During his term as president, he was affectionately known as the "People's President", saying that signing the Office of Profit Bill was the toughest decision he had taken during his tenure. Kalam was criticised for his inaction in deciding the fate of 20 out of the 21 mercy petitions submitted to him during his tenure. Article 72 of the Constitution of India empowers the President of India to grant pardons, and suspend or commute the death sentence of convicts on death row. Kalam acted on only one mercy plea in his five-year tenure as president, rejecting the plea of rapist Dhananjoy Chatterjee, who was later hanged. Perhaps the most notable plea was from Afzal Guru, a Kashmiri terrorist who was convicted of conspiracy in the December 2001 attack on the Indian Parliament and was sentenced to death by the Supreme Court of India in 2004. While the sentence was scheduled to be carried out on 20 October 2006, the pending action on his mercy plea resulted in him remaining on death row. He also took the controversial decision to impose President's Rule in Bihar in 2005.