24.5 INA Trials (Shah Nawaz Khan, Prem Kumar Sahgal, Gurbaksh Singh Dhillon) and Impact of Trials on the Armed Forces
Indian History β Indian History β Modern History β Modern History β Subhas Chandra Bose and the Indian National Army (INA) | Author: admin | Aug 15, 2026
1. Context & Foundation
The conclusion of the Second World War in August 1945 brought a dramatic shift in the dynamics of the Indian national movement. Following the unconditional surrender of Japan after the atomic bombings of Hiroshima and Nagasaki, the Indian National Army (INA) or Azad Hind Fauj was forced to lay down its arms along the East Asian fronts. The colonial state immediately launched a massive repatriation and screening operation, apprehending approximately 23,000 INA soldiers and bringing them back to the Indian mainland as Prisoners of War (POWs).
The British military administration decided to adopt a policy of selective prosecution, intending to court-martial senior INA officers on severe charges of treason, "waging war against the King-Emperor," torture, and murder. To showcase imperial authority, the British chose Delhiβs historic Red Fort as the venue for the first public trials in November 1945.
However, this decision proved to be a major strategic miscalculation by the Raj. The first three senior officers selected for the joint trial represented the diverse, secular fabric of the subcontinent:
- Major General Shah Nawaz Khan (a Muslim)
- Colonel Prem Kumar Sahgal (a Hindu)
- Colonel Gurbaksh Singh Dhillon (a Sikh)
The joint trial of these three officers from different religious backgrounds instantly captured the imagination of the Indian public. Rather than viewing them as "traitors to the Crown," the Indian masses embraced them as patriotic heroes who had taken up arms to secure the absolute liberation of the motherland. The trials sparked an unprecedented wave of public sympathy, cutting across communal, regional, and political barriers.
This powerful upsurge soon spread directly to the colonial stateβs ultimate bulwark of power: the British Indian Armed Forces. In February 1946, Indian ratings of the Royal Indian Navy (RIN) in Bombay launched a historic mutiny, directly inspired by the INA trials. The combination of the mass agitations on the streets and the open rebellion within the armed forces broke the military and administrative backbone of the British Empire, making the continuation of colonial rule structurally untenable and forcing the final transfer of power.
2. Detailed Study Notes
Big Picture Overview
The post-war national upsurge (1945β1946) can be systematically categorized into three major phases:
- The Red Fort Trials & Legal Defence (November 1945 β May 1946)
- Main emphasis: The public court-martial of the three senior INA officers and the high-profile legal defense organized by the Indian National Congress.
- Key Outcome: The INA Defence Committee successfully used the courtroom as a political platform, forcing the military command to commute the death sentences.
- The Mass Agitations & Joint Solidarity (Winter of 1945β1946)
- Main emphasis: Nationwide public demonstrations, strikes, and fund-raising campaigns in support of the INA prisoners, uniting diverse political groups.
- Key Outcome: Complete collapse of communal divisions as Congress, the Muslim League, Akalis, and the CPI jointly supported the INA cause.
- The Royal Indian Navy (RIN) Mutiny (February 1946)
- Main emphasis: The armed rebellion of Indian naval ratings starting at HMIS Talwar in Bombay, protesting against racial discrimination and the INA trials.
- Key Outcome: Exposed the final erosion of military loyalty to the British Crown, forcing the British Cabinet to dispatch the Cabinet Mission of 1946.
Major Topic: The Red Fort Trials and the INA Defence Committee
The joint trial of Shah Nawaz Khan, Prem Kumar Sahgal, and Gurbaksh Singh Dhillon began at the Red Fort in November 1945:
1. The Accused Officers
- Major General Shah Nawaz Khan: Commanded the elite INA battalion during the Imphal-Kohima campaign.
- Colonel Prem Kumar Sahgal: A senior commander and trusted colleague of Netaji.
- Colonel Gurbaksh Singh Dhillon: A prominent field officer of the Azad Hind Fauj.
2. The Legal Defence Team
To defend the accused officers, the Indian National Congress established the historic INA Defence Committee (1945). The committee assembled some of the most brilliant legal minds of the country to represent the prisoners in court:
- Bhulabhai Desai: Served as the leading counsel for the defense, delivering a masterly, weeks-long closing argument.
