The Liberhan Commission report is the longest act of institutional self-examination that the Indian republic has ever devoted to a single afternoon. A one-man commission of inquiry, constituted on 16 December 1992 with a three-month mandate to establish how the Babri Masjid at Ayodhya came to be demolished ten days earlier, sat for seventeen years, received forty-eight extensions, examined more than one hundred witnesses and delivered a report of 1,029 pages to Prime Minister Manmohan Singh on 30 June 2009. The document named sixty-eight persons as culpable for leading the country to the brink of communal discord. It found that the demolition had been planned rather than spontaneous, that the Uttar Pradesh government of Kalyan Singh had stood guard against preventive action, and that the movement’s senior leadership bore responsibility for a joint conspiratorial enterprise. No prosecution, dismissal, disqualification or reform followed from any of it. The report was debated in Parliament, answered through an Action Taken Report that largely noted its recommendations, and then shelved, while a criminal court in Lucknow spent the same decades reaching the opposite conclusion on the same events and a Constitution Bench of the Supreme Court settled the underlying land dispute on grounds that owed the Commission almost nothing.

This article reads the post-1992 trajectory through that audit. Its claim is the one the evidence sustains: the seventeen-year Liberhan inquiry produced an institutional-political audit of real substance, and the Indian state’s engagement with the audit was rhetorical rather than institutional, a pattern of debate without implementation that reveals how commissions of inquiry actually function inside the constitutional order. The claim is complementary to the reading offered in the political-architectural-phase-transition reading, which treats the demolition as the moment a street movement converted itself into an electoral machine. That reading explains what the demolition did to Indian politics. The audit reading explains what Indian institutions did with the demolition, and the answer, documented across seventeen years of extensions and one parliamentary winter, is that they examined it exhaustively and acted on it barely at all.

Three Ways of Reading a Demolition

Every contested event in a democracy accumulates official readings, and the demolition of the Babri Masjid accumulated three. The first is the political reading, concerned with consequences: the demolition as the climax of the Ram Janmabhoomi movement, the end of one phase of Hindu nationalist mobilisation and the beginning of another, examined in this series through the 1990 Rath Yatra movement-activation and the movement’s own long build-up. The second is the criminal-legal reading, concerned with guilt: the first information reports registered at Ayodhya on 6 December 1992, the Central Bureau of Investigation chargesheets of 1993, the two trial streams at Rae Bareli and Lucknow, and the acquittal of all thirty-two surviving accused by a special court on 30 September 2020. The third reading is the audit reading, concerned with responsibility in the institutional sense: who held office, who gave assurances, who failed to act, and which bodies were designed so that their failure carried no cost. The Liberhan Commission is the audit reading’s archive and its embodiment.

The three readings do not compete for the same ground, and this article does not pretend otherwise. A criminal court asks whether the prosecution has proved a conspiracy beyond reasonable doubt against named individuals, and it answers within rules of evidence that exclude much of what a commission may consider. A political history asks what the event set in motion. An audit asks a colder question: given the duties that office-holders and organisations had assumed, in affidavits, in court undertakings, in public assurances, how did each perform, and what did the system do with the answer? Each reading also has a characteristic blindness that the others correct. The political reading, organised around consequences, tends to treat the demolition’s success as its explanation, reading the movement’s later victories back into the afternoon as inevitability. The criminal reading, organised around proof, tends to mistake the failure of a prosecution for the innocence of an event, as though an acquittal on evidence rules were a finding that nothing was planned. The audit reading, organised around duty, has the opposite temptation: it can find responsibility so widely distributed, from conspirators to facilitators to the merely passive, that responsibility inflates into the condition of an era and attaches to no one in a way that bites. The Liberhan report is alert to that temptation in its own text, grading its sixty-eight names rather than levelling them, and the grading is what keeps the document an audit rather than a lament. Read together, the three readings describe an event that was planned as the audit found, unpunished as the courts recorded, and transformative as the political historians argue, and any account of Ayodhya that holds fewer than all three of those propositions is a partial account wearing a complete one’s clothes. Justice Manmohan Singh Liberhan, a serving judge of the Punjab and Haryana High Court when the government of P. V. Narasimha Rao appointed him, spent seventeen years assembling that answer. The scholarly disagreement this article adjudicates is therefore not whether the demolition was planned, a question on which the Commission and the criminal court reached opposed conclusions that this article sets side by side. The disagreement is about what the audit itself means. One line of commentary, represented by A. G. Noorani’s essays on the Ayodhya question and by Manoj Mitta’s reporting on the Commission’s conduct, treats the inquiry’s duration and the state’s inaction as evidence that the audit was a device for deferral, an institutional sedative. Another line, visible in Pratap Bhanu Mehta’s post-2009 essays on institutional audit, treats commissions as truth-establishing bodies whose value survives non-implementation, because a documented record constrains future denial. The record assembled below supports a claim between those poles and sharper than either: the Liberhan audit established facts that no later institution has formally displaced, and the Indian state developed, through this case, a repeatable technique for absorbing such facts without consequence, of which the forty-eight extensions were the first half and the Action Taken Report the second.

Before the Audit: The Road to 6 December 1992

The structure that fell on 6 December 1992 had stood since 1528, when Mir Baqi, a commander of the Mughal emperor Babur, raised a mosque at Ayodhya bearing an inscription that recorded its construction in Babur’s name. The dispute over the site hardened in the nineteenth century, and its decisive modern turn came on the night of 22 and 23 December 1949, when idols of Ram appeared inside the mosque and the district administration of Faizabad, under District Magistrate K. K. K. Nayar, locked the premises with Hindu worship continuing inside and Muslim entry barred. The template that day created, a disputed religious place administered by the state in frozen ambiguity, is traced in the religious-place-state-administration template. For four decades the lock held. In February 1986 a district judge ordered the locks opened to Hindu worshippers, and the political temperature of the site changed permanently.

The movement that then gathered around the site was organisational before it was electoral. The Vishwa Hindu Parishad, working through the Dharm Sansad and the Ram Shila Pujan campaign of 1989, built a nationwide devotional network whose political meaning is examined in the religious-political-mobilisation-substantive reading. The Bharatiya Janata Party adopted the cause formally through its Palampur resolution of June 1989. L. K. Advani’s Rath Yatra of September and October 1990, halted at Samastipur by the Bihar government of Lalu Prasad Yadav, left dead across several states in the rioting that trailed it and made Ayodhya the central mobilising question of national politics. In June 1991 the BJP won power in Uttar Pradesh, and Kalyan Singh took office as chief minister in Lucknow with the movement’s expectations attached to his government and the mosque’s physical safety attached to his government’s word.

Through 1992 the assurances accumulated on paper. The Kalyan Singh government told the Supreme Court, told the National Integration Council and told the Union government that the mosque would be protected and that the kar seva announced for 6 December would be symbolic, a devotional ceremony conducted without damage to the structure. The Supreme Court, on the strength of those undertakings, permitted the symbolic kar seva to proceed. The Union government of P. V. Narasimha Rao, weighing the dismissal of a state government under Article 356 against the assurances on record, chose to rely on the assurances. The Rao government’s response context matters here because the same government that liberalised the economy with such decisiveness in 1991 approached Ayodhya through constitutional restraint and received assurances that dissolved on contact with the crowd. On 5 December 1992, Advani and other senior leaders addressed a rally at Lucknow. On the morning of 6 December, a crowd officially estimated in the hundreds of thousands had gathered at Ayodhya around the disputed structure, with senior movement leaders seated on a dais at Ram Katha Kunj, a short distance from the mosque, and the state’s police deployed under orders that, as the Commission later established, forbade firing in any circumstances.

6 December 1992: The Documented Sequence

The Commission’s first term of reference required it to reconstruct the sequence of events, and its report remains the fullest official chronology of the day. The kar seva began in the morning with ritual observances at the disputed site. In the late morning, kar sevaks broke through the security cordon around the structure. Around midday, the first kar sevaks climbed onto the domes. Photographs and press footage from the scene, which the Commission examined alongside witness testimony, show men atop the central dome by the early afternoon, striking at it with pickaxes and iron rods while the crowd below pulled at ropes attached to the structure. The central dome collapsed in the mid-afternoon. The two remaining domes followed in sequence, and by the early evening the entire structure had been reduced to rubble. The Commission recorded that the idols and the cash box from beneath the central dome were removed before the demolition of that dome was completed and were reinstalled the same night in a makeshift temple raised on the debris, a sequence of acts performed under the eyes of the movement’s leadership and the state’s police, neither of which intervened to stop the work.

When did the last dome of the Babri Masjid fall?

The last dome fell in the early evening of 6 December 1992, completing a demolition begun around midday when kar sevaks first climbed the structure. The central dome collapsed in the mid-afternoon, the side domes followed, and by nightfall the site held rubble and a makeshift temple containing the idols removed from beneath the central dome.

The state’s response came after the fact. Kalyan Singh resigned as chief minister on the evening of 6 December, accepting moral responsibility, and the Union government dismissed his government and imposed President’s rule in Uttar Pradesh the same night. Within days, the Rao government banned the Rashtriya Swayamsevak Sangh, the Vishwa Hindu Parishad and allied organisations, and dismissed the BJP governments of Madhya Pradesh, Rajasthan and Himachal Pradesh. Riots followed the demolition across India and beyond it, in Mumbai in two waves across December 1992 and January 1993, in Surat, Bhopal, Delhi and dozens of other towns, and the commonly reported death toll from the violence of that winter exceeds two thousand. The demolition itself had lasted an afternoon. The institutional reckoning was assigned, ten days later, to a single judge with a three-month deadline.

