NEED OF FREEDOM OF PRESS: A CRITICAL ANALYSIS

FINAL DRAFT SUBMITTED IN FULFILLMENT OF THE SUBJECT

TELECOMMUNICATIONS, PRESS AND MEDIA LAW FOR THE COURSE B.A. L.L.B.
(Hons.), 9th SEMESTER during the Academic Year 2020-2021

Submitted By:

Abhinav Prasad

1605

BBA. LLB.

Submitted To:

Ms. Sadaf Fahim

October, 2020

CHANAKYA NATIONAL LAW UNIVERSITY

NYAYA NAGAR, MITHAPUR, PATNA - 800001.

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 DECLARATION

I hereby declare that the project work of Press, media & Telecommunication that is “Need of
freedom of press: A Critical Analysis” submitted to Ms. Sadaf Fahim, Chanakya National
Law University, Patna, is an original work done by me under the guidance of Ms. Sadaf
Fahim, Faculty-in-Charge (Press & Media), CNLU, Patna. The content in this project have
not been submitted to any other University or Institute for any purpose.

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 ACKNOWLEDGEMENT

It is my greatest pleasure to be able to present this project of press media

&telecommunication. I found it very interesting to work on this project. I would like to thank
my teacher, Ms. Sadaf Fahim for providing me with such an interesting project topic and for
her constant support and guidance.

I would also like to thank my librarian for helping me in gathering data for the project. Last,
but not the least, I would heartily thank my family and friends for their unwavering support
without which this work would not have been possible.

Abhinav Prasad

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Table of Contents
DECLARATION ................................................................................................................................... 2
ACKNOWLEDGEMENT ....................................................................................................................... 3
OBJECTIVES OF STUDY: .................................................................................................................. 5
HYPOTHESIS .................................................................................................................................. 5
RESEARCH METHODOLOGY ........................................................................................................... 5
SOURCES OF DATA:........................................................................................................................ 5
DEFINATION OF FREEDOM OF PRESS ................................................................................................. 6
FREEDOM OF PRESS& ARTICLE 19(1)(A) ............................................................................................. 8
Security of the State: ..................................................................................................................... 8
Friendly relations with foreign States: ............................................................................................ 9
Public order: .................................................................................................................................. 9
Decency and morality: ................................................................................................................... 9
Contempt of court: ........................................................................................................................ 9
Defamation: ................................................................................................................................ 10
Incitement to an offence: ............................................................................................................ 10
Sovereignty and integrity of India: ............................................................................................... 10
FREEDOM OF PRESS IN INDIA – A CONSTITUTIONAL PROSPECTIVE .................................................. 11
NEED OF FREEDOM OF PRESS .......................................................................................................... 15
COMPARISION OF PRESS FREEDOM INDEX ...................................................................................... 16
CONCLUSION ................................................................................................................................... 18

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OBJECTIVES OF STUDY:

 The objectives of the study are to understand in detail the concept of Freedom of
press.
 To know the importance of freedom of press.
 Understand recent trends of freedom of press in the country.

HYPOTHESIS

The hypothesis of my project is press has absolute freedom with reference to their telecast
and other broadcasting. Secondary hypothesis is that the freedom of press has declined in
current NDA government tenure.

RESEARCH METHODOLOGY
For the project research, the researcher has primarily relied upon the Doctrinal method of
research.
A Doctrinal Research means a research that has been carried out on propositions by the way
of analyzing the existing provisions, and cases by applying the reasoning power. It includes
conventional methods of research like library based research, searching upon some texts
(writings or documents), secondary data, etc.
The quality of doctrinal research depends upon the source materials on which the researcher
depends for his study.

SOURCES OF DATA:

Primary sources - Statues, Case laws

Secondary sources - Books, Websites

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 DEFINATION OF FREEDOM OF PRESS

Democracy can flourish only when the citizens of a country enjoy the freedom to speech and
expression subject to some reasonable restrictions. There is a need of trust between the
different levels of the government of a country for it to move forward with respect to other
nations. This trust is generated by press, which guarantees the citizens daily happenings in its
purest form.

It was hence due to this anxiety that The Press Council of India was born in 1994. But if, we
look to the first time, Lord Wellesley promulgated the “Press Regulations”, which had the
effect of imposing pre-censorship on a new-born newspaper publishing industry. Thereafter,
in 1835 the “Press Act” was passed. It was then in 1857, the “Gagging Act” was passed,
which among other things introduced the concept of compulsory licencing for the owning or
running of printing presses; empowered the government the publication or dissemination of
statements or new stories which had the tendency to cause restlessness against the
government, hence setting an example of a weakened authority.

