Marking forty-one years of PUDR and PUCL’s Who are the Guilty? (released on 17 November 1984), PUDR’s report, Delhi 1984: The Long Aftermath, 41 years of Criminal Injustice, Apathy and Struggles of Survivors (November 2025), offers a detailed account of three different aspects of the long aftermath which followed the mass killings of Sikhs in Delhi in 1984. First, the report offers an analysis of the gamut of official interventions that continued for well over thirty years. Second, in tandem with this official history, the report examines the functioning of the criminal justice system, the nature of investigations and trials. The social costs of the carnage and ensuing official interventions for the survivors constitutes the third aspect. Divided over three chapters, the report recalls, reviews and records the diverse elements of this long aftermath.

What happened in 1984?
More than official interventions, the account of ‘Delhi 1984’ was best recorded by fact-finding teams and volunteers who visited localities, met residents, recorded testimonies, wrote affidavits, organized relief, questioned the police and administration, and processed these different types of information in diverse reports which remain the best documents of the times. By revisiting these important historical documents, the Preface recalls some salient ‘facts’ as to what happened:

• the planned nature of the killings evident in the ‘phased’ nature of the violence
• the pre-meditated and calculated organization of mobs by local Congress (I) leaders
• the identification of households through use of voters and ration lists
• the use of government run DTC buses for transporting mobs
• and the role of the police in conniving with the mobs and the leaders

While all this is well-known, the fallout of the pogrom—for that is what the organized and targeted massacre of Sikhs was—on history thereafter is what the rest of the report concerns itself with.

Who was responsible for the killings?
Chapter 1 (page 6) analyses how the 11 Committees, 2 Commissions of Inquiry and 2 SITs (table, Annexure 1, page 28) failed to name and indict the guilty who had been identified by survivors and named in reports.

Why did they fail?

• The processes of internal subversion which underlay the mandate, procedures and conclusions of the Ranganath Mishra and the inherent biases of the Nanavati Commission which diminished its findings twenty years after the carnage form the focus of the chapter.
• The obvious administrative limitations coupled with official interference which derailed the workings of the Committees is addressed in the section, “Committees in Search of Justice”.
• The insufficiency of the SIT findings confirms why delayed judicial mechanisms cannot redress the erosion of institutional functioning—the role of the police and courts—that subverted the processes of justice in the immediate aftermath of Delhi 1984.

But was this aftermath of Delhi 1984 an exceptional instance of a ruling party sabotaging every available route of justice for the survivors? How did other Commissions of Inquiry function in the cases of Nellie 1983, Bhagalpur 1989, Bhopal 1992, Mumbai 1993, Gujarat 2002, or Muzaffarnagar 2013?

The discussion highlights the features of internal subversion or external inclinations which underline the history of this institution. Hence, the findings have remained either ‘convenient’, in keeping with the interests of governments in power, or ‘ineffective’ since Commissions of Inquiry are recommendatory bodies, not courts of law. Such findings can be forgotten at will or remembered for political reasons.

Who was punished for murdering over 2700 Sikhs in Delhi 1984?

The functioning of the criminal justice system–the Delhi police, trial courts and appellate/constitutional courts (Delhi High Court and Supreme Court) –indicates an abject failure in providing justice. Chapter 2 (page 13) elaborates on this failure.

As per available information, only 650 FIR’s/cases were filed for 2700+ killings and the widespread violence that included injuries to persons, burning and looting of houses and property, sexual violence and attacks on Gurudwaras. The following summary, taken from news sources, tells the tale of the 649 cases (as information about one case is missing):

• 362 chargesheets filed whilst 267 closure reports filed as “untraced”.
• Of 362 chargesheets filed: 39 convictions of 442 people; remaining 323 cases ended in acquittals.
• In 51 of the 323 cases, the courts did not even frame charges.
• Of 12 appeals filed in the Delhi High Court, 8 were dismissed (of which 6 are now pending in the Supreme Court) and 4 appeals remain pending in the Delhi High Court.

The legal journey of 13 cases are captured and give an indication of the role of the criminal justice system where the perpetrators have by and large been shielded (table, Annexure 2, page 34).

How did this happen?

• Police investigations – as noted by the courts – served the perpetrators of the crimes and not the victims. Most cases were poorly investigated and then closed by stating that the perpetrators could not be identified.
• The trial courts by and large did not appreciate the extraordinary circumstances in which crimes took place and consequently did not pass directions that would have served the ends of justice.
• Notably, neither the Delhi High Court nor the Supreme Court directed for immediate and independent investigations which would have ensured that incriminating material was duly collected and preserved including against those in positions of responsibility – whether in the police or in political parties. Neither did the courts bother about providing witness protection across the case or ensure mechanisms by which witnesses, including victims, were provided safety and confidence to step forward and identify the perpetrators. Nor was a dedicated special court created to deal with these cases.

The consequences?

• The family members of the victims were effectively shut out of the justice process and the criminal justice system failed to identify, prosecute and punish the guilty. Today, 41 years later, there appears to be a continuing mechanical and symbolic attempt to revive the cases in the courts.

 Who paid the price and carried the burden of history?
Through the report the accounts of the survivors come through. Most are women. Who are they? At the time of the killings, they desperately shielded their menfolk and tried protecting themselves. Immediately after that, they went looking for the dead, completed the rituals, ran to the police station to register FIRs, frantically sought help for holding their broken children and burnt lives, and fought off the threats, attacks, bribes and intimidation from the powerful accused and the police.

Chapter 3 (page 20) deals with their stories through testimonies that PUDR gathered from its meetings with them in their relocated and, often, desperate homes in rehabilitation colonies. The chapter also integrates the findings of the previous two chapters which examine how these women fared before Commissions and Courts.

• Why did neither of the Commissions attend to the question of sexual violence that was sporadically reported in their testimonies? The chapter and Annexure 3, page_40, address these instances of willed erasure and failure of official history to address the burden of women who are the survivors of mass violence.
• Why were witnesses put on trial? The ease with which trial courts discredited the survivors’ testimonies on grounds of delay, ‘hearsay’, or even ‘contradiction’ shows the inherent distrust of witnesses who are survivors of mass-killing. The testimonies of some of the women describe in detail the struggles that these women have had to put up for securing justice in the courts.
• Between Commissions, Courts, Relief and Compensation Offices, how have these women and their families fared in these forty years?   (Annexure 4, page 42, recounts the lives of “The Lost Generation”).

The accounts of the survivors – recounted decades after the violence – bears out the multiple fronts on which they have suffered and continue to bear the costs of the 1984 pogrom. The role of the different arms of the State – from direct perpetration of violence to the cover-up and failure of the criminal justice system to identify and prosecute the perpetrators – is revealed.

Paramjeet Singh and Harish Dhawan
(secretaries)

To download the full report click here