The Night After and the Winter That Followed

The Commission’s terms of reference ran to the occurrences at the complex, but the demolition’s first audit trail was written by the state in the week after, through acts that later witnesses would be asked to explain. On the night of 6 December, with the makeshift temple raised on the debris and kar sevaks holding the site, Muslim residents of Ayodhya were attacked in the lanes of the town and families fled toward Faizabad; the Commission heard evidence on the violence in Ayodhya itself, which the national attention on the domes largely eclipsed. Curfew closed over the town. In Delhi, the Rao cabinet moved through the evening: Kalyan Singh’s resignation and the imposition of President’s rule in Uttar Pradesh came first, and on 10 December the Union government banned the Rashtriya Swayamsevak Sangh, the Vishwa Hindu Parishad, the Bajrang Dal, the Islamic Sevak Sangh and the Jamat-e-Islami Hind under the Unlawful Activities (Prevention) Act. On 15 December the Rao government dismissed the three remaining BJP state governments, in Madhya Pradesh under Sunder Lal Patwa, in Rajasthan under Bhairon Singh Shekhawat and in Himachal Pradesh under Shanta Kumar, on the ground that governments led by the party of the movement could not be trusted with the constitutional order the movement had defied. Advani, Joshi and other senior leaders were arrested in the demolition’s aftermath and released within weeks. Each of these acts belonged to the executive register, swift, reversible and political. The bans would lapse or be struck down in part; the dismissed governments’ parties would win the elections that followed in 1993 in two of the three states; the arrests produced no immediate prosecution of consequence.

It was against that record of motion without consequence that the appointment of an inquiry, ten days after the event, should be read. The Rao government also promised, and in February 1993 published, a White Paper on Ayodhya setting out its own account of the events and its own defence, a document the Commission later had in its record. The White Paper and the Commission were the two halves of a single governmental instinct: to convert a catastrophe of governance into a literature of governance, findings and papers accumulating where sanctions did not. None of this is said to diminish the inquiry’s necessity. A demolition carried out against the Supreme Court’s orders, under a state government’s assurances, in the presence of the national leadership of a major party, required an authoritative reconstruction, and only a judicial commission could command the testimony such a reconstruction needed. The point is about sequence and substitution. The audit was commissioned at the moment when every faster instrument had already been used and had already failed to attach a consequence to the event, and it inherited that failure as its working condition. Justice Liberhan’s seventeen years began in a landscape where the Indian state had demonstrated, within ten days, both its capacity to act against the demolition’s political sponsors and the limits it observed in doing so. The Commission’s task was to establish the facts. The facts, when they came, would return to the same landscape.

Delhi in the Autumn of 1992: The Centre’s File

The Commission’s criticism of the Union government rests on a file that the evidence phase reconstructed month by month, and the file deserves its own account because it shows the audit method working on the auditor’s own appointing power. Through 1992 the Union Home Ministry received the reporting that a threatened monument generates: assessments of the mobilisation’s scale, warnings from the Intelligence Bureau about the kar sevaks’ intentions, and the record of a site at which the state government controlled both the police and the promise of protection. On 23 November 1992, a fortnight before the demolition, the National Integration Council met in Delhi, and the Uttar Pradesh government assured the Council, as it assured the Supreme Court in the same season, that the disputed structure would be protected and the kar seva kept symbolic. The assurance was given before the assembled leadership of the republic and recorded. It was also, the Commission found, worthless, and the finding against Lucknow rests on it more than on any crowd behaviour of 6 December: a government that has assured the National Integration Council and the Supreme Court, and then posts its police under orders forbidding fire and holds the Centre’s paramilitary companies at a distance from the site, has answered the audit’s question in its own documents.

The Centre’s half of the file is a study in a different failure, the failure of a government that believed the assurances because the alternative was unconstitutional politics of the hardest kind. Dismissing an elected state government under Article 356 on the suspicion that it would break its word meant acting before the crime, against a Bharatiya Janata Party government, with the certain charge that Congress had struck at a Hindu government to protect a mosque, and with the memory of Article 356’s abuse across four decades arguing restraint. The Rao government chose the assurances. It also positioned central forces in the region, and the Commission examined why those forces, present in Uttar Pradesh in strength, were not deployed at Ayodhya in time: the constitutional choreography of aid to civil power, under which the state government requests and directs deployment, gave Lucknow the procedural means to hold the Centre’s battalions at Faizabad while the domes fell a few kilometres away. The report’s criticism of Rao is therefore structural rather than conspiratorial, and more damaging for it. The Centre had the intelligence, the forces and the constitutional warning; what it lacked was a mechanism, or a willingness, to override a state government’s assurances at the moment when overriding them was the only act that mattered. The Commission’s grade for Delhi, failure of responsibility without culpability for the enterprise, has been contested from both directions ever since, by the movement’s defenders who call it the report’s escape hatch for its appointers and by Congress’s critics who call it too kind. The audit grammar explains the grade: Rao’s government directed nothing at Ayodhya and assured nothing to the Court; it merely failed, completely and consequentially, at the task the Constitution assigns the Union when a state government becomes the threat.

Ten Days Later: A One-Man Commission Under the 1952 Act

On 16 December 1992, ten days after the demolition, the Union government issued the notification constituting the Liberhan Ayodhya Commission of Inquiry under the Commissions of Inquiry Act 1952. The chairman was Justice Manmohan Singh Liberhan, then a serving judge of the Punjab and Haryana High Court, who would later serve as Chief Justice of the Himachal Pradesh High Court and of the Andhra Pradesh High Court while the inquiry continued around his judicial career. The Commission was a one-man body, assisted by counsel and a small secretariat, headquartered in Delhi with sittings that followed the evidence. Its terms of reference directed it to inquire into the sequence of events and the facts and circumstances relating to the occurrences at the Ram Janmabhoomi Babri Masjid complex on 6 December 1992, into the role played by the chief minister, the council of ministers, officials and others in Uttar Pradesh, and into the measures that could have prevented the destruction, together with the failures that allowed it. The original mandate allowed three months. The report was due, on that arithmetic, in March 1993.

The choice of instrument mattered as much as the choice of man. The Commissions of Inquiry Act 1952 creates bodies that investigate and report; it does not create bodies that punish. A commission’s findings are recommendatory in law, addressed to the government that appointed it, and the government is obliged only to lay the report before the legislature with a memorandum of action taken, within six months of submission, unless it extends that period itself. The Liberhan Commission therefore began life as an audit in the strict sense: it could establish, attribute and recommend, and every consequence depended on executive and legislative will that the Act did not compel. The political scientist’s distinction, drawn sharply in Pratap Bhanu Mehta’s essays after the report appeared, between institutions that decide and institutions that document, was built into the Commission’s founding notification. What the seventeen years added was a second discovery: the documenting institution could itself be slowed, by the simple device of the extension, until the political moment its findings addressed had entirely passed.

What powers does a commission of inquiry hold?

A commission under the Commissions of Inquiry Act 1952 holds a civil court’s powers to summon witnesses, compel documents and receive evidence on oath. Its findings bind nobody. It cannot convict, sentence, disqualify or award a remedy; its conclusions travel to the government that appointed it as recommendations awaiting an Action Taken Report.

Justice Liberhan worked the instrument he had been given. The Commission summoned politicians, officials, police officers, journalists and movement functionaries; it took evidence on oath; it assembled press footage, official correspondence and the paper trail of assurances exchanged between Lucknow and Delhi through 1992. More than one hundred witnesses were examined across the inquiry’s life. L. K. Advani appeared and deposed. Murli Manohar Joshi appeared. The last witness examined, in August 2005, was Kalyan Singh, whose repeated non-appearances had consumed years of the Commission’s calendar before his testimony was finally recorded. The evidence phase, in other words, closed fourteen years after the demolition with the testimony of the man whose government had guarded the site. The four years that followed were consumed by the writing of the report, a fact that the Commission’s critics placed beside the extension record and read unkindly.

Seventeen Years and Forty-Eight Extensions

The extension pattern is the audit’s skeleton, and it deserves to be laid out as the artifact this article contributes to the pillar. Table 1 sets the trajectory in sequence: constitution, mandate, extensions, evidence, submission, tabling and the parallel tracks that outran the audit.

Table 1: The Liberhan audit trajectory, 1992 to 2020, as established in the Commission’s record and the parliamentary and court record that followed it.

Stage	Dates	What the record shows
Constitution	16 December 1992	One-man commission under the Commissions of Inquiry Act 1952; three-month mandate
Original deadline	March 1993	Mandate expires unmet; the first extension begins the pattern
Extensions	1993 to 2009	Forty-eight extensions granted by successive Union governments
Evidence phase	1993 to 2005	More than one hundred witnesses examined; Kalyan Singh, the last witness, deposes in August 2005
Report writing	2005 to 2009	Four years between the close of evidence and submission
Submission	30 June 2009	Report of 1,029 pages handed to Prime Minister Manmohan Singh
Leak and tabling	23 and 24 November 2009	Contents in the press a day before Home Minister P. Chidambaram tables the report and the Action Taken Report
Criminal track	1993 to 2020	CBI prosecution ends in acquittal of all thirty-two surviving accused, 30 September 2020
Title track	9 November 2019	Supreme Court Constitution Bench settles the Ayodhya title dispute on grounds independent of the Commission

The mechanics of the pattern were lawful at every step. Under the 1952 Act, the appointing government extends a commission’s tenure by notification, and no parliamentary vote, no judicial approval and no public justification is required. Forty-eight notifications across seventeen years issued from governments of every complexion: the Congress government of Narasimha Rao that appointed the Commission, the United Front governments of H. D. Deve Gowda and I. K. Gujral, the National Democratic Alliance governments of Atal Bihari Vajpayee, whose party’s leaders stood among the inquiry’s subjects, and the United Progressive Alliance government of Manmohan Singh, which received the report. The extension was the one Liberhan question on which India’s rival governments never disagreed in public. Manoj Mitta, who reported the Commission’s proceedings for years and wrote the most sustained journalistic account of its delays, documented the rhythm of the thing: the deadline would approach, the Commission would write seeking more time, the Home Ministry would extend, and the file would close again for a season. The Commission’s defenders answered that the evidence was vast, that witnesses of the first rank evaded appearance for years, that a serving and then retired judge carried the inquiry alongside a full judicial career until 1998 and that the report’s bulk testified to labour rather than leisure. The cost of the inquiry, reported across its life and totalled at submission, came to roughly eight crore rupees, spent on an institution whose product every government in turn agreed to keep unpublished for a little longer.

