“It is not a charge sheet and they cannot be jailed on the basis of this report,” said Dinesh Tripathi, a senior independent lawyer.
“There has to be a criminal investigation by police … The government can file the case in the court only after that,” he said, adding that the process could take at least a couple of months.
Analysts say whether or not to take forward the recommendations is the responsibility of Shah, 35, and his Rastriya Swatantra Party.
The panel also recommended action against dozens of other officials and security personnel for the crackdown.
Families of the victims of the protests have been demanding punishment for those who were responsible for the crackdown.