- Tej Bahadur Sapru: A veteran moderate liberal and eminent jurist who returned to active legal defense despite failing health.
- Jawaharlal Nehru: Donned his barrister's robes after a gap of nearly thirty years to sit on the defense bench.
- Asaf Ali: A highly distinguished nationalist lawyer and freedom fighter.
- Kailash Nath Katju: A prominent legal scholar and defense advocate.
- The Defence Strategy: Bhulabhai Desai brilliantly argued that the actions of the INA soldiers were governed by the Sovereign INA Act passed by a formally constituted, internationally recognized government-in-exile (the Provisional Government of Azad Hind). Therefore, they operated as combatants of a sovereign belligerent state-in-arms, rendering them not liable under the municipal Indian Penal Code (IPC) or the British Indian Army Act.
3. Public Mobilization and Commutation
- INA Day & Week: November 12, 1945, was celebrated as "INA Day," followed by the celebration of "INA Week," which featured massive public rallies, student strikes, and closed shops across the country.
- Broad-Based Fund Raising: Funds for the relief and rehabilitation of captured INA personnel were contributed liberally by diverse groups, including film stars, municipal committees, Gurudwara committees, and Indian diasporic groups.
- The Verdict: The military court-martial found the three officers guilty of waging war against the King-Emperor and sentenced them to transportation for life (death sentences).
- The Commutation: Fearing a massive, uncontrollable national revolt, the Commander-in-Chief of the British Indian Army, General Sir Claude Auchinleck, utilized his extraordinary military powers to commute and remit the life sentences, confirming only the lesser penalties of cashiering and forfeiture of arrears of pay and allowances. The three officers were subsequently set free, marking a historic victory for the nationalist forces.
Major Topic: The Royal Indian Navy (RIN) Mutiny (February 1946)
The politicization and patriotic awakening generated by the INA trials culminated in the historic Ratings Mutiny of February 1946, which was also known as the "Last War of Indian Independence":
[ INA RED FORT TRIALS (1945) ]
Eroded Military Loyalty
β
βΌ (Trigger Point)
[ HMIS TALWAR, BOMBAY (FEB 18, 1946) ]
β’ Striking over bad food & racism
β’ B.C. Dutt writes "Quit India" on hull
β
βΌ (Expansion Phase)
[ NATIONWIDE NAVAL SURGE ]
β’ 20,000 Ratings, 78 Ships, 20 Shore Bases
β’ Spread to Karachi (HMIS Hindustan) & Calcutta
β’ Hoisting of Congress, League, & CPI flags together
β
βΌ (The Surrender)
[ MEDIATION BY SARDAR PATEL ]
Surrender on Feb 23, 1946 under assurance
of no political victimization.
1. The Trigger at HMIS Talwar
- On February 18, 1946, nearly 1,100 non-commissioned ratings (naval sailors recruited from diverse, non-martial classes) on the training ship HMIS Talwar in Bombay went on strike.
- Key Grievances: Protested against unpalatable food (the slogan was "No Food, No Work"), harsh working conditions, and the extreme racial discrimination and abuse hurled by their senior British officer, Commander Arthur Frederick King.
- The Nationalist Spark: The immediate trigger was the arrest of rating B.C. Dutt, who had defiantly scrawled the words "Quit India" on the hull of HMIS Talwar.
2. The Rapid Expansion
- The strike quickly escalated into a full-scale mutiny under the leadership of the Naval Central Strike Committee (NCSC), headed by M.S. Khan and Madan Singh.
- The Scale of Rebellion: The mutiny spread to 78 ships, 20 shore establishments, and over 20,000 ratings across Karachi (where the training ship HMIS Hindustan mutinied after a fierce gun-battle with British forces), Calcutta, Madras, and Visakhapatnam.
- Symbolic Unity: The mutinying ratings hauled down the Union Jack and hoisted three flags tied together on the ship masts: the tricolour of the Indian National Congress, the green flag of the Muslim League, and the Red Flag of the Communist Party of India (CPI), showcasing absolute communal and political unity.
3. Mass Support and General Strikes
- The mutiny enjoyed immense public sympathy. The working class of Bombay went on a massive sympathetic strike, paralyzing the city's transport and industrial establishments.
