 Post Bathani Tola Carnage there were several retaliatory naxal attacks killing at least 500 upper caste civilians  as well as attacks on Dalits and Labourers organized by the Ranvir Sena in Laxmanpur Bathe and Sankarbigha in which 81 Dalits were killed.The Counsel for the witness, Anand Vatsyayan, expressed being shocked at the High Court verdict and reportedly said that "sufficient evidence were at hand to uphold the judgement passed by the Ara sessions court.The Supreme Court guidelines in the event of a massacre are quite clear.