The political scientist Yogendra Yadav’s phrase for the era, the second democratic upsurge, describes the mobilisation from below that remade the party system in these same years; the extension record describes the corresponding movement within the state, a capacity for indefinite postponement of judgment that no upsurge disturbed. By 2003, a decade in, the Commission had become a standing joke of the Delhi press corps and a standing reproach in the essays of A. G. Noorani, whose book The Babri Masjid Question, 1528 to 2003 treated the inquiry’s pace as part of the larger pattern by which the Indian state metabolised the demolition. In 2007 the Union government let it be known that the report would come within the year; the report came in 2009, after two further extensions. When Justice Liberhan finally carried the document to the Prime Minister’s residence on 30 June 2009, the demolition’s principal accused were elder statesmen of a party preparing its next ascent, and the three-month audit had outlasted four general elections.

Why Seventeen Years Were Possible: The Design of the 1952 Act

The extension pattern was not an abuse of the instrument; it was the instrument, used exactly as designed. The Commissions of Inquiry Act 1952 leaves three decisive choices with the appointing government: whether to constitute a commission, how long it may sit, and what to do with its report. No statutory deadline binds the second choice, no consequence attaches to the third beyond the laying of a memorandum, and the government that receives the findings is frequently the institutional descendant, or the ally, or the other self, of the governments the findings judge. Added to those structural features, the Act’s own procedural amendments lengthened every serious inquiry of the Liberhan type. The protections inserted for persons likely to be prejudicially affected by a commission’s conclusions, the Section 8B notices that entitle named persons to representation, to cross-examine and to reply, are genuine safeguards of fairness, and in the Liberhan proceedings they generated their own years: notices to the movement’s senior leaders, rounds of replies and rejoinders, litigation at the margins. A commission that must hear everyone it may condemn, on oath, with counsel, across a record of this size, will not report in three months, and a government that wishes it to report slowly need only decline to hurry it. The seventeen years were co-produced by a chairman who accepted the extensions and by governments that granted them, and behind both stands the Act, which offers the executive a complete technology of lawful deferral: appoint the inquiry to demonstrate seriousness, extend the inquiry to manage the calendar, receive the inquiry when its subjects are history.

The pattern is older than Liberhan and wider than Ayodhya, which is why this article treats the case as evidence about the instrument rather than about one judge. The Sarkaria Commission on Centre-State relations, appointed in 1983, reported in 1988 with recommendations that governments implemented selectively across decades, and its trajectory, serious findings absorbed at the convenience of the audited, is the Liberhan pattern in the federal register. The Ranganath Misra Commission on the 1984 anti-Sikh violence reported in a fraction of Liberhan’s time and met a comparable absorption. The Indian commission of inquiry, across subjects and decades, has converged on a stable institutional role: it is the state’s instrument for establishing an official truth at the exact speed at which the truth’s consequences can be outlived. Justice Liberhan’s seventeen years are the extreme value of that function, not an exception to it, and any reform argument that begins with the judge’s pace rather than with the Act’s incentives has mistaken the symptom for the design.

The Witnesses: What the Testimony Established

A commission’s report is only ever the residue of its hearings, and the Liberhan hearings, spread across twelve years of evidence, assembled the fullest sworn record of the Ayodhya campaign that exists. More than one hundred witnesses passed through the witness box: the movement’s political leadership, its religious leadership, the officials of two governments, the police officers who had commanded at Ayodhya, the journalists who had photographed the domes falling, and the functionaries who had organised the kar sevaks’ convergence. The testimony’s value lies less in any single deposition than in the accumulation of concessions. Witness after witness, examined on oath and confronted with the documents of 1992, narrowed the ground on which the demolition could be described as an accident of crowd emotion. The assurances to the Supreme Court were produced and their authors examined on them. The orders to the police were produced. The speeches of 5 December at Lucknow were played and transcribed. The movement’s own literature, its mobilisation instructions and its camp arrangements at Ayodhya, entered the record through the men who had written and administered them.

Advani’s deposition ran across several appearances and set the terms his defenders and his critics still use. He maintained before the Commission, as he had maintained in public since the afternoon itself, that the demolition had saddened him, that he and Joshi had appealed to the kar sevaks to descend, and that he had not known of any plan to bring the structure down. The Commission weighed that testimony against the mobilisation record he had led since the Rath Yatra and against the findings on planning, and its conclusion, that the appeals were feeble and the leadership’s distance pretended, is a judgment on the deposition as much as on the day. Joshi’s testimony tracked a similar line. Kalyan Singh, whose examination the Commission sought for years, finally deposed in August 2005, closing the evidence; the report’s portrait of his government, drawn in the language quoted later in this article, rests substantially on the paper record of assurances and orders rather than on his oral defence of them. Officials of the Union government deposed on the intelligence that had reached Delhi and on the Centre’s reasoning through the autumn of 1992, giving the Commission the material for its criticism of the Rao government’s passivity.

Two features of the evidence phase shaped everything the report could and could not do. The first is that the Commission could consider material a criminal court would grade or exclude: press footage and photographs, newspaper reports, the movement’s pamphlets, the pattern of logistics. Its planning finding is built from that breadth, from the accumulation of a thousand details of preparation that no single exhibit proves and that together admit, in the Commission’s judgment, no other reading. The second feature cuts the other way. A commission cannot test its emerging conclusions against a defence conducted to criminal standards, and the report’s severest critics inside the movement argued in 2009 that the inquiry had proceeded for years as an examination in one direction, hearing the prosecution’s archive at leisure while the accused leaders’ case was compressed into depositions the Commission was free to disbelieve. The honest summary is that both features are constitutive of the instrument. The 1952 Act builds a body that can know more than a court and bind less than a court, and the Liberhan record is what that design produces when it is given seventeen years and an event of the first magnitude: a sworn archive of unmatched completeness attached to conclusions of unmatched unenforceability.

The Report of 30 June 2009

The report Justice Liberhan submitted ran to 1,029 pages with annexures, organised as a narrative of the Ayodhya movement’s growth, a reconstruction of the demolition day, an examination of the assurances and the administrative collapse that preceded it, and a set of conclusions assigning culpability by name. Its bulk has made it a document more often excerpted than read whole; its findings circulate in summaries, lecture decks and seminar slides, and readers who receive those summaries as presentation files can open them directly in a browser through a PPT viewer. The report’s argumentative core, however, is compact enough to state. The Commission concluded that the events of 6 December 1992 were the product of a joint conspiratorial enterprise, that the mobilisation of kar sevaks was orchestrated and planned rather than spontaneous, that the Uttar Pradesh government of Kalyan Singh was the key instrument through which the enterprise was protected from prevention, and that sixty-eight named persons, from the movement’s senior-most leadership to officials on the ground, were culpable for leading the country to the brink of communal discord. Four findings carry the report, and each deserves separate treatment, because the post-2009 engagement handled each one differently.

The report’s passage from submission to publication is the audit trajectory’s epilogue in advance, and it belongs in the record before the findings themselves. Justice Liberhan handed the document to Prime Minister Manmohan Singh on 30 June 2009, and for nearly five months the government of India said almost nothing about it. The report rested with the Home Ministry while the six-month statutory window for tabling ran. No summary was released, no briefing given, no indication offered of the government’s intentions toward sixty-eight named persons or toward the machinery that had produced them. When the contents finally surfaced, they surfaced as a leak to a newspaper, and the government’s response to its own audit became a crisis of the leak’s management: an emergency meeting of the Union Cabinet on the morning of 24 November 2009 approved the tabling, the Home Minister carried the report and the Action Taken Report into both Houses under opposition protest, and the state’s formal reception of its seventeen-year audit was accomplished inside a quarrel about how the newspapers had obtained it a day early. A commission that had been extended forty-eight times in silence was published, in the end, by accident, and received, in form, as an embarrassment to be managed rather than a record to be answered. Everything the findings contain should be read with that reception in mind, because the reception was the first instalment of the implementation.

The report’s internal architecture mirrors its terms of reference and rewards a brief description, because the document is usually cited by its conclusions alone. Its early volumes reconstruct the dispute’s long prehistory, from the mosque’s construction and the nineteenth-century conflicts through the 1949 appearance of the idols and the litigation that froze the site, to the unlocking of 1986 and the movement’s organised growth thereafter. Its central volumes reconstruct the crisis year and the day itself from the assembled testimony, the assurances, the intelligence record, the orders and the footage. Its conclusions then distribute culpability across the sixty-eight names, analyse the conduct of the two governments, and close with recommendations addressed to the prevention of recurrence: the protection of disputed religious places, the accountability of administrations during communal mobilisation, the insulation of police command from political direction at the moment of crisis. Annexures carry the documentary spine, the notifications, the correspondence between Lucknow and Delhi, the texts of assurances, so that the report functions as its own archive and a reader can test its conclusions against the papers they rest on. That self-archiving quality is the document’s lasting strength and the reason it survives its critics: later writers on Ayodhya, whatever their verdict on Justice Liberhan’s judgments, work from a record he compelled into existence on oath, much of which would otherwise have remained in government files and fading memory. The audit’s findings can be rejected, as they were by the movement and discounted by the criminal court. The audit’s record cannot be unmade, and every subsequent account of 6 December 1992, including the accounts written to refute the Commission, is built partly from its bricks.

Finding One: Sixty-Eight Names

The report’s most reported sentence was a list. Sixty-eight persons were held culpable, and the names at the head of every newspaper’s account were those of the Bharatiya Janata Party’s senior leadership: L. K. Advani, Murli Manohar Joshi, Uma Bharti, Kalraj Mishra, Vinay Katiyar, and Atal Bihari Vajpayee, alongside the Vishwa Hindu Parishad’s Ashok Singhal and Giriraj Kishore, the Rashtriya Swayamsevak Sangh’s leadership, Sadhvi Rithambara, and the chief minister Kalyan Singh. The Commission was careful, in its own text, about the gradations within that list. Some of the named had directed the movement for years; some had been present at Ayodhya on the day; some had spoken at the rally at Lucknow on 5 December 1992; some, in the Commission’s judgment, held responsibility through the ideological and intellectual leadership of a campaign whose destination they understood. The report’s harshest language was reserved for the three leaders it called pseudo-moderates: Vajpayee, Advani and Joshi, of whom it wrote that they had pretended to keep a distance from the Ram Janmabhoomi campaign while aware of its direction, and concluded, in a passage quoted in every account of the report since, that they had violated the trust of the people and that the Commission had no hesitation in condemning these pseudo-moderates for their sins of omission.

