 Pranab Mukherjee was secretly felicitated for helping Sanjay Gandhi for arresting high profile political opponents.In the elections held on 16–20 March 1977 Congress Party suffered a defeat at the hands of the Janata Party, which took office on 24 March 1977.The government appointed the commission on 28 May 1977 under Section 3 of the Commissions of Inquiry Act, 1952.