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The Red Fort Trials

The Red Fort Trials | Indian National Army / INA Trials, 1945–46 | UPSC Modern Indian History — Study Notes


The Red Fort Trials
The Red Fort | Delhi

The Indian National Army (INA) Trials, popularly called the Red Fort Trials, were court-martial proceedings conducted by the British Indian government against officers of the INA (Azad Hind Fauj) between November 1945 and May 1946. The accused were charged with treason, murder, torture and abetment to murder, arising from their role in the Indian National Army led by Subhas Chandra Bose, which had fought alongside Japan against the British during World War II.


The trials were held in the Red Fort, Delhi, the same site where the British had tried the last Mughal emperor, Bahadur Shah Zafar, after the Revolt of 1857 — deliberately chosen to send a message about imperial authority. Instead, the trials backfired: they triggered nationwide sympathy, mass protests, and are widely regarded by historians as one of the key factors that accelerated the British decision to leave India.


Quick Facts

Details

November 1945 – May 1946

Venue

Red Fort (Lal Qila), Delhi

Also known as

INA Trials

First & most famous trial

Joint court-martial of Col. Prem Kumar Sahgal, Col. Gurbaksh Singh Dhillon, Maj. Gen. Shah Nawaz Khan (5 Nov 1945)

Charges

Waging war against the King-Emperor (treason, IPC Sec. 121); murder/abetment to murder of INA soldiers

Total courts-martial

About 10, held between late 1945 and 1946

Prosecution counsel

Sir Naushirwan P. Engineer (Advocate General of India)

Key defence counsel

Bhulabhai Desai, Jawaharlal Nehru, Asaf Ali, Tej Bahadur Sapru, Kailash Nath Katju

Verdict (1st trial)

Found guilty; sentenced to transportation for life, but sentence remitted — all three released, 3 Jan 1946





Background: The INA and Its Surrender


The Indian National Army was reorganised and led by Netaji Subhas Chandra Bose from 1943 under the Provisional Government of Free India (Azad Hind), with Japanese backing. It was composed largely of Indian prisoners of war from the British Indian Army captured in Malaya, Singapore and Burma, along with Indian civilians in Southeast Asia. The INA fought alongside Japanese forces in the Imphal and Burma campaigns (1944–45).
With Japan's defeat in 1945, the INA collapsed and thousands of its officers and men were taken prisoner by the British. The colonial government decided to prosecute several INA officers by court-martial for offences under the Indian Army Act and the Indian Penal Code, choosing to make the first trial a very public one.

The First and Most Famous Trial (Nov 1945 – Jan 1946)


The three principal accused — Shah Nawaz Khan, Prem Sahgal and Gurbaksh Singh Dhillon
The three principal accused — Shah Nawaz Khan, Prem Sahgal and Gurbaksh Singh Dhillon

The opening and most celebrated court-martial began on 5 November 1945 at the Red Fort. The three accused — Major General Shah Nawaz Khan, Colonel Prem Kumar Sahgal and Colonel Gurbaksh Singh Dhillon — deliberately represented India's three major communities (Muslim, Hindu and Sikh respectively), which became a powerful symbol of communal unity during the trial.
  • Shah Nawaz Khan and Sahgal: charged with waging war against the King-Emperor and abetment to murder.
  • Dhillon: additionally charged with murder (of INA men accused of desertion/mutiny).
  • All three were officers of the British Indian Army who had joined the INA after capture and risen to senior commands.
The three were convicted and sentenced to transportation for life. However, in the face of massive public pressure, the Commander-in-Chief, General Claude Auchinleck, remitted the sentences, and all three were released on 3 January 1946.

Legal Defence and the INA Defence Committee


The Indian National Congress made the release of the INA officers a major political cause during the 1945–46 agitation. The Congress set up the INA Defence Committee, which engaged some of the country's most eminent lawyers pro bono, including Bhulabhai Desai, Jawaharlal Nehru (who wore his barrister's gown for the first time in over two decades), Asaf Ali, Tej Bahadur Sapru and Kailash Nath Katju. The Muslim League also extended support.