Vajpayee’s place in the list drew the sharpest dispute, and the dispute itself records the audit’s method. The former prime minister had not been at Ayodhya on 6 December 1992; he had addressed the Lucknow rally the previous day, a speech whose recording and transcripts the Commission examined, in which he had spoken of kar sevaks going to Ayodhya and of the ground needing to be levelled, language his defenders read as metaphor addressed to the kar seva’s ritual and his critics read as coded preparation. The Commission placed him among the culpable on the strength of his position within the movement’s leadership and his knowledge of its design, a responsibility of membership and awareness rather than of presence. Advani and Joshi were present at Ayodhya, seated at Ram Katha Kunj, and the Commission found their appeals to the kar sevaks on the domes to have been, in its word, feeble: requests made for the record by leaders who, on the evidence of the mobilisation they had led for two years, commanded an obedience they chose that afternoon not to exercise. Uma Bharti occupied a category of her own in the proceedings, because she had told the Commission, as Justice Liberhan recalled in interviews after the criminal verdict of 2020, that she took responsibility for the demolition categorically. The report treated that candour as confirmation of the enterprise’s organised character: a spontaneous riot does not produce a minister who accepts responsibility for its outcome as a matter of pride.

How many people did the Liberhan report hold culpable?

The report held sixty-eight persons culpable for leading the country to the brink of communal discord. The list joined the Bharatiya Janata Party’s senior leadership, among them L. K. Advani, Murli Manohar Joshi and Atal Bihari Vajpayee, to Vishwa Hindu Parishad and Rashtriya Swayamsevak Sangh leaders, Uttar Pradesh officials and Chief Minister Kalyan Singh.

Finding Two: The Government That Stood on Guard

The report’s institutional centre of gravity is its treatment of the Kalyan Singh government, because there the audit method, duty measured against performance, bites hardest. The Uttar Pradesh government had assured the Supreme Court that the structure would be protected, had assured the National Integration Council and the Union government to the same effect, and had obtained the permission for symbolic kar seva on the basis of those assurances. The Commission found that the state government had not merely failed to honour its word but had arranged its conduct to make prevention impossible. In the report’s most quoted passage on the state government, the Commission wrote that Kalyan Singh stood on guard against the possibility of any preventive action by the central government or the Supreme Court or any other institution, and that he and his trusted lieutenants spared no lie before the highest authorities to befool them and to tie their hands with the niceties of a constitutional democracy. The finding mattered because it converted a familiar political argument, that a chief minister lost control of a crowd, into an audited conclusion of a different order: the crowd was never meant to be controlled, the police had been ordered not to fire in any circumstances, the paramilitary forces sent by the Union government were kept from effective deployment, and the state’s assurances were the enterprise’s outer wall.

One legal consequence did land on the assurance regime during the audit’s lifetime, and its smallness measures the whole. The Kalyan Singh government’s undertakings to the Supreme Court had covered not only the mosque’s protection but the status of the land around it, and in Mohammed Aslam v Union of India, decided on 24 October 1994, the Supreme Court held Kalyan Singh guilty of contempt for the breach of his government’s undertaking, sentencing the former chief minister to a symbolic imprisonment of one day and a fine of two thousand rupees. It remains, across the twenty-eight years this article covers, the only judicial penalty imposed on a principal of 6 December 1992: one day, symbolic, for the contempt, while the demolition itself travelled through the courts to an acquittal in 2020. The Commission’s archive and the contempt judgment read together state the assurance system’s whole logic. The paper was enforced, eventually and symbolically, against the man who had signed it. The act the paper existed to prevent was never punished at all.

The Commission extended the institutional failure finding beyond Lucknow, though with a difference of kind. The Union government of P. V. Narasimha Rao was criticised for its failure to act on the intelligence and the warnings before it, for accepting assurances that the record gave it reason to doubt, and for a passivity across 1992 that the report treated as a dereliction of the Centre’s constitutional responsibility for a state sliding toward a foreseeable crime. Rao was not placed among the sixty-eight culpable, a distinction the report’s critics on one side read as leniency toward the audit’s own appointing authority and its defenders read as the line between culpability for an enterprise and failure in preventing one. The distinction is the audit’s signature: the Commission distributed responsibility in grades, conspiracy at the movement’s centre, facilitation in the state government, omission at the Centre, and rhetorical distance punished as hypocrisy in the case of the pseudo-moderates. A criminal court, working to a single standard of proof, could never produce such a map. That is the audit’s value, and, as the sequel showed, also its weakness, because a map that no institution is obliged to act on can be admired and ignored in the same gesture.

The Officials in the List: Bureaucratic Culpability

The sixty-eight names were not all politicians, and the report’s treatment of the official names is where its audit character shows most plainly, because officials cannot plead ideology. The Commission examined the conduct of the Uttar Pradesh administration and police through the chain that ran from Lucknow’s secretariat to the Faizabad district officers and the police commanders deployed at Ayodhya, and it assigned culpability within that chain on the audit’s standard question: what was this office’s duty on 6 December 1992, and what did the office do? The answers it recorded describe a machinery that had been aligned, level by level, with the state government’s design. The district administration that had managed the site through the morning’s breaches did not escalate. The police command, bound by the chief minister’s order against firing in any circumstances, watched the cordon dissolve. The senior officials who had drafted and transmitted the assurances to Delhi and to the Supreme Court were examined on the distance between their drafts and their knowledge. For a political reader the bureaucratic names are the report’s least memorable lines. For an institutional reader they are its most consequential, because they identify the layer at which prevention actually failed and at which any future prevention would have to be organised, and because the Action Taken Report’s silence falls on them too: no official named by the Commission is recorded as having been disciplined, demoted or prosecuted on the report’s basis in the years after 2009. The politicians in the list could answer that a commission’s findings are not verdicts. The officials could have been answered by their own service rules, which require no verdict to act on a documented dereliction. Nothing in the record shows that they were.

The Audit Grammar: Duties on Paper

The Liberhan report’s method becomes visible when its findings are read as a set of comparisons between paper and conduct. The Ayodhya crisis of 1992 was governed, to an unusual degree, by documents of assurance. A state government filed undertakings with the Supreme Court and received permission for a religious ceremony on their strength. A chief minister assured the National Integration Council. A Union government recorded its reliance on those assurances in its own White Paper. A movement published its programme for a symbolic ceremony. The Commission’s work, at its core, was to lay each document beside the day it governed and measure the distance. The no-firing order measured against the undertaking of protection. The Lucknow speeches of 5 December measured against the programme of symbolic kar seva. The dais at Ram Katha Kunj measured against the appeals its occupants claimed to have made. This is why the report reads, in its best passages, less like a prosecution than like an audit of a bankrupt firm, in which every representation made to a regulator is traced to the transaction it misdescribed.

The grammar matters for the series’ larger argument about religion and the state, framed in the contested-settlement framework as a settlement maintained through postponement. Assurances are postponement’s paperwork. They allow every institution to proceed as though the constitutional order were intact, the state government trusted, the court obeyed, the ceremony symbolic, while the event assembles underneath the paper. The Commission’s deepest finding, beneath the four headline findings, is that the paper itself was part of the enterprise: that the assurances functioned, in the report’s phrase about befooling the highest authorities, as the mechanism by which the demolition purchased immunity from prevention. An audit that establishes this has done something neither a trial nor a title suit can do. It has shown how the forms of constitutionalism were used as instruments against constitutionalism’s substance, by office-holders acting within their legal powers at every step until the afternoon when the powers were simply not used. The post-2009 state, invited to act on a report whose lesson was that its own forms had been gamed, responded in form: an Action Taken Report. The symmetry is the story.

Finding Three and Four: Orchestration and the Architect

The report’s third and fourth findings answer the question the whole country had argued since the afternoon itself: was the demolition a plan or an eruption? The Commission’s answer, in its paragraph 158.10, the most technically argued passage of the report, is a chain of physical facts. The mode of assault, the small number of kar sevaks who carried out the demolition against the constraints of space, the veiling of the identity of the kar sevaks who entered the domes, the removal of the idols and the cash box from beneath the central dome before its fall and their reinstallation in a makeshift temple the same night, the availability of implements and material for demolition and for swift construction, led the Commission categorically to the conclusion that the demolition was carried out with great painstaking preparation and planning. The mobilisation finding runs parallel: the convergence of kar sevaks on Ayodhya and Faizabad was, in the report’s words, neither spontaneous nor voluntary; it was well orchestrated and planned, and the army-like discipline of organisations such as the RSS, the report argued, did not corroborate the theory that the gathering was assembled for symbolic kar seva alone. The report named the Rashtriya Swayamsevak Sangh the chief architect of the demolition and the core of the Sangh Parivar, and it described the enterprise across the three organisations, in a phrase from its conclusions, as a joint conspiratorial enterprise in which a handful of leaders invoked the name of a paragon of tolerance to turn peaceful communities into intolerant hordes.

The mobilisation evidence on which the orchestration finding rests was assembled from the campaign’s own paperwork and from the accounts of the men who ran its logistics. The Commission recorded the arrangements by which kar sevaks were summoned, transported, camped and fed at Ayodhya and Faizabad in numbers that grew across the autumn of 1992; the instructions issued for the kar seva; the composition of the crowd at the site, which included, on the evidence the Commission accepted, kar sevaks who had practised the physical tasks of the demolition, climbing and hauling with ropes and grappling irons, before the day itself. It recorded the management of the site’s geography: the positioning of leaders at Ram Katha Kunj, the routes by which the cordon was breached, the small working parties who performed the demolition while the vast crowd functioned as presence and pressure rather than as the instrument. And it recorded the day’s second half, which spontaneity explains worst of all: the orderly removal and reinstallation of the idols, the raising of the makeshift temple on the debris before nightfall, the preparation of the site for worship at dawn. A riot does not file its paperwork in advance or consecrate its results by evening. The Commission’s orchestration finding is, at bottom, a refusal to let the scale of the crowd disguise the narrowness of the act: a few hundred prepared men demolished the mosque, and the lakhs around them, on the report’s reading, were the enterprise’s protection and its alibi.

