Bhima-Koregaon Commission Escalates Proceedings, Issues Show Cause Notice to Uddhav Thackeray Over Non-Compliance

Pune, India – The two-member commission of inquiry investigating the 2018 Bhima-Koregaon violence has taken a significant procedural step, issuing a show cause notice to former Maharashtra Chief Minister and Shiv Sena (UBT) chief, Uddhav Thackeray. The notice demands that Thackeray explain why a bailable warrant should not be issued against him for his persistent failure to respond to a plea for the production of documents deemed crucial to the inquiry.

The commission, led by retired Justice Jay Narayan Patel and former State Chief Secretary Sumit Mullick, is tasked with a fact-finding mission into the violent clashes that erupted on January 1, 2018. The incident occurred near the ‘vijay stambh’ (victory pillar) in Pune's Bhima-Koregaon area during the 200th-anniversary commemoration of the Battle of Bhima Koregaon, where Dalit soldiers fighting for the British East India Company defeated the Peshwa army.

The current legal escalation stems from an application filed in February by Vanchit Bahujan Aghadi leader, Prakash Ambedkar. The application centers on a set of documents allegedly submitted by Nationalist Congress Party (NCP) chief Sharad Pawar to Thackeray in 2020, during Thackeray's tenure as Chief Minister.

The Crucial Documents at the Heart of the Matter

According to Ambedkar’s plea, these documents contain serious allegations suggesting that the incumbent Chief Minister, Devendra Fadnavis—who also held the position in 2018 when the violence occurred—and the Pune Police were responsible for the unrest. Ambedkar has urged the commission to compel the production of this evidence, arguing it is vital for a comprehensive and impartial investigation into the root causes of the violence. He has also suggested that Pawar be summoned to testify regarding the contents and context of these documents.

"These documents," Ambedkar highlighted in his application, "were crucial for the inquiry into the incident and should be examined as part of the ongoing investigation."

The commission has noted that this is not its first attempt to secure Thackeray’s cooperation. Advocate Ashish Satpute, representing the commission, confirmed that notices had been issued to the former Chief Minister on two prior occasions regarding the same matter. The continued lack of response prompted Ambedkar's counsel to press for a bailable warrant to ensure Thackeray's presence and the production of the evidence.

The show cause notice, a standard legal precursor to more coercive measures, formally puts Thackeray on notice of the potential for a warrant. The commission’s directive is unequivocal:

"You are directed to remain present either in person or through authorised representative on December 2, 2025 at 11.00 AM and show cause as to why the said application [for a bailable warrant] should not be allowed... If you fail to comply with this show cause notice, further action as permissible in law would be taken against you."

This development places the spotlight on the procedural powers vested in commissions of inquiry under the Commissions of Inquiry Act, 1952 . The Act grants such bodies the powers of a civil court in respect of summoning and enforcing the attendance of any person, requiring the discovery and production of any document, and requisitioning any public record. The commission’s measured, step-by-step approach—from initial notices to a show cause hearing—demonstrates a commitment to procedural fairness while signaling its intolerance for non-compliance.

Legal Implications and the Commission's Long Road

For legal professionals, this situation serves as a compelling case study on the enforcement authority of quasi-judicial bodies, particularly when high-profile political figures are involved. The commission's decision to pursue a warrant against a former Chief Minister underscores its mandate to operate independently and seek all relevant evidence, regardless of the political stature of the individuals involved. The outcome of the December 2025 hearing will set a significant precedent for how the commission deals with recalcitrant witnesses or parties moving forward.

The Bhima-Koregaon Commission itself has been a subject of scrutiny due to its extended timeline. Constituted in 2018, its original mandate was to ascertain the facts behind the violence and provide recommendations to prevent future incidents. However, it has received numerous extensions over the past seven years. After its latest term was set to expire on October 31, it has now been granted a further extension until March 1, 2026.

This prolonged duration raises pertinent questions within the legal community about the efficacy and timeliness of such inquiries. While thoroughness is paramount, the long-drawn-out nature of the proceedings can delay justice and accountability. The commission is reportedly hearing final arguments and is expected to submit its definitive findings in 2026. The information contained in the documents sought from Thackeray could potentially have a material impact on these final conclusions.

As the commission enters the final phase of its investigation, its handling of this procedural challenge will be closely watched. The pursuit of these documents signifies a critical juncture in a long and complex inquiry, with the potential to reshape the narrative surrounding one of modern India's most contentious instances of caste-based conflict.