Union Minister’s murder case remains unresolved even after 50 years — a stain on India’s justice system 

Fifty-one years after Railway Minister LN Mishra’s assassination, justice remains elusive amid unanswered questions and prolonged litigation

By KSN Prasad

India’s justice system moves so slowly, it could teach a snail how to walk. The cases dragging on for decades are proof. If there is any creature on earth slower than a snail, our judiciary could give it lessons — or compete with it. The LN Mishra murder case is a stark example.

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Fifty-one years ago, a Union Minister of India was killed in a bomb attack. More than half a century later, the case is still pending in a higher court. This was the first murder of a Union Minister after 23 years of independent, representative government in India. In other words, it was the second major political assassination in the country after Mahatma Gandhi’s murder. It is also the first murder case in the history of Indian courts to remain under litigation for such a long time. The victim in this bomb-attack case was Railway Minister Lalit Narayan Mishra, known as LN Mishra.

When the murder occurred, Indira Gandhi was the Prime Minister and Kasu Brahmananda Reddy was the Union Home Minister. The incident took place on January 2, 1975, at Samastipur Railway Station in Bihar. That day, LN Mishra had gone there to inaugurate a broad-gauge railway line. While the event was underway, assailants hurled grenades at the dais. In the blast, Mishra was grievously injured while MLC Suryanarayana and railway employee Ram Kishore Prasad died on the spot.

Mishra, his brother Jagannath Mishra — who later became Bihar Chief Minister — and 25 others were injured. The Railway Minister was shifted to Danapur for better treatment. He died the next day, January 3, while undergoing treatment. This is how it came to be known as the LN Mishra murder case.

The CBI took up the investigation. It arrested four followers of Anand Marg and a lawyer, Ranjan Dwivedi, as responsible for the attack. Soon after, the Centre banned Anand Marg for nearly two years. On November 1, 1977, the CBI filed a chargesheet in Patna naming these five as accused. In 1979, the case was transferred to Delhi. The Delhi trial court delivered its verdict in December 2014 — a full 39 years after the incident. That, in itself, is a record in the history of Indian courts. If it takes so many years for a judgment in a Union Minister’s murder case, one can imagine the plight of cases involving ordinary citizens.

According to the CBI chargesheet, Anand Marg’s leader, Prabhat Ranjan Sarkar, was in jail in a murder case. To pressure the Indira Gandhi government into releasing him, the group decided to act. As part of that plan, six followers met in 1973 in Bhagalpur district, Bihar, and plotted the attack. Four of them reached Samastipur Railway Station on January 2, 1975, and hurled grenades at  Mishra during the inauguration.

The trial court heard the case for 39 years. More than 20 judges changed during this period. A total of 200 witnesses were examined — 160 for the prosecution and 40 for the accused. Examining so many witnesses in a murder case is itself a record in the country. On December 18, 2014, the Delhi trial court pronounced judgment. One of the accused died during the trial. The court sentenced three Anand Marg followers — Santoshanand Avadhuta, Sudevanand Avadhuta, Gopalji — and lawyer Ranjan Dwivedi to life imprisonment and fines. It also directed the Bihar government to pay Rs 5 lakh each to the heirs of three victims of the grenade attack.

But the case did not end there. The convicts filed an appeal in the Delhi High Court in 2015. Meanwhile, Mishra’s family, led by his grandson and advocate Vaibhav Mishra, has been pursuing the case for years. He does not claim the convicted men are innocent. But he argues that the CBI investigated the case negligently and perfunctorily, letting the real culprits go. He maintains that the actual masterminds behind Mishra’s murder are different and has long demanded a reinvestigation.

To that end, while the convicts’ 2015 appeal was pending, Vaibhav Mishra filed a Criminal Miscellaneous Application in the same court. This facility exists specifically in the Delhi High Court. Through it, he sought permission to intervene in the case. He did not claim the convicted men were innocent, but demanded that the case be reinvestigated from the beginning to identify the real conspirators behind the 1975 bomb attack. He based his plea on the 1978 Bihar Police report, the 1979 Tarkunde Commission report, and statements given by three suspects — initially arrested by the CBI — before the Samastipur Magistrate. He noted that murder charges against two of those suspects were later withdrawn.

During the final hearing of the convicts’ appeal, the High Court permitted Vaibhav Mishra in March 2022 to assist the CBI. But in 2023, the same court rejected his demand for a proper investigation or reinvestigation. He then filed a Special Leave Petition in the Supreme Court. Shortly afterwards, he sought permission to withdraw it. The Supreme Court allowed the withdrawal and directed Vaibhav to assist the Division Bench of the Delhi High Court during the final hearing of the convicts’ appeal.