- The Royal Indian Air Force (RIAF) units in Bombay and Poona, along with Army signal corps in Jabalpur, went on strike in solidarity, demonstrating that the nationalist spirit had penetrated every wing of the military.
4. The Surrender (February 23, 1946)
- The senior leadership of the Congress and the Muslim League (including Mahatma Gandhi) opposed the violent, uncoordinated nature of the mutiny, fearing it would lead to anarchy on the eve of independence.
- Sardar Vallabhbhai Patel traveled to Bombay to mediate. He, along with Muhammad Ali Jinnah, persuaded the Naval Strike Committee to surrender on February 23, 1946.
- The NCSC Declaration: In their final message, the ratings declared: "We are surrendering to India, and not to Britain." Despite Patel's assurances against victimization, over 475 ratings were subsequently dismissed and court-martialed by the British administration.
Do Not Confuse
SPSC and state-level civil service examinations consistently test the legal and political details of the historic conspiracy and court-martial cases of the national movement. Study this comparative grid to keep your facts clear:
Famous Trials of the Nationalist Period
| Feature | The Alipore Conspiracy Case (1908) | The Meerut Conspiracy Case (1929) | The Red Fort INA Trials (1945β1946) |
|---|---|---|---|
| Historical Catalyst | Bomb thrown at Magistrate Kingsford in Muzaffarpur by Khudiram Bose and Prafulla Chaki. | Growing influence of socialist, communist, and trade union strikes during the Great Depression. | Capture of Azad Hind Fauj soldiers after the surrender of Japan in World War II. |
| Key Accused | Aurobindo Ghosh and his brother Barindra Kumar Ghosh. | 31 Communist & Trade Union Leaders (including S.A. Dange, Muzaffar Ahmed, Philip Spratt). | Shah Nawaz Khan, Prem Kumar Sahgal, Gurbaksh Singh Dhillon. |
| Primary Charges | Conspiracy to manufacture illegal bombs and wage war against the King. | Sedition and conspiring to establish a branch of the Comintern to overthrow the King's sovereignty. | Waging war against the King-Emperor by murder and abetment of murder. |
| Lead Defense Counsel | Chittaranjan Das (Deshbandhu), who successfully got Aurobindo Ghosh acquitted. | Jawaharlal Nehru and M.A. Ansari, who defended the accused communists. | Bhulabhai Desai (leading counsel), Tej Bahadur Sapru, Nehru, and Asaf Ali. |
| Operational Venue | Alipore Court, Calcutta (Bengal Presidency). | Meerut Sessions Court (United Provinces). | Red Fort, New Delhi (Imperial Capital). |
Core Difference: The Alipore Case (1908) was a trial of early revolutionary nationalists in Bengal, the Meerut Case (1929) was a British crackdown to curb the spread of communism among industrial workers, and the Red Fort Trials (1945) were a post-war military court-martial of INA officers that provoked a nationwide, cross-communal armed forces upsurge.
MCQ Traps
- The "Patel defended INA in Court" Trap: SPSC papers frequently list Sardar Vallabhbhai Patel as one of the defense lawyers who appeared in the Red Fort trials. This is false. Patel was not a defense lawyer in court. The defense team consisted of Bhulabhai Desai, Tej Bahadur Sapru, Jawaharlal Nehru, K.N. Katju, and Asaf Ali. Patel operated on the political and organizational front of the INA Defence Committee to arrange relief and rehabilitation funds.
- The "League Opposed INA Trials" Fact: Distractors in multiple-choice questions often state that the Muslim League boycotted the INA agitations because Shah Nawaz Khan was a Muslim. This is false. The Muslim League actively supported the countrywide protest against the INA trials and joined the Congress in demanding the release of the three officers.
- The "All Armed Forces supported the Mutineers" Fallacy: Watch out for options claiming that the Congress and the Muslim League officially backed the RIN Mutiny in February 1946. This is false. Both the Congress and the Muslim League officially opposed the mutiny, advising the ratings to surrender. Only the Communist Party of India (CPI) officially supported the strike.
- The "First INA Trial Date" Trap: SPSC questions often confuse the dates of the INA trials with the Quit India Movement. Remember: the Red Fort INA Trials began in November 1945, following the end of the war, not during the QIM of 1942.
