat's ministry following a split in the state unit of Congress party. In the hearing of related case, Uttarakhand High Court declared the president's rule imposition by the President unconstitutional and restored the Harish Rawat's led government in the state.
2Supreme Court of India held the stay on Uttarakhand High Court's verdict thus reinstating the president's rule in the state.
West Bengal1url=https://web.archive.org/web/20240502122633/https://news.google.com/newspapers?nid=P9oYG7HA76QC&dat=19680221&printsec=frontpage&hl=endate=2 May 2024 }}. *Indian Express*. 21 February 1968. p. 1. Retrieved 2 May 2024.
2Collapse of United Front Coalition between Bangla Congress and CPI(M).
3pages=408–411}}
4Government dismissed in spite of Siddhartha Shankar Ray enjoying majority support in Assembly.

References

References

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