Subsequently, Prime Minister Gandhi made A. N. Ray—the senior-most judge amongst those in the minority in Kesavananda Bharati—Chief Justice of India. Ray superseded three judges more senior to him—J. M. Shelat, K. S. Hegde and Grover—all members of the majority in Kesavananda Bharati. Indira Gandhi's tendency to control the judiciary met with severe criticism, both from the press and political opponents such as Jayaprakash Narayan ("JP"). Political unrest This led some Congress party leaders to demand a move towards a presidential system emergency declaration with a more powerful directly elected executive. The most significant of the initial such movement was the Nav Nirman movement in Gujarat, between December 1973 and March 1974. Student unrest against the state's education minister ultimately forced the central government to dissolve the state legislature, leading to the resignation of the chief minister, Chimanbhai Patel, and the imposition of President's rule. Meanwhile, there were assassination attempts on public leaders as well as the assassination of the railway minister Lalit Narayan Mishra by a bomb. All of these indicated a growing law and order problem in the entire country, which Mrs. Gandhi's advisors warned her of for months. In March–April 1974, a student agitation by the Bihar Chatra Sangharsh Samiti received the support of Gandhian socialist Jayaprakash Narayan, referred to as JP, against the Bihar government. In April 1974, in Patna, JP called for "total revolution," asking students, peasants, and labor unions to non-violently transform Indian society. He also demanded the dissolution of the state government, but this was not accepted by the center. A month later, the railway-employees union, the largest union in the country, went on a nationwide railways strike. This strike was led by the firebrand trade union leader George Fernandes who was the President of the All India Railwaymen's Federation. He was also the President of the Socialist Party. The strike was brutally suppressed by the Indira Gandhi government, which arrested thousands of employees and drove their families out of their quarters. Raj Narain verdict Raj Narain, who had been defeated in the 1971 parliamentary election by Indira Gandhi, lodged cases of election fraud and use of state machinery for election purposes against her in the Allahabad High Court. Shanti Bhushan fought the case for Narain (Nani Palkhivala fought the case for Indira). Indira Gandhi was also cross-examined in the High Court which was the first such instance for an Indian Prime Minister