Telangana / Hyderabad State Connection
The historic developments of the Red Fort trials and the Royal Indian Navy mutiny had a direct, revolutionary impact on Hyderabad State and the Telangana districts under Nizam VII, Mir Osman Ali Khan:
- The Deccan Pro-INA Surge: SPSC and TSPSC aspirants must note the regional spillover. When the Red Fort trials of Shah Nawaz, Sahgal, and Dhillon began in late 1945, it provoked massive, united public protest rallies in Hyderabad, Secunderabad, and Warangal. Local student organizations, cutting across communal lines, organized protest strikes, raised black flags, and collected funds for the INA Defence Committee, defying the Nizam's state police and the Hyderabad public security regulations.
- Erosion of Nizam's Military Control: The Royal Indian Navy Mutiny of February 1946 and the subsequent strikes in the Royal Indian Air Force deeply affected the loyalty of the native troops of the Nizamβs Army. Deccani and Telugu-speaking soldiers stationed in Secunderabad Cantonment expressed open sympathy toward the mutineers, refusing to participate in any military patrol designed to suppress local anti-British demonstrations, which severely weakened the Nizam's military and police machinery.
- The Psychological Fuel for the Telangana Armed Struggle (1946β1951): The spectacle of Indian soldiers openly defying British officers and the ultimate victory of the legal defense team in securing the release of the INA officers permanently shattered the traditional "aura of authority" enjoyed by the British Raj and the Nizam's feudal administration in the Deccan. This revolutionary awakening, combined with the extreme economic misery of the wartime grain levy system, convinced the local cadres of the Andhra Maha Sabha (AMS) and the Communist Party of India (CPI) that the autocratic-feudal regime of the Nizam was on the verge of collapse, laying the direct psychological and tactical foundation for the launch of the historic Telangana Peasant Armed Struggle (1946β1951).
3. Quick Revision Cheat Sheet
- August 15, 1945: Japan surrenders; collapse and apprehension of 23,000 INA soldiers.
- November 1945: The public INA Trials begin at the Red Fort, New Delhi.
- The Accused: Major General Shah Nawaz Khan, Colonel Prem Kumar Sahgal, and Colonel Gurbaksh Singh Dhillon.
- INA Defence Committee: Established by Congress in 1945 to provide legal defense and relief.
- The Defense Team: Led by Bhulabhai Desai, alongside Tej Bahadur Sapru, Jawaharlal Nehru, K.N. Katju, and Asaf Ali.
- November 12, 1945: Celebrated nationwide as "INA Day"; November 5 to 11 was observed as "INA Week."
- General Sir Claude Auchinleck: Commander-in-Chief who commuted the death sentences to cashiering and forfeiture of pay.
- February 18, 1946: The Royal Indian Navy (RIN) Mutiny begins at the training ship HMIS Talwar in Bombay.
- B.C. Dutt: The naval rating whose arrest for scrawling "Quit India" on the hull of HMIS Talwar triggered the mutiny.
- M.S. Khan: President of the Naval Central Strike Committee (NCSC) that led the mutiny.
- Scale of Mutiny: Involved 20,000 ratings, 78 ships, and 20 shore establishments across Bombay, Karachi (HMIS Hindustan), and Calcutta.
- The Flags: Congress Tricolour, Muslim League Green Flag, and CPI Red Flag hoisted together on mutinying ships.
- February 23, 1946: Ratings surrender following the mediation of Sardar Vallabhbhai Patel and Jinnah.
- March 1946: British Prime Minister Clement Attlee dispatches the high-powered Cabinet Mission to India to negotiate a peaceful transfer of power.
4. Exam Strategy & PYQ Focus
High-Yield Focus Areas
VERY HIGH PRIORITY
- The Three Red Fort Officers: Memorize their names: Shah Nawaz Khan, Prem Kumar Sahgal, and Gurbaksh Singh Dhillon. State civil service exams consistently ask match-the-following or odd-one-out questions regarding their identities.
- The Defense Lawyers Team: Ensure you memorize that Bhulabhai Desai was the lead counsel, and Sardar Patel was not a defense lawyer in court. This is a highly repeated SPSC trick question.
