Justice Manmohan Singh Liberhan, former Chief Justice of the Madras and Andhra Pradesh High Courts, died on 2 August 2026 at the age of 87.
Born on 11 November 1938 near Chandigarh, he began his legal career at the Punjab and Haryana High Court in 1964.
He headed the one-man Liberhan Commission appointed on 16 December 1992 to inquire into the demolition of the Babri Masjid.
The Commission submitted its report on 30 June 2009, after 17 years and 48 extensions.
The report described the demolition of 6 December 1992 as a meticulously planned act.
The Babri Masjid at Ayodhya is demolished.
The one-man Liberhan Commission is appointed under the Commissions of Inquiry Act, 1952 to inquire into the demolition.
The Commission receives 48 extensions of its term while recording evidence.
The report is submitted, describing the demolition as meticulously planned.
Justice Liberhan dies at the age of 87.
The Central or a state government may appoint a commission of inquiry to investigate any matter of public importance. A commission has the powers of a civil court for summoning witnesses, requiring documents and examining evidence on oath, and it may be headed by a sitting or retired judge. What it cannot do is decide anything. Its report is recommendatory: the government must lay it before the legislature along with an action-taken memorandum, but is under no obligation to accept its findings, and the report by itself creates no criminal liability. That gap between exhaustive fact-finding and legal consequence is what makes the Liberhan Commission a standard case study — seventeen years of inquiry and forty-eight extensions produced a detailed narrative of what happened, while the criminal proceedings arising from the same events followed an entirely separate course through the courts.
Simple Analogy: A commission of inquiry writes the definitive account of what happened. Whether anything follows from that account is somebody else's decision.
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A body appointed under the Commissions of Inquiry Act, 1952 to inquire into a definite matter of public importance; its findings are recommendatory.
The one-man commission appointed on 16 December 1992 to inquire into the Babri Masjid demolition; reported on 30 June 2009.
The memorandum a government must lay before the legislature alongside a commission's report, stating what it proposes to do.
The High Court at Chandigarh where Justice Liberhan began practice in 1964.