These findings are where the audit reading and the ideology question meet, and they should be read beside the tripartite-disentanglement framework, which separates the ideological strands that the Ayodhya campaign fused. The Commission’s architecture finding is an empirical claim about coordination, supported in its text by the logistics of mobilisation, the training and deployment of kar sevaks, the management of the crowd’s composition and the sequencing of the day’s acts, from the removal of the idols to the construction of the makeshift temple to the preparation of the ground for a future temple. It is also the finding that the criminal process would eventually reject outright, not by re-examining the logistics but by ruling the prosecution’s evidence of them inadmissible or unproven. The two conclusions have coexisted in the Indian public record ever since, a commission’s finding of meticulous planning and a court’s finding of spontaneity, each formally valid within its own procedure, and the citizen who asks what actually happened at Ayodhya receives from the state two answers that cannot both be right. That coexistence, rather than either answer alone, is the audit trajectory’s most consequential product, and this article returns to it after the responses and the criminal track are on the record.

The Indicted Answer Back

The report was submitted in June 2009 but remained unpublished through the autumn, and its contents entered public life through a leak: on 23 November 2009, the Indian Express published the report’s conclusions a day before the government tabled the document in Parliament, and the winter session opened in uproar. Advani rose in the Lok Sabha to take strong objection to the leak, to accuse the government of engineering it, and to repeat the description he had carried since 1992, that the demolition was the saddest day of his life. Home Minister P. Chidambaram denied that the government had leaked the report and tabled it, with the Action Taken Report, on 24 November 2009. The Bharatiya Janata Party’s institutional response rejected the report as a political document prepared to serve the ruling party’s purposes; its leaders argued in the debates that followed, through December 2009, that the Commission had converted a failure of crowd control into a conspiracy by hindsight, that Vajpayee’s inclusion exposed the exercise’s partisan design, and that a report delivered seventeen years late, against men in their eighties, was an instrument of election-season embarrassment rather than of institutional repair. Those arguments deserve their strongest statement, and it is this: a commission that takes seventeen years forfeits moral authority over timeliness; a report that grades responsibility from conspiracy to sins of omission invites the charge that it has written politics in the grammar of law; and a finding against a leader for a speech’s metaphor, delivered after that leader’s retirement from public life, reads to his supporters as verdict by insinuation.

The responses from within the movement were not uniform, and the audit record is richer for the divergences. Uma Bharti neither denied nor qualified: she had accepted responsibility before the Commission itself, and after the criminal acquittal of 2020 Justice Liberhan publicly recalled that she had taken responsibility categorically. Kalyan Singh, who had left the BJP and returned across the intervening years, rejected the report’s account of his government, standing on his resignation of 6 December 1992 as the act of a chief minister who had accepted moral responsibility while denying criminal design. The Rashtriya Swayamsevak Sangh rejected the architect finding. The Congress party, whose own prime minister’s government the report had criticised, welcomed the findings against the BJP leadership and answered the criticism of Rao with the argument that the Centre had been constitutionally constrained by the state government’s assurances, the same assurances the Commission found to have been lies. A. G. Noorani, who had demanded a rigorous audit for seventeen years, received the report as vindication of the planned-demolition account and as an indictment of the deferral system that had delayed it past the point of consequence. Manoj Mitta’s post-2009 journalism pressed the point the BJP’s defenders and the report’s celebrants both preferred to skip: that the Commission’s own conduct, its acceptance of extension after extension and its four years of writing after the evidence closed, had made the audit an accomplice in the deferral it documented.

Why did the findings produce no prosecutions?

The findings produced no prosecutions because a commission cannot prosecute, and the bodies that could were already seized of the case on their own evidence. The Central Bureau of Investigation’s prosecution ran on a separate track from 1993, governed by standards of proof the Commission did not apply, and the Action Taken Report began no fresh proceedings.

Tabling, Leak and the Action Taken Report

The six months between submission and tabling are the audit trajectory in miniature. The Commissions of Inquiry Act obliges the government to lay the report before the legislature with a memorandum of action taken within six months of receiving it. The Manmohan Singh government received the report on 30 June 2009 and tabled it on 24 November, inside the statutory window and at the last practical moment of the winter session’s opening, after the leak had stripped the tabling of ceremony. The Action Taken Report that accompanied it is the document on which this article’s claim principally rests. Read against the findings, the memorandum is an exercise in absorption. The government accepted the report’s account in general terms, recorded that many of its recommendations touched matters governed by existing law and existing machinery, pointed to measures already in force, and committed itself to no prosecution, no dismissal, no commission-specific reform and no timetable. The parliamentary debate that followed in December 2009, repeatedly disrupted, organised itself along party lines within hours and concluded without a vote that bound anyone to anything. Its content deserves a sentence of record, because the debate was the audit’s only hour of institutional life. Advani, defending himself in the Lok Sabha, returned to the themes of his testimony: the demolition as the saddest episode of his public life, his appeals at Ayodhya as genuine, the report as a political exercise whose inclusion of Vajpayee discredited its method. The government’s speakers, led by the Home Minister who had tabled the report, defended the Commission’s integrity and its findings, and trained their fire on the movement’s responsibility rather than on their own memorandum’s emptiness, which no speaker for the treasury benches was asked to justify in operational terms: which recommendation, which prosecution, which reform, by when. The opposition benches that had demanded the tabling used the debate to prosecute the leak; the benches that had leaked or received the leak used it to prosecute 1992. Between the two prosecutions, the Action Taken Report, the only document in the room that committed the living government to anything at all, passed almost without examination, which is to say it performed its function perfectly. A memorandum designed to absorb an audit was absorbed into a debate designed to exhaust one, and the winter session adjourned. By the new year the report had passed into the archive, its recommendations neither rejected nor enacted, the fate the Act’s design makes available to any government patient enough to wait for the news cycle to move.

This is the pattern that the contested-settlement framework of this pillar predicts for the hardest questions of religion and state in India: not resolution, and not open repudiation, but a settlement maintained by postponement, in which institutions process a challenge until the challenge loses its charge. The Liberhan trajectory is that pattern’s most fully documented instance, because the postponement is itself the archive: forty-eight extension notifications, a six-month tabling delay, an Action Taken Report of studied generality, and a debate without consequence. Each step was lawful. Each step was defended at the time on plausible grounds. The aggregate is a technique of governance that the political science of the period, watching the same years produce the integrated three-tensions framework of a rising opposition, largely failed to name, because it leaves no decision to study. It leaves only duration.

The Road Not Taken: Prevention Law and the Missing Reform

If implementation had been intended, its shape was available, because the same years that consumed the Commission also produced a legislative attempt to build the preventive machinery the demolition had shown to be absent. The Prevention of Communal Violence Bill, introduced by the United Progressive Alliance government in 2005 and revised through a National Advisory Council draft in 2011, proposed exactly what an auditor of 1992 would have prescribed: defined duties for district officials during communal mobilisation, accountability for failures of prevention, protection for victims and a framework for the Centre to act when a state government would not. The bill was opposed by state governments across party lines as an intrusion into the federal distribution of public order, criticised by the Bharatiya Janata Party as discriminatory in its drafting, revised, reintroduced and allowed to lapse with the Fifteenth Lok Sabha in 2014. No version of it has returned. The parallel is not decorative. The bill and the report were the two institutional children of the same diagnosis, that Indian communal violence is administered into possibility by failures of prevention that carry no cost, and they died the same death, one by extension and absorption, the other by lapse and federal objection. Between them they map the full repertoire of non-implementation available to the Indian state: a finding can be noted, a bill can be drafted, a debate can be held, a decade can pass.

The comparison sharpens the article’s claim against its easiest misreading. Audit-without-implementation does not require a conspiracy of silence, and this article alleges none. It requires only that each participant in the sequence act within a defensible local reason: the Home Ministry extending an inquiry whose subject remained sub judice in the public mind, the government tabling a report at the statutory deadline’s edge, the opposition converting a debate into a partisan exchange, the federal units defending their constitutional turf against a prevention law, the courts answering the questions put to them in the forms in which they were put. The Liberhan trajectory is seventeen years of defensible local reasons summing to an indefensible whole, and the Commission’s archive, precisely because it records the machinery from inside, is the document that lets a reader watch the summation happen. That is a contribution no verdict in the criminal track, and no decree in the title track, was designed to make.

The Parallel Criminal Track: 1993 to 2020

Against the audit’s seventeen years ran the criminal case’s twenty-seven. Two first information reports were registered at Ayodhya on 6 December 1992, one against unnamed kar sevaks for the demolition itself and one against eight named leaders, among them Advani, Joshi and Uma Bharti, for speeches and incitement. The Central Bureau of Investigation took over the investigation, and its 1993 chargesheet named forty-nine persons in a combined case alleging conspiracy. The procedural history that followed consumed decades on questions of forum and framing: the case was split between courts at Rae Bareli and Lucknow; in 2001 the conspiracy charge against the senior leaders was dropped on a technical ground in the Rae Bareli stream, a defect the Allahabad High Court later noted without reviving the charge; and for sixteen years the conspiracy allegation, the heart of the prosecution and the mirror of the Commission’s central finding, sat outside the trial altogether. On 19 April 2017 the Supreme Court revived the conspiracy charge, clubbed the two trial streams at Lucknow, ordered day-to-day hearings and set the special court a deadline, extending the presiding judge’s tenure to let him finish. By the time of judgment, seventeen of the forty-nine accused had died, among them Ashok Singhal and Giriraj Kishore, and thirty-two stood for verdict.