- The HMIS Talwar and B.C. Dutt: Always pair the training ship HMIS Talwar with B.C. Dutt and his act of scrawling "Quit India" to solve statement-based options.
HIGH PRIORITY
- The Commutation Authority: Note that the sentences were commuted by the Commander-in-Chief, General Sir Claude Auchinleck, and not by Viceroy Lord Wavell, under extreme political pressure.
- The Three Flags of the Mutiny: SPSC papers often ask which three flags were hoisted together on the mutinying ships. They were the Congress Tricolour, the Muslim League Green Flag, and the CPI Red Flag.
- The RIN Mutiny Dates: Memorize the exact date the mutiny began (February 18, 1946) and the date of surrender (February 23, 1946).
MODERATE PRIORITY
- The HMIS Hindustan Conflict: Note that the armed conflict of the ratings in Karachi occurred on the ship HMIS Hindustan, which surrendered after a gun-battle with British military units.
What to Skip / Low-Yield
- Microscopic, page-by-page court transcripts of the day-to-day cross-examinations of minor witnesses during the Red Fort trials.
- Detailed mechanical blueprints or specifications of the boilers and engine parts of HMIS Talwar.
How to Study This Topic
- Construct a "Red Fort & RIN Mutiny Timeline": On a single study card, draw a linear flowchart tracing: \[\text{Red Fort Trials begin (Nov 1945)} \rightarrow \text{Auchinleck Commutes Sentences (Jan 1946)} \rightarrow \text{Talwar Strike (Feb 18, 1946)} \rightarrow \text{Karachi Mutiny (Feb 19)} \rightarrow \text{Patel-NCSC Surrender (Feb 23, 1946)} \rightarrow \text{Cabinet Mission Arrives (Mar 24, 1946)}\] This chronological flowchart is highly effective for sequencing questions.
- Tabulate the Defense Team and the Accused: Create a simple 2-column table listing the three tried officers on one side and the five defense barristers on the other to eliminate multiple-choice options effortlessly.
5. Chronology & Broader Context (Past β Present β Future)
Pre-context
Prior to the outbreak of the trials in November 1945, the national movement had successfully concluded its most intense mass phaseβthe Quit India Movement of August 1942. While the brutal imperial suppression of the QIM had left the mainstream Congress organization temporarily paralyzed, the dramatic military campaigns of Netaji Subhas Chandra Bose and the Azad Hind Fauj in Southeast Asia had secretly kept the spirit of militant nationalism alive among the Indian public. The return and capture of the INA soldiers in late 1945 provided the perfect catalyst to reactivate mass agitations and merge the underground resistance with mainstream constitutional demands.
Concurrent Events
- The Post-War General Elections in India (Winter of 1945β1946): Occurring simultaneously, the elections saw the Congress secure a sweeping majority in general provincial seats, while the Muslim League captured all reserved Muslim seats, solidifying the communal polarization on the eve of the trials.
- The Nuremberg Trials in Germany (1945β1946): Raging concurrently in Europe, the international war crime trials conducted by the Allied powers against the captured Nazi leadership heavily influenced the legal and diplomatic vocabulary utilized by Bhulabhai Desai during his defense of the INA officers at the Red Fort.
Post-context
The immediate consequence of the INA trials and the subsequent Royal Indian Navy mutiny was a total breakdown of British military confidence in India, forcing Prime Minister Clement Attlee to dispatch the Cabinet Mission in March 1942/1946 to facilitate a peaceful transfer of power. While the subsequent failure of the Cabinet Mission led directly to the communal horrors of Direct Action Day in August 1946, the secular legacy and cross-communal unity achieved during the Red Fort trials and the RIN mutiny remained a shining star, serving as a direct institutional baseline for the drafting of the Constitution of Independent India in 1950.
Related Notes
- 2.1 Age of Discovery and European Exploration
- 3.1 Bengal Under Nawabs (Murshid Quli Khan, Alivardi Khan) and Rise of EIC Influence
- 4.1 Nature, Stages, and Methods of British Imperial Expansion
- 5.1 Policy of Ring Fence and Early Expansion Strategies
- 6.1 Evolution of East India Company: Trading Body to Sovereign Power