The killings of Sikhs in Delhi and other cities followed the assassination of Prime Minister Indira Gandhi on 31 October 1984 by two of her bodyguards. Official and commission estimates place the toll in Delhi alone at more than 2,700. What made the episode a recurring subject in Indian public law was not only the scale of the violence but the collapse of the ordinary criminal process afterwards: hundreds of first information reports were closed as untraced and most prosecutions ended in acquittal. Successive commissions of inquiry, and later a Special Investigation Team constituted by the Centre to reopen closed cases, were the mechanism by which a handful of prosecutions were revived decades later. Sajjan Kumar's 2018 conviction came out of exactly that route: the Delhi High Court set aside a trial court acquittal and convicted him, and the judgment is frequently cited for its observations on delayed justice in mass-crime cases.