The prosecution’s theory, as the Central Bureau of Investigation framed it from its 1993 chargesheet onward, had been the Commission’s theory in criminal dress: that the demolition was the object of a conspiracy hatched by the movement’s leadership, executed through the mobilisation, and protected by the state government’s design. The bureau supplemented its chargesheet as the case moved between forums, and the accused list it carried into the Lucknow trial joined the political leadership to the movement’s organisers and the officials of the day, forty-nine names at the start, reduced by death across twenty-seven years to thirty-two. The theory’s weakness, as the trial finally exposed it, was never its narrative plausibility, which the Commission’s archive supports in detail, but its proof discipline: the speeches had to be authenticated recording by recording, the meetings proved witness by witness, and the chain from mobilisation to demolition built link by link for each accused, under a standard that acquits whenever a link is left in doubt.

On 30 September 2020, Special Judge Surendra Kumar Yadav acquitted all thirty-two. The judgment, running beyond two thousand pages, held that the demolition was not pre-planned, that no criminal conspiracy had been proved, that the accused leaders had attempted to restrain the crowd rather than incite it, that the men who climbed the domes were anti-social elements, and that the Central Bureau of Investigation’s audio and video evidence had not been authenticated to the standard a criminal conviction requires. Stated by outcome, as this article states every judgment: the prosecution failed, on the evidence admitted, to prove its case against any accused, and the case ended. Two Ayodhya residents carried an appeal to the Allahabad High Court, which dismissed it on 9 November 2022 on the ground that the appellants were not victims with standing to appeal an acquittal, and the criminal track closed there.

How did the criminal court’s answer differ from the Commission’s?

The Commission found the demolition meticulously planned by a joint conspiratorial enterprise; the special court found it unplanned and the conspiracy unproved. The difference is procedural before it is factual: the Commission weighed the record under no standard of proof, while the court judged authenticated evidence against named accused and discounted the recordings on which the planning case rested.

The sixteen lost years of the conspiracy charge deserve their own paragraph in any honest account, because they show the criminal track failing by the same mechanism as the audit track, procedure as deferral. The defect that removed the charge in 2001 was administrative rather than evidentiary: the notifications under which the demolition cases had been distributed between the courts at Rae Bareli and Lucknow were flawed, and the charge of conspiracy, the only charge that described the event the country had watched, fell through the flaw. No court in that sequence found that the conspiracy allegation was false; the system found that it had been filed defectively, and then declined for a decade and a half to cure the defect, through governments of both national parties, until the Supreme Court in 2017 did in one order what the machinery had not done in sixteen years: it restored the charge, merged the streams, and imposed a clock. Even then the clock ran three and a half years, through a change of presiding judge and a pandemic, to an acquittal that turned on the authentication of recordings. The parallel with the Commission is exact and bleak. India did not lack forums for the demolition; it lacked, in forum after forum, the institutional will to let any of them finish while finishing still mattered, and the two tracks, audit and criminal, each arrived at last at a complete and formally valid answer, twenty-eight years after the afternoon both were describing.

The juxtaposition is the audit trajectory’s hardest exhibit, and it must be handled exactly. The acquittal does not falsify the Commission’s findings, because the two bodies answered different questions under different rules: culpability in the audit sense, a judgment on office, conduct and responsibility, against guilt in the criminal sense, a judgment on proved individual acts. Judge Yadav’s court, notably, did not find that the Commission had invented its record; it found the prosecution’s proof insufficient, and it treated the speeches and recordings through the admissibility rules of a trial. Justice Liberhan, asked about the verdict in its aftermath, declined to criticise it, remarking that everyone does his job honestly, that the court had the right to differ, and that he stood by his report and its conclusion of a civil conspiracy. The institutional fact remains that the Indian state, presented with the same afternoon, maintains two official truths in two registers, and has arranged its affairs so that neither register can disturb the other. The audit cannot convict; the court, acquitting, does not erase the audit; and the citizen reads both.

9 November 2019: A Verdict That Answered a Different Question

Eleven months before the acquittal, the Supreme Court settled the question the Liberhan Commission had never been asked. The Constitution Bench in M. Siddiq v Mahant Suresh Das, delivering a unanimous judgment on 9 November 2019, decided the title to the disputed land. The Court held that the Sunni Central Waqf Board had not established exclusive title, that the Hindu claimants had established a possessory case on the balance of probabilities, and it directed that the disputed site be handed to a trust for the construction of a Ram temple, with five acres at a suitable place in Ayodhya allotted to the Sunni Waqf Board for a mosque. On the demolition itself the judgment spoke in the register of law rather than of responsibility: it recorded that the destruction of the mosque in 1992 had been an egregious violation of the rule of law, and that the placing of the idols in 1949 had been a desecration the law could not recognise as creating rights. It named no culprit, assigned no culpability, and relied on the Liberhan findings for nothing in its reasoning on title, which it built from the Archaeological Survey’s excavation record, the historical evidence of worship and possession, and the law of limitation.

What did the Supreme Court decide in November 2019?

The Constitution Bench decided title, not culpability. It awarded the disputed Ayodhya site to a trust for a Ram temple, directed that five acres elsewhere in Ayodhya be allotted to the Sunni Central Waqf Board for a mosque, and described the 1992 demolition as an egregious violation of the rule of law, without adopting the Liberhan Commission’s findings on responsibility.

The three institutional answers stand in a row, and their separateness is the point. The Commission answered the responsibility question and was not implemented. The criminal court answered the guilt question and acquitted. The Supreme Court answered the property question and closed the dispute the movement had opened in 1949, on evidence and doctrines that bypassed the audit altogether. Between them, the answers exhaust the Indian state’s repertoire for an event of this kind, and the repertoire contains no instrument that converts an audited finding of political responsibility into a political consequence. The temple’s construction proceeded under the trust the judgment created; the pran pratishtha of January 2024 consecrated it; and the Liberhan report rests in the parliamentary archive as the republic’s fullest account of how the site was cleared for the outcome the Court eventually regularised.

The Report’s Own Limits

An audit of the audit is owed before the adjudication, because the report’s authority in this article’s argument should not exceed what the document can bear. The report is repetitive across its 1,029 pages, returning to episodes and formulations as the years of its writing accumulated, and even sympathetic reviewers at its publication remarked that its bulk owed something to the absence of an editor with power over a retired chief justice. It is a one-man document in a stronger sense than the phrase suggests: no colleague’s dissent disciplines its judgments, no minority note marks the points where another reader of the same record might have graded responsibility otherwise, and its severest passages, the pseudo-moderates condemnation above all, carry a rhetorical heat that a bench of three would probably have cooled and that its targets exploited to discount the whole. Its evidence, assembled for an audit, included material that no trial could have admitted, and the report does not always mark, page by page, the difference between what was proved on oath, what was documented, and what the chairman inferred from the pattern of the whole; the criminal court’s later discounting of the recordings was a reminder that the archive’s breadth and a court’s admissibility are different virtues. And the four years between the close of evidence in 2005 and submission in 2009 remain the report’s least explained feature, years in which the document existed nowhere in public and its author answered to no calendar, a silence at the heart of the audit that its defenders attribute to the writing of a thousand pages and its critics to the same deferral the report condemns in others.

These limits are real, and they do not overturn the trajectory argument, for a reason worth stating plainly. The report’s weaknesses are weaknesses of craft and pace. The trajectory’s failure is a failure of response, and it would have been identical had the report been flawless, as the Srikrishna comparison shows: a tighter, faster, better-edited audit met the same absorption in the same years. Critics who begin with Liberhan’s repetitions end, if they follow their own evidence, at the Action Taken Report, which is a short document, written promptly, by a government with every resource, and which performed the deferral in miniature that the Commission had performed at scale. The report’s limits explain why its enemies could discount it. They do not explain why its friends, in office when it arrived, did nothing with it, and that second fact is the one the next catastrophe’s commission will inherit unless the instrument itself is redesigned.

The Careers of the Indicted: 2009 to 2020

The complication this article must address, the argument that the audit did produce consequences, is best tested against the biographies of the indicted in the decade after the report. The record is not ambiguous. Atal Bihari Vajpayee had retired from public life before the report appeared and died in August 2018, honoured across party lines, his place in the report’s list a footnote in the obituaries. L. K. Advani, who led the opposition in the Lok Sabha that debated the report in 2009, was by 2014 placed in the Bharatiya Janata Party’s Margdarshak Mandal, the elders’ body created as Narendra Modi’s leadership consolidated, a sidelining executed by his own party for its own reasons and unconnected to any finding. Murli Manohar Joshi travelled the same road to the same body. Uma Bharti, named in the list and the one leader who had accepted responsibility before the Commission, became a minister in the Union government formed in May 2014 and held the water resources portfolio. Kalyan Singh, the report’s central institutional culprit, became Governor of Rajasthan in 2014, a constitutional office, and after the criminal acquittal of 2020 returned to the Bharatiya Janata Party’s active ranks before his death in August 2021. Vinay Katiyar sat in the Rajya Sabha. Ashok Singhal led the Vishwa Hindu Parishad until his death in 2015. Not one career in the list of sixty-eight can be shown to have been shortened, diverted or burdened by the report that named it. The consequences the audit produced were real but they were literary and archival: a permanent entry in the record, a citation in the arguments of opponents, a chapter in the histories. In the currency the audit was denominated in, responsibility, the exchange rate at the treasury of Indian politics was zero, and it stayed zero through the tenures of the government that received the report and the governments that succeeded it.

This is the context in which the report’s afterlife in the temple’s own chronology should be read. The trust created by the 2019 judgment began construction of the Ram temple in August 2020, weeks before the criminal acquittal, and among the figures honoured in the temple’s movement-history were men the Commission had held culpable and the special court had just acquitted, Champat Rai of the Vishwa Hindu Parishad among the trust’s office-bearers. The pran pratishtha of January 2024, performed by the Prime Minister before the assembled leadership of the movement’s generation, closed the arc that the demolition had opened, in the register of achievement. The Liberhan report survives in that arc as its shadow text: the only official document that describes the arc’s founding afternoon in the grammar of culpability, preserved, unrepealed and unanswered in the archive of the Parliament that debated it for a winter and moved on.