It is an absence of statutory and administrative control on dissemination of information,

ideas, knowledge and thoughts.

The freedom of the press and of expression is guarded by the First Amendment to the US
Constitution which specifically lays down that this freedom be in no way abridge by the laws.
It is not Indian Leaders were not aware of the US First Amendment or of Jefferson’s famous
declaration when he said that “Were it left me to decide whether we should have a
government without newspaper or newspapers without a government, I should not hesitate a
moment to prefer the latter.” Jawahar Lal Nehru echoed similar views “I would rather have a
completely free press, with all the dangers involved in the wrong use of that freedom, than a
suppressed or regulated press.” Voltair once said, “I do not agree with a word you say but I
defend to death your right to say it.”

Mrs. Gandhi has never had much faith in the press. Her misgivings about the press wee first
expressed in her address to the International Press Institute Assembly in New Delhi on
November 15, 1966, when she blamed the press for giving wide publicity to student unrest in
the country. She said, “How much liberty should the press have in country like India which is
engaged in fighting a war against poverty, backwardness, superstition and ignorance.” Mrs.

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Gandhi would not suggest restrictions that might be imposed on the press but said that it was
for the leading editions, and journalists of the country to decide. Nine years later when Mrs.
Gandhi declared emergency action was taken against the press immediately and complete
censorship was imposed.

Kuldip Nayar, a veteran journalist wrote to Mrs. Gandhi soon after she imposed the
emergency, “if newspaper have criticized the government, it is largely because of its sluggish
administration, slow progress in the economy field and the gap between promise and
performance. My concept of a free press is to ferret out the truth and let the public know.”

To preserve the democratic way of life, it is essential that people should have the freedom to
express their feelings to make their views known to the people at large. The press, a powerful
media of mass communication should be free to play its role in building a strong viable
society. Denial of the freedom of press to citizens would necessarily undermine the power to
influence public opinion.

Besides the restrictions imposed on the press by the Constitution, there exists various other
laws which further curtail press freedom and the right of the citizen to information as well as
the right to freedom of speech and expression. They are all in force in the interest of public
order of the sovereignty and security of the state.

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 FREEDOM OF PRESS& ARTICLE 19(1)(A)
To preserve the democratic way of life it is essential that people should have the freedom of
express their feelings and to make their views known to the people at large. The press, a
powerful medium of mass communication, should be free to play its role in building a strong
viable society. Denial of freedom of the press to citizens would necessarily undermine the
power to influence public opinion and be counter to democracy.

Freedom of press is not specifically mentioned in article 19(1) (a) of the Constitution and
what is mentioned there is only freedom of speech and expression. In the Constituent
Assembly Debates it was made clear by Dr. Ambedkar, Chairman of the Drafting Committee,
that no special mention of the freedom of press was necessary at all as the press and an an
individual or a citizen were the same as far as their right of expression was concerned. 1

The framers of the Indian constitution considered freedom of the press as an essential part of
the freedom of speech and expression as guaranteed in Article 19 (1) (a) of the Constitution.

In Romesh Thaper vs State of Madras 2 and Brij Bhushan vs State of Delhi3, the Supreme
Court took it for granted the fact that the freedom of the press was an essential part of the
right to freedom of speech and expression. It was observed by Patanjali Sastri J. in Romesh
Thaper that freedom of speech and expression included propagation of ideas, and that
freedom was ensured by the freedom of circulation.

It is clear that the right to freedom of speech and expression carries with it the right to publish
and circulate one’s ideas, opinions and other views with complete freedom and by resorting
to all available means of publication. The right to freedom of the press includes the right to
propagate ideas and views and to publish and circulate them. However, the freedom of the
press is not absolute, just as the freedom of expression is not. Public Interest has to be
safeguard by article 19(1)(2) which lays down reasonable limitations to the freedom of
expression in matters affecting:

Security of the State: Reasonable restrictions can be imposed on the freedom of speech and
expression, in the interest of the security of the State. All the utterances intended to endanger

1
Dr. Mahendra Tiwari, Freedom of press in India: Constitutional Perspectives, (2006)
2
AIR 1950 SC 124
3
AIR 1950 SC 129

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the security of the State by crimes of violence intended to overthrow the government, waging
of war and rebellion against the government, external aggression or war, etc., may be
restrained in the interest of the security of the State It does not refer to the ordinary breaches
of public order which do not involve any danger to the State.

