While Upton was posted to India, a confidential report that he had authored in October 1980 was leaked to a journalist for The Age, that included criticism of the then Indian Prime Minister Indira Gandhi.

[2] After a time at the Joint Intelligence Organisation in the early 1970s, Upton returned to the foreign affairs department and was posted to London as Minister in 1973.

[4] In 1975, when Sir Patrick Shaw died in office as Australian Ambassador to the United States, Upton was appointed Chargé d'Affaires ad interim.

[7] Whilst he was living in New Delhi, details of a confidential report that Upton sent to the Department of Foreign Affairs in October 1980 was published in The Age.

[8][9] The published report included critical remarks about the then Indian Prime Minister, Indira Gandhi, who had been in office for less than a year at the time.