Doctor Who: EVERY Version Of The Master Explained
10. The Trial Master (First Appearance: 1996)
It's certainly possible that the Master who's put on trial in the opening of the 1996 TV Movie is the Tremas incarnation. However, it's not Anthony Ainley who gets exterminated by those high-pitched Daleks – it's actor Gordon Tipple.
It's not clear exactly what the Master did in the gap between Survival and the TV Movie to anger the Daleks, although given that he was on trial on the Dalek homeworld Skaro, it may have been something to do with destroying or taking over their planet.
Alternatively, an early draft for the TV Movie had the Master in league with the Daleks, so maybe it's a hangover from that?
Either way, the result of the Master's trial was his execution. Unable to regenerate due to having used up all his lives, his remains were placed in a casket, and the Seventh Doctor set about taking them back to Gallifrey for a proper burial.
However, this was a task he would fail to complete.