Imprisoned during Indira Gandhi’s authoritarian Emergency regime from 25 June to March 1976 in Delhi’s Tihar jail. On being released, gives a historic 4-hour speech in the UP Legislative Assembly on 23 March, condemning the Emergency and energizing opposition to Indira Gandhi. Redoubles efforts at forging opposition unity, but faces issues with Morarji Desai’s desire to be leader and Jana Sangh’s opposition to subsuming its identity in a single political party.