recognition of a few sovereign governments, and that the Indian Penal Code did not apply to their case. The judge nevertheless pronounced the three officers guilty and sentenced them to transportation for life. The accused were however released and during the course of the trials reignited the Indian freedom struggle leading to complete independence in 1947. Death Bhulabhai Desai died on 6 May 1946. His immense wealth led to the creation of the Bhulabhai Memorial Institute in Bombay. Legacy M.C. Setalwad authored his biography, Bhulabhai Desai. Bhulabhai Desai Road in Mumbai is named after him. References Rajmohan Gandhi, Patel: A Life (1992) Indian independence activists from Gujarat Indian National Army trials 1877 births 1946 deaths Gujarati people University of Mumbai alumni Members of the Central Legislative Assembly of India Elphinstone College alumni Prisoners and detainees of British India 19th-century Indian lawyers Politicians from Mumbai Indian National Congress politicians from Gujarat People from Valsad district 20th-century Indian lawyers 20th-century Indian politicians Lawyers in British India