Newly-appointed CJI Sanjiv Khanna's late uncle, Justice Hans Raj Khanna, was denied the CJI post by ex-PM Indira Gandhi. In 1976, HR Khanna was the sole dissenting judge in the 4:1 verdict in the ADM Jabalpur vs Shivkant Shukla case during the Emergency. Nine months after the judgment, the government appointed MH Beg as the CJI, superseding Justice HR Khanna.