On April 28, 1976, during the Emergency, a five-judge bench of the Supreme Court decided the case known as ADM Jabalpur. Four judges sided with the government on the detention of citizens without trial. Justice H.R. Khanna dissented alone. “Detention without trial is an anathema to all those who love personal liberty,” he wrote.
In January 1977 the government of Indira Gandhi passed over Khanna, the senior judge, and appointed M.H. Beg Chief Justice. Khanna resigned.