Friendly relations with foreign States: This ground was added by the Constitution (First
Amendment) Act of 1951. The State can impose reasonable restrictions on the freedom of
speech and expression, if it tends to jeopardise the friendly relations of India with other State.

Public order: This ground was added by the Constitution (First Amendment) Act, 1951 in
order to meet the situation arising from the Supreme Court’s decision in Romesh Thapar 4,
case. The expression ‘public order’ connotes the sense of public peace, safety and tranquility.

In Kishori Mohan v. State of West Bengal 5, the Supreme Court explained the differences
between three concepts: law and order, public order, security of State. Anything that disturbs
public peace or public tranquility disturbs public order. But mere criticism of the government
does not necessarily disturb public order A law punishing the utterances deliberately tending
to hurt the religious feelings of any class has been held to be valid as it is a reasonable
restriction aimed to maintaining the public order.

Decency and morality: The word ‘obscenity’ is identical with the word ‘indecency’ of the
Indian Constitution and arises the question whether the tendency of the matter charged as
obscene tend to deprave and corrupt the minds which are open to such immoral influences’.
This test was upheld by the Supreme Court in Ranjit D. Udeshi v. State of Maharashtra6 In
this case the Court upheld the conviction of a book seller who was prosecuted under Section
292, I.P.C., for selling and keeping the book The Lady Chatterley’s Lover. The standard of
morality varies from time to time and from place to place.

Contempt of court: The constitutional right to freedom of speech would not allow a person
to contempt the courts. The expression Contempt of Court has been defined Section 2 of the
Contempt of Courts Act, 1971. The term contempt of court refers to civil contempt or
criminal contempt under the Act. But judges do not have any general immunity from

4
Supra Note 1
5
AIR 1972 SC 1749
6
AIR 1965 SC 881

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criticism of their judicial conduct, provided that it is made in good faith and is genuine
criticism, and not any attempt to impair the administration of justice. In

Defamation: The clause (2) of Article 19 prevents any person from making any statement
that injures the reputation of another. With the same view, defamation has been criminalised
in India by inserting it into Section 499 of the I.P.C.

Incitement to an offence: This ground was also added by the Constitution (First
Amendment) Act, 1951. The Constitution also prohibits a person from making any statement
that incites people to commit offence.

Sovereignty and integrity of India: This ground was also added subsequently by the
Constitution (Sixteenth Amendment) Act, 1963. This is aimed to prohibit anyone from
making the statements that challenge the integrity and sovereignty of India.

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 FREEDOM OF PRESS IN INDIA – A CONSTITUTIONAL
PROSPECTIVE
In India before Independence, there was no constitutional or statutory guarantee of freedom
of an individual or media/press. At most, some common law freedom could be claimed by the
press, as observed by the Privy Council in Channing Arnold v. King Emperor7.

“The freedom of the journalist is an ordinary part of the freedom of the subject and to
whatever length, the subject in general may go, so also May the journalist, but apart from
statute law his privilege is no other and no higher. The range of his assertions, his criticisms
or his comments is as wide as, and no wider than that of any other subject. 8”

With object and views, the Preamble of the Indian Constitution ensures to all citizens inter
alia, liberty of thought, expression, belief, faith and worship. The constitutional significance
of the freedom of speech consists in the Preamble of Constitution and is transformed as
fundamental and human right in Article 19(1)(a) as “freedom of speech and expression.

For achieving the main objects, freedom of the press has been included as part of freedom of
speech and expression which is a universally recognized right adopted by the General
Assembly of the United Nations Organization on 10th December, 1948. The heart of the
declaration contained in Article 19 says as follows:

“Everyone has the right to freedom of opinion and expression, this right includes freedom to
hold opinions without interference and to seek, receive and impart information and ideas
through any media and regardless of frontiers 9.”

The same view of freedom of holding opinions without interference has been taken by the
Supreme Court in Union of India v. Assn. for Democratic Reforms 10 in which the Court has
observed as follows:

“One-sided information, disinformation, misinformation and non-information, all equally

create an uninformed citizenry which makes democracy a farce. … Freedom of speech and

7
(1914) 16 BOMLR 544
8
M.S.M. Sharma v/s Sri Krishna Sinha, AIR 1959 SC 395
9
Union of India v/s Association for Democratic Reforms (2002) 5 SCR 294
10
AIR 2001 DELHI 126.