The Other Inquiry of That Winter: Srikrishna in Mumbai

Six weeks after the Liberhan Commission was constituted, the government of Maharashtra appointed Justice B. N. Srikrishna to inquire into the Mumbai riots of December 1992 and January 1993, the violence the demolition had ignited in India’s commercial capital, in which roughly nine hundred people died. The two commissions are the period’s controlled experiment in the audit form: same winter, same instrument, opposite durations, convergent outcomes. Srikrishna’s inquiry was interrupted where Liberhan’s was merely extended: the Shiv Sena and Bharatiya Janata Party government that took office in Maharashtra in 1995 disbanded the commission in January 1996, and reconstituted it months later under public and judicial pressure, with the March 1993 bomb blasts added to its charge. Srikrishna reported in February 1998. His findings named the Shiv Sena’s leadership, recording that Bal Thackeray had, in the report’s phrase, acted like a veteran general commanding his loyal Shiv Sainiks to retaliate, and named serving police officers in connection with specific firings and failures, among them the killings at the Suleman Usman Bakery. The governments that received the report accepted its language in principle and implemented its named accountability barely at all; officers criticised in its pages continued in service, some to promotion, and the prosecutions it pointed toward arrived years late and mostly failed. The Srikrishna trajectory took five years to reach the destination Liberhan reached in seventeen, and the destination was the same building.

The comparison disciplines the argument about Liberhan’s pace. If duration were the variable that determined implementation, Srikrishna’s comparatively brisk report would have been implemented and Liberhan’s late one ignored. Both were ignored in the same grammar, tabling, a memorandum, a debate or the promise of one, and then the archive, because the variable that governs implementation is not the audit’s speed but the audited parties’ presence inside the receiving state. In Maharashtra the party indicted in the report governed the state that received it. In Delhi the parties indicted in the Liberhan report, and the party criticised in it, alternated in the government that extended it, tabled it and answered it. An audit addressed to the audited will be implemented at the audited parties’ pleasure, and the pleasure of every government in the Liberhan file, across seventeen years, was postponement. The two commissions together make the point that neither makes alone: the failure is not in the judges, who produced findings of fact that have survived every subsequent proceeding, but in a constitutional design that routes findings about governments through governments, and then expresses surprise at the temperature of the room in which they land.

The Scholars’ Quarrel over the Audit

Four bodies of commentary have organised the report’s reception, and the article’s claim should be located among them precisely. A. G. Noorani, whose The Babri Masjid Question, 1528 to 2003 remains the most exhaustive documentary history of the dispute, treated the inquiry throughout its life as a test the republic was failing in slow motion; his post-2009 essays read the report as belated vindication of the planned-demolition account and its delay as the state’s confession. Manoj Mitta, the journalist who covered the Commission most continuously and wrote its proceedings into the public record when few others attended, supplied the reception’s uncomfortable second voice: his post-2009 journalism documented the Commission’s own delays, the years after the evidence closed, and the gap between the report’s severity toward the movement and its comparative gentleness toward the government that had appointed it, a gap he traced through the treatment of Narasimha Rao. Pratap Bhanu Mehta’s essays after the tabling gave the report its most careful institutional defence, arguing that commissions belong to the republic’s truth-establishing machinery, that a documented record disciplines future politics even when the present ignores it, and that judging an audit by prosecutions mistakes its genre. Paul Brass’s work on communal violence, above all The Production of Hindu-Muslim Violence in Contemporary India of 2003, supplies the fourth frame and the coldest: Brass argued that riots in India are produced by institutionalised systems with known specialists and rehearsed sequences, and that the state’s inquiries characteristically function within those systems as rituals of restoration, converting produced violence back into spontaneous tragedy so that ordinary politics can resume.

The Liberhan report is a hard case for Brass’s frame, and the hardness is instructive. Whatever its delays, the report refused the conversion his theory predicts: it named the production, the producers and the protective state machinery, in an official text, with a judge’s authority. If the ritual-of-restoration reading held completely, the report would have found a spontaneous crowd and an overwhelmed administration. It found the opposite. And yet the trajectory after the report fits Brass’s frame almost exactly, a system absorbing a truthful audit by the simple method of agreeing with it in debate and filing it in the archive, the conversion performed not on the facts but on their consequences. Christophe Jaffrelot’s scholarship on the Hindu nationalist movement supplies the complementary half: his accounts of the Sangh Parivar’s organisational integration explain why the Commission’s architecture finding, coordination across the RSS, the VHP and the BJP as a single enterprise, was the finding the movement most needed to reject, because it described the movement’s structure accurately at the moment the movement was presenting itself to voters as a conventional party among others. The quarrel, mapped this way, resolves into the article’s claim. Noorani and Mitta are right about the deferral and its authors. Mehta is right about the record and its permanence. Brass is right about the absorption, wrong only about the report itself, which declined to perform the conversion his model assigns to inquiries. A truthful audit, absorbed without consequence, is a more precise description of the Indian outcome than either failure or success, and it is the description the seventeen-year archive supports line by line.

Audit Without Implementation: The Claim Adjudicated

The strongest counter to this article’s claim must be taken at full strength. It runs: the audit did have consequences. The findings entered the political bloodstream; the Bharatiya Janata Party’s leadership carried the report’s verdict through the 2009 and 2014 cycles; the report stands in the record where schoolbooks, courts and citizens can cite it; the 2019 judgment’s language on the demolition’s illegality breathes the same air; and an audit’s function in a democracy is to establish truth, not to execute it, so that audit-without-implementation misdescribes a success as a failure. Pratap Bhanu Mehta’s post-2009 essays give this counter its most serious form: institutions of documentation discipline the future by making denial expensive, and a report that fixes the facts of 6 December 1992 in an official text has done the work its design allows.

The counter is right about the record and wrong about the trajectory, and the distinction this article has maintained, between rhetorical engagement and institutional implementation, is what separates them. Rhetorical engagement happened abundantly: a leaked report, a stormy tabling, a December debate, a permanent place in the polemics of both parties. Institutional implementation, meaning the consequences that audits exist to trigger within the state, prosecutions founded on the findings, officials disciplined, the Commissions of Inquiry Act reformed, a government bound to answer findings rather than note them, did not happen at any point in the trajectory. The comparison inside this pillar is instructive: the Srikrishna Commission into the Mumbai riots of 1992 and 1993, appointed weeks after the Liberhan Commission, reported in 1998, and its findings against named politicians and police officers met an Action Taken Report and a implementation record nearly as thin, a rhyme that suggests the pattern belongs to the instrument and the political order, not to one judge’s pace. Where the Liberhan case is singular is duration: seventeen years converted the deferral from a decision, which could be contested, into a condition, which could only be endured. A government that rejects a report makes news and takes a position. A system that extends it forty-eight times makes neither, and the accountability evaporates into procedure.

There is a final lesson in the trajectory, and it concerns the instruments a democracy builds after its next catastrophe, because India will appoint commissions again. The Liberhan archive teaches that the moment of appointment is the moment of maximum sincerity in the entire process, and that everything after it is negotiation between the finding and its consequences. A state that wished its audits to bite would not need braver judges; the republic has never lacked judges willing to write that a demolition was planned and a government complicit. It would need to move the consequences out of the audited parties’ hands: fixed tenures that executives cannot extend, reports laid before legislatures by the commission itself rather than by the government it judges, action-taken memoranda debated on a clock with a vote attached. None of these reforms was proposed by the government that tabled the Liberhan report, none was demanded with any persistence by the opposition that brandished it, and none has been enacted in the years since, though commissions have continued to be appointed, extended and received in the pattern this article has traced. The absence of reform is itself the audit’s last finding, delivered not by Justice Liberhan but by the seventeen years: the system examined its own method of examining, and voted, by silence across four general elections, to keep it.

The adjudication, then: the political-architectural reading explains the demolition’s consequences for the party system; the criminal-legal reading records the failure of prosecution; the audit-trajectory reading explains the Indian state’s method with facts it cannot use and will not bury. The Liberhan Commission was asked, in December 1992, to tell the republic what had happened and whose failure it was. It answered completely, and the republic’s institutions, across four changes of governing party and seventeen years of extensions, arranged to hear the answer at the exact speed at which it could no longer oblige them to act. That arrangement, documented notification by notification in the Commission’s own archive, is the finding about India that outlasts every finding about Ayodhya.

Frequently Asked Questions

Q: What were the Liberhan Commission’s findings on the 1992 demolition?

The Commission found that the demolition of the Babri Masjid on 6 December 1992 was neither spontaneous nor voluntary but orchestrated and planned, the product of a joint conspiratorial enterprise by the leadership of the Ram Janmabhoomi movement. It held sixty-eight persons culpable for leading the country to the brink of communal discord, found the Uttar Pradesh government of Kalyan Singh to have been the key instrument protecting the enterprise from prevention, named the Rashtriya Swayamsevak Sangh the chief architect of the demolition, and criticised the Union government of P. V. Narasimha Rao for failing to act on the warnings before it.

Q: Who was Justice M.S. Liberhan?

Justice Manmohan Singh Liberhan was a judge of the Punjab and Haryana High Court when the Union government appointed him, on 16 December 1992, to chair the one-man commission of inquiry into the demolition of the Babri Masjid. He later served as Chief Justice of the Himachal Pradesh High Court and of the Andhra Pradesh High Court while the inquiry continued, and he remained its chairman through all forty-eight extensions until he submitted the report to Prime Minister Manmohan Singh on 30 June 2009. His name attaches to the inquiry because the Commission was, from constitution to submission, a single judge’s seventeen-year examination.

Q: How long did the Liberhan inquiry take?

The inquiry took seventeen years. Constituted on 16 December 1992 with a mandate of three months, the Commission received forty-eight extensions from successive Union governments and submitted its report on 30 June 2009. The evidence phase ran until August 2005, when Kalyan Singh, the last of more than one hundred witnesses, was finally examined, and the remaining four years went to the writing of the 1,029-page report. The duration made the Liberhan Commission one of the longest-running inquiries in Indian institutional history and a byword for the deferral built into the commission system.

Q: What did the Liberhan Commission find?

The Commission found a planned demolition executed under political protection. Its paragraph 158.10 reasoned from the physical record: the small number of kar sevaks who performed the demolition, the veiling of their identities, the removal of the idols and cash box before the central dome fell, the tools and material at hand, and the makeshift temple raised the same night. From that record it concluded that the demolition was carried out with great painstaking preparation and planning, that the mobilisation was orchestrated, and that responsibility ran from the movement’s leadership to the state government that had tied the hands of every preventive authority.