Following that, he filed an application in the Delhi High Court. It was listed along with the main appeal on April 7, 2024, and adjourned to May 16. In September, a bench of Justice Pratibha Singh and Justice Madhu Jain made it clear that no further adjournments would be granted in this case. In March 2025, the CBI stated it would not agree to a reinvestigation. The respondents, the late Mishra’s family members, objected to the CBI’s stand. The court posted the matter to May 18, 2026, to hear arguments from the respondents on the CBI report. Though that date has passed, it is still not known whether reinvestigation was permitted or the case was closed. Full details will be clear only after the High Court bench delivers its judgment or issues the next listing.

Among the accused, all except Gopalji were also named by Vaibhav as accused in the March 20, 1975, assassination attempt on then Chief Justice of India, A.N. Ray. Meanwhile, the Morarji Desai government, which did not trust the Justice KK Mathew Commission appointed by Indira Gandhi to probe Mishra’s murder, dissolved it and set up the Justice VM Tarkunde Commission in 1977. Tarkunde submitted his report on February 15, 1979. Vaibhav argues that the report found a deep political conspiracy behind the murder and contained not only the names of Anand Marg members but also of senior political leaders. Yet, except for one name, the prominent names were never disclosed in court.

Justice Mathew’s Commission, however, accepted the CBI’s argument that there was no other plausible alternative to explain the murder. In August 1978, then Chief Minister Karpoori Thakur directed the Bihar Police CID to submit a report on the incident. The CID submitted its report in October. It was prepared by then Bihar DIG Shashibhushan Sahay. Vaibhav alleges that the CBI neither considered nor examined this report.

He further claims that the CBI first arrested Arun Kumar Thakur, Arun Kumar Mishra, Uma Kant, and Shiva Lal Sharma. They gave statements before the Samastipur Magistrate. In November 1975, murder charges against Arun Kumar Thakur and Arun Kumar Mishra were withdrawn. Vaibhav alleges that statements recorded from the suspects under Section 164 CrPC were set aside, and the case was diverted toward others.

He told The Indian Express in March 2026 that political leaders were involved in this murder, and their names were revealed in the statements. While the suspects initially arrested indicated involvement of top political leaders, the CBI shielded them and pinned the entire blame on Anand Marg, Mishra’s family alleges.

Senior journalist Arun Shourie wrote a book in 1979 titled Who Murdered L.N. Mishra, Indian Express Reports. It came out after the Emergency. Vaibhav and other family members rely heavily on Shourie’s account in their arguments. Shourie wrote that the 1979 Justice Tarkunde report named former MLC Ram Bilas Jha and suggested a major political conspiracy.

He also wrote that the Bihar Police CID report said the CBI was blaming Anand Marg to protect those close to the power centre in Delhi. In a Lok Sabha debate on March 26, 1975, then Home Minister Kasu Brahmananda Reddy confirmed the arrest of the four suspects and their statements, but murder charges against the two Aruns were dropped in November 1975, Shourie revealed in his book.

“The CBI deliberately abandoned the investigation into LN Mishra’s murder case; in other words, it willfully destroyed the investigation,” Tarkunde stated in his report to the Bihar government. “As soon as evidence began to emerge that the conspiracy was hatched by Bihar MLC Ram Bilas Jha, possibly with the involvement of then Prime Minister Indira Gandhi, the CBI stopped work in March 1975, just two months after the murder,” Justice Tarkunde wrote. This portion was published on the front page of The Indian Express on March 27, 1979. Yashpal Kapoor was Prime Minister Indira Gandhi’s secretary and a powerful figure in the Congress. Bihar MLC Ram Bilas Jha was close to him.

BJP leader Ashwini Choubey has joined Vaibhav in this effort. Choubey also signed the miscellaneous application filed by Vaibhav. Their legal battle rests on three documents: the secret Bihar CID report, the Tarkunde Commission report, and the statements of the arrested suspects. In a plea filed in the Delhi High Court, Choubey attached as an annexure a note that Vaibhav had sent to Prime Minister Narendra Modi and Union Home Minister Amit Shah.

At present, the Mishra murder case has been continuing up to May 18 this year. What happened after that is still not known. In the history of the Indian judiciary, this is the longest-running criminal case — more than half a century. Although more witnesses were examined in the 26/11 Mumbai terror attack trial of Kasab, the verdict took nine years. The murder cases of US Presidents Abraham Lincoln and John F Kennedy were decided within months. Globally, the Mishra murder case may well be the longest-running criminal case.