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expression includes right to impart and receive information which includes freedom to hold
opinions.”

In India, freedom of press is implied from the freedom of speech and expression guaranteed
under Article 19(1)(a) of the Constitution of India. Article 19(1)(a) says that all citizens shall
have the right to freedom of speech and expression. But this right is subject to reasonable
restrictions imposed on the expression of this right for certain purposes under Article 19(2).

Keeping this view in mind Venkataramiah, J. of the Supreme Court of India in Indian
Express Newspapers (Bombay) (P) Ltd. v. Union of India 11 has stated:

“In today’s free world freedom of press is the heart of social and political intercourse. The
press has now assumed the role of the public educator making formal and non-formal
education possible in a large scale particularly in the developing world, where television and
other kinds of modern communication are not still available for all sections of society. The
purpose of the press is to advance the public interest by publishing facts and opinions without
which a democratic electorate [Government] cannot make responsible judgments.
Newspapers being purveyors of news and views having a bearing on public administration
very often carry material which would not be palatable to Governments and other
authorities.”

The above statement of the Supreme Court illustrates that the freedom of press is essential for
the proper functioning of the democratic process. Democracy means Government of the
people, by the people and for the people; it is obvious that every citizen must be entitled to
participate in the democratic process and in order to enable him to intelligently exercise his
right of making a choice, free and general discussion of public matters is absolutely essential.
This explains the constitutional viewpoint of the freedom of press in India 12.

The fundamental principle which was involved in freedom of press is the “people’s right to
know”. It therefore received a generous support from all those who believe in the free flow of
the information and participation of the people in the administration; it is the primary duty of

11
1986 AIR 515
12
Thayer, Legal Control of Press (1962), PP 5–7.

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all national courts to uphold this freedom and invalidate all laws or administrative actions
which interfere with this freedom, are contrary to the constitutional mandate 13.

Therefore, in view of the observations made by the Hon’ble Supreme Court in various
judgments and the views expressed by various jurists, it is crystal clear that the freedom of
the press flows from the freedom of expression which is guaranteed to “all citizens” by
Article 19(1)(a). Press stands on no higher footing than any other citizen and cannot claim
any privilege (unless conferred specifically by law), as such, as distinct from those of any
other citizen. The press cannot be subjected to any special restrictions which could not be
imposed on any citizen of the country14.

In Romesh Thapar v/s State of Madras 15, Patanjali Shastri,CJ, observed that “Freedom of
speech & of the press lay at the foundation of all democratic organization, for without free
political discussion no public education, so essential for the proper functioning of the process
of popular government, is possible.” In this case, entry and circulation of the English journal
“Cross Road”, printed and published in Bombay, was banned by the Government of Madras.
The same was held to be violative of the freedom of speech and expression, as “without
liberty of circulation, publication would be of little value” 16.

The Hon’ble Supreme Court observed in Union of India v/s Association for Democratic
Reforms17, “One-sided information, disinformation, misinformation and non information, all
equally create an uninformed citizenry which makes democracy a farce. Freedom of speech
and expression includes right to impart and receive information which includes freedom to
hold opinions”. In Indian Express Newspapers v/s Union of India, it has been held that the
press plays a very significant role in the democratic machinery. The courts have duty to
uphold the freedom of press and invalidate all laws and administrative actions that abridge
that freedom. Freedom of press has three essential elements. They are:

1. Freedom of access to all sources of information,

2. Freedom of publication, and

13
R v. Dean of St. Asaph, (1784) 3 TR 428
14
Brij Bhushan vs State of Delhi, A.I.R. 1950 SC 129; 1950 SCR 605
15
A.I.R. 1950 SC 124
16
Romesh Thaper vs State of Madras, A.I.R. 1950 SC 124
17
Supra Note 9.

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3. Freedom of circulation.

There are many instances when the freedom of press has been suppressed by the legislature.
In Sakal Papers v/s Union of India 18, the Daily Newspapers (Price and Page) Order, 1960,
which fixed the number of pages and size which a newspaper could publish at a price was
held to be violative of freedom of press and not a reasonable restriction under the Article
19(2). Similarly, in Bennett Coleman and Co. v/s Union of India19, the validity of the
Newsprint Control Order, which fixed the maