B N Srikrishna in his report on Friday, Mar 6 said the behaviour of the lawyers was unruly which led to the clashes. Justice Srikrishna had been appointed by the court to investigate what caused the clashes.
The lawyers had refused to rejoin work despite the Supreme Court's order. They said they will do so only after the Justice Srikrishna Commission report.
Srikrishna in his report urged the Supreme Court "take this opportunity to exercise its extraordinary constitutional powers and lay down sufficient guidelines for the behaviour of the lawyers within and without the court premises as the bar councils have not been acting as an effective regulatory body of their professional conduct".