On 12 June 1975, the Allahabad High Court declared Indira Gandhi's election to the Lok Sabha in 1971 void on grounds of electoral malpractice. The court ordered her stripped of her parliamentary seat and banned from running for any office for six years. As the constitution holds that the Prime Minister must be a member of either the Lok Sabha or the Rajya Sabha, the two houses of the Parliament of India, this would have effectively removed her from office. However, Gandhi rejected calls to resign and announced plans to appeal to the Supreme Court. Gandhi insisted that the conviction did not undermine her position, despite having been unseated from Lok Sabha.
Gandhi moved to restore order by ordering the arrest of most of the opposition participating in the unrest. Her Cabinet and government then recommended that President Fakhruddin Ali Ahmed declare a state of emergency because of the disorder and lawlessness following the Allahabad High Court decision. Accordingly, Ahmed declared a State of Emergency caused by internal disorder, based on the provisions of Article 352 of the Constitution, on 25 June 1975.