Q: Who was named in the Liberhan report?

Sixty-eight persons were held culpable. The list included L. K. Advani, Murli Manohar Joshi, Uma Bharti, Kalraj Mishra, Vinay Katiyar and Atal Bihari Vajpayee of the Bharatiya Janata Party; Ashok Singhal and Giriraj Kishore of the Vishwa Hindu Parishad; leaders of the Rashtriya Swayamsevak Sangh; Sadhvi Rithambara; and Uttar Pradesh chief minister Kalyan Singh with officials of his administration. The report graded the responsibility it assigned: conspiracy and direction at the movement’s centre, facilitation in the state government, and, for Vajpayee, Advani and Joshi, the condemned hypocrisy of pseudo-moderates who had kept a public distance from a campaign they understood.

Q: Was anyone prosecuted for the Babri demolition?

Yes, though no prosecution succeeded. The Central Bureau of Investigation chargesheeted forty-nine persons in 1993 on charges that included criminal conspiracy, and the case ran through courts at Rae Bareli and Lucknow for twenty-seven years. The conspiracy charge against the senior leaders was dropped on a technical ground in 2001 and revived by the Supreme Court in April 2017, which clubbed the trial streams and ordered day-to-day hearings. Seventeen accused died during the proceedings. On 30 September 2020 the special court at Lucknow acquitted all thirty-two surviving accused, holding the demolition unplanned and the conspiracy unproved.

Q: When was the Liberhan report submitted?

Justice Liberhan submitted the report to Prime Minister Manmohan Singh on 30 June 2009, seventeen years after the Commission’s constitution and four years after its evidence phase had closed. The government laid the report before Parliament on 24 November 2009, a day after its contents had appeared in the press through a leak, together with the Action Taken Report recording the government’s response. The interval between submission and tabling, and the leak that ended it, became part of the report’s story: the audit reached the public through a newspaper before it reached the legislature through the channel the law prescribes.

Q: How many extensions did the Liberhan Commission receive?

The Commission received forty-eight extensions. Granted by notification under the Commissions of Inquiry Act 1952, each extension required no parliamentary vote and no public justification, and governments of every complexion issued them in turn: the Congress government that appointed the Commission, the United Front governments, the National Democratic Alliance governments of Atal Bihari Vajpayee, and the United Progressive Alliance government that finally received the report. The rhythm settled into a pattern reported for years by journalists covering the inquiry: the deadline approached, the Commission sought time, the Home Ministry extended, and the file closed again. The extension count is the audit trajectory’s most compact statistic.

Q: What was the Action Taken Report on the Liberhan report?

The Action Taken Report was the memorandum the Union government laid before Parliament with the report on 24 November 2009, as the Commissions of Inquiry Act 1952 requires. It recorded the government’s response to the Commission’s findings and recommendations in general terms: it noted the findings, observed that many recommendations touched matters already governed by existing law and machinery, and pointed to measures in force. It initiated no prosecution founded on the report, disciplined no official, announced no reform of the inquiry system and set no timetable for any of these. The debate that followed in December 2009 divided on party lines and bound nobody.

Q: When was the Liberhan report tabled in Parliament?

Home Minister P. Chidambaram tabled the report in Parliament on 24 November 2009, within the six-month period the Commissions of Inquiry Act allows the government after receiving a commission’s report. The tabling was overtaken by the leak of the report’s contents to the Indian Express, which published its conclusions on 23 November, so the winter session opened with opposition protests over the leak and the government’s denial that it had engineered it. Discussion of the report and the Action Taken Report followed in December 2009, repeatedly disrupted, and demands for a Hindi translation of the 1,029-page text added their own delay.

Q: What did the Liberhan report say about P. V. Narasimha Rao?

The report criticised the Union government headed by P. V. Narasimha Rao without placing Rao among the sixty-eight culpable. It treated the Centre’s conduct through 1992 as a failure of responsibility: the Rao government accepted the Uttar Pradesh government’s assurances of protection despite the record before it, declined to use its constitutional powers against a state government sliding toward a foreseeable crime, and remained passive while the demolition was prepared and executed. Critics of the report read Rao’s exclusion from the culpable list as leniency toward the government that had appointed the Commission; its defenders read the distinction as the line between directing an enterprise and failing to prevent one.

Q: How much did the Liberhan inquiry cost?

The inquiry cost roughly eight crore rupees across its seventeen years, a figure compiled from the government’s periodic statements of the Commission’s expenditure and reported at the report’s submission. The spending covered the chairman’s establishment, counsel, staff, sittings and the production of the 1,029-page report, and it accumulated precisely because the inquiry accumulated: each extension carried the Commission’s apparatus forward for another season. Critics of the Commission cited the eight crore total beside the three-month original mandate as the fiscal measure of deferral; the Commission’s defenders answered that the cost belonged to the governments that kept extending an inquiry they would not close.

Q: What did L. K. Advani say in response to the Liberhan report?

Advani answered on two registers. In Parliament on 23 November 2009, when the report’s contents reached the press before tabling, he took strong objection to the leak, accused the government of engineering it for political advantage, and repeated the description he had used since 1992, that the demolition was the saddest day of his life. On the findings themselves, he and the Bharatiya Janata Party rejected the report as a political document: they argued that the Commission had converted a failure of crowd control into a conspiracy by hindsight, that his appeals at Ayodhya had been genuine attempts at restraint, and that Atal Bihari Vajpayee’s inclusion exposed the exercise’s partisan design.

Q: What did Uma Bharti say about her role in the demolition?

Uma Bharti was the exception among the indicted: she accepted responsibility. Present at Ayodhya on 6 December 1992 and seated near the disputed structure as the domes fell, she told the Liberhan Commission that she took responsibility for the demolition, a statement Justice Liberhan recalled publicly after the criminal acquittal of 2020, remarking that she had taken responsibility categorically. Where other leaders answered the report with denials of design or claims of restraint, Bharti’s recorded position treated the demolition as an act she owned, and the Commission read that candour as evidence of the enterprise’s organised character: a spontaneous riot does not produce a leader who claims its outcome with pride.

Q: How many witnesses did the Liberhan Commission examine?

The Commission examined more than one hundred witnesses across its evidence phase, which ran from 1993 to August 2005. They included the movement’s senior leadership, L. K. Advani and Murli Manohar Joshi among them; Union and state ministers; the officials and police officers who had administered Ayodhya and Faizabad; journalists who had covered the day; and functionaries of the organisations involved. The last witness examined was Kalyan Singh, the former Uttar Pradesh chief minister, whose testimony was recorded in August 2005 only after years of non-appearance had consumed the Commission’s calendar, a delay the report’s critics cite whenever the seventeen years are defended as the evidence’s fault.

Q: What were the Liberhan Commission’s terms of reference?

The notification of 16 December 1992 directed the Commission to inquire into the sequence of events and all the facts and circumstances relating to the occurrences at the Ram Janmabhoomi Babri Masjid complex at Ayodhya on 6 December 1992, including the destruction of the mosque; into the role played in those events by the chief minister, the council of ministers, officials and other persons in Uttar Pradesh; into whether the destruction could have been prevented and the failures that allowed it; and into the measures to be taken to prevent the recurrence of such events. The terms fixed the inquiry’s character from the start: an audit of events, roles and failures, addressed to the government as recommendations.

Q: Why did the Liberhan inquiry take seventeen years?

The seventeen years had several authors. The Commission’s subject was vast and its witnesses included serving politicians and officials who delayed appearance for years; Kalyan Singh’s testimony closed the evidence only in 2005. The chairman carried the inquiry alongside a judicial career until his retirement from the Andhra Pradesh High Court. Above those frictions stood the structure of the Commissions of Inquiry Act: extension required only a government notification, no government of any party had an interest in forcing a conclusion against the leaders the inquiry examined or in closing an examination of its own failures, and four years of report writing followed the evidence. Delay, in the Liberhan case, was the system’s default setting rather than any single actor’s decision.

Q: Did the Supreme Court’s Ayodhya judgment rely on the Liberhan report?

No. The Constitution Bench judgment of 9 November 2019 in M. Siddiq v Mahant Suresh Das decided the title dispute from the Archaeological Survey’s excavation record, the evidence of worship and possession and the law of limitation, and it did not rest its reasoning on the Commission’s findings or adopt its assignments of culpability. The judgment spoke of the demolition in a different register, recording that the destruction of the mosque had been an egregious violation of the rule of law, while deciding a property question. The Commission had answered who was responsible; the Court answered whose the land was; the state’s two fullest treatments of Ayodhya proceed in parallel without either depending on the other.

Q: What happened to the appeal against the 2020 acquittal in the demolition case?

Two Ayodhya residents, Haji Mahboob Ahmad and Syed Akhlaq Ahmed, carried the challenge to the September 2020 acquittal, first as a revision and then as a criminal appeal before the Allahabad High Court. On 9 November 2022 a division bench dismissed the appeal on maintainability, holding that the appellants could not be treated as victims of the demolition with the standing the law requires to appeal an acquittal. The Central Bureau of Investigation did not itself appeal the special court’s judgment. With that dismissal the criminal proceedings arising from 6 December 1992 closed, twenty-nine years after the first chargesheet, without a conviction against any of the forty-nine persons originally accused.

Q: What is the difference between the Liberhan Commission and the Srikrishna Commission?

Both were commissions of inquiry into the communal violence of the same winter, appointed weeks apart, and their trajectories rhyme. The Liberhan Commission, appointed on 16 December 1992, audited a single event, the demolition of the Babri Masjid, and the failures of the governments around it. The Srikrishna Commission, headed by Justice B. N. Srikrishna and appointed in January 1993, examined the Mumbai riots of December 1992 and January 1993 and the bomb blasts that followed, naming politicians and police officers in its 1998 report. Srikrishna reported in five years; Liberhan took seventeen. Both reports met governmental responses that accepted their language and withheld their consequences, which is why the two are read together as evidence about the commission instrument itself.