Nehru with Tej Bahadur Sapru and Kailash Nath Katju during the trial
Nehru with Tej Bahadur Sapru and Kailash Nath Katju during the trial

Desai's defence argument, that soldiers of the INA, having sworn allegiance to a de facto Provisional Government of Free India, could not be tried for treason against the King — is often cited as one of the most eloquent legal arguments made during the freedom struggle, even though it was not accepted by the court.

Public Reaction and Significance


News of the trial and its charges of treason against soldiers popularly seen as patriots triggered an unprecedented wave of sympathy and unrest across India:
  • Mass demonstrations, hartals and processions broke out in cities including Calcutta, Bombay and Delhi in support of the accused.
  • Police firing on protestors in Calcutta (Nov 1945) killed a number of demonstrators, intensifying anger against British rule.
  • The INA cause cut across communal and political lines — Congress, the Muslim League and other groups all backed the accused, reviving a sense of national unity in the final phase of the freedom movement.
  • Historians (and even Prime Minister Clement Attlee, in later remarks) suggested that the INA trials — more than civil disobedience alone — shook British confidence in the loyalty of the Indian Army and hastened the decision to quit India.
  • The atmosphere of unrest generated by the trials is also linked to the Royal Indian Navy (RIN) Mutiny of February 1946, in which naval ratings in Bombay revolted, partly inspired by the INA episode.
 
 Subsequent Trials

After the first trial, around nine more courts-martial followed through 1946, including that of Abdul Rashid, Shingara Singh, Fateh Khan and Captain Malik Munawar Khan Awan — for some of which the venue was shifted from the Red Fort itself to an adjoining building, though they continued to be referred to collectively as the Red Fort/INA trials. Continuing public pressure led the government to progressively scale back prosecutions, and further trials were eventually halted.

Key Points for UPSC


Prelims pointers
  • Red Fort Trials = INA Trials; held Nov 1945 – May 1946.
  • First trial's three accused: Shah Nawaz Khan, Prem Sahgal, Gurbaksh Singh Dhillon (Muslim–Hindu–Sikh symbolism).
  • Charge: Section 121 IPC — waging war against the King-Emperor; also murder/abetment to murder.
  • Key defence lawyer: Bhulabhai Desai; Nehru also appeared for the defence.
  • Venue significance: Red Fort was earlier the site of Bahadur Shah Zafar's 1858 trial.
  • Linked event: Royal Indian Navy Mutiny, February 1946.
  • Mains angle
  • Role of the INA trials in reviving mass nationalism and communal unity in 1945–46.
  • The trials as a factor (alongside RIN Mutiny, economic exhaustion of Britain, Labour government's stance) in Britain's decision to grant independence.
  • Contrast between Gandhian mass movements and the INA's armed-struggle legacy, and how both strands fed into the endgame of colonial rule.

 
Practice Questions
Prelims-style
Q1. The Red Fort Trials of 1945–46 were associated with which of the following?
(a) Quit India Movement leaders
(b) Officers of the Indian National Army
(c) Members of the Royal Indian Navy
(d) Revolutionaries of the Ghadar Party
Answer: (b)
Q2. Which of the following pairs (accused – community represented) is correctly matched in the first INA trial?
(a) Shah Nawaz Khan – Sikh
(b) Gurbaksh Singh Dhillon – Muslim
(c) Prem Sahgal – Hindu
(d) None of the above
Answer: (c)

Mains-style
Q3. "The INA Trials of 1945–46 did more to unite India against British rule than years of civil disobedience." Critically examine this statement.
Q4. Discuss the significance of the Red Fort Trials in the context of the final phase of India's freedom struggle.

| Pavan | Indus Student


Sources / Further Reading
Wikipedia — Indian National Army trials | Association for Asian Studies — "Trial at the Red Fort, 1945–46" | INSIGHTS IAS / NextIAS / Vajiram & Ravi. Modern History notes on the INA Trials | The Better India — "How a Gujarat Lawyer Defended the INA"

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