Satpathy otherwise attempted to resist Indira Gandhi's policies during the Emergency. Satpathy left office in December 1976. During the general election in 1977, she was part of a group of protesters led by Jagjivan Ram, which became the Congress for Democracy (CFD) party. CFD merged with Janata Party in May 1977. Nandini Satpathy was elected to Orissa Vidhan Sabha from Dhenkanal in June 1977. In 1980, she won that seat as Congress (Urs) candidate, and in 1985 as an independent. In 1990, her son Tathagata Satpathy won Dhenkanal assembly seat as Janata Dal candidate. Nandini Satpathy returned to the Congress party in 1989, on the request of Rajiv Gandhi. The Congress party was unpopular in Odisha as a whole, due to its two term miss rule (primarily under Janaki Ballabh Patnaik as Chief Minister). She was elected as a member of the State Legislative Assembly from Gondia, Dhenkanal and remained in the Assembly until 2000, when she decided to retire from politics; she did not contest the 2000 elections. She was not influential in and was critical of the Odisha branch of the Congress party. Court Case In 1977, Satpathy was accused of corruption and a police investigation started into possible violations of the Prevention of Corruption Act in force at that time. During the investigation, she was interrogated on a number of questions in written form. She refused to answer any questions; her attorney argued that Article 20 (3) of the Indian Constitution protected her against forced self-incrimination. The court agreed, strengthening the rights of the accused with a recognition of the right to a lawyer and the right against self-incrimination; it moreover held that women have the right to be questioned at their homes in the presence of male relatives, have the right to be brought to the police station only after a formal arrest, and have the right to be searched only by other women. Over the next 18 years, Satpathy won all of the cases against her. Literary career Satpathy was a writer in the Odia language; her work has been translated and published into a number of other languages. She received the 1998 Sahitya Bharati Samman Award for her contributions to Oriya literature. Her last major literary work was translating Taslima Nasreen's Lajja into Oriya. Death She died on 4 August 2006 at her home in Bhubaneswar. Srimati Nandini Satpathy Memorial Trust (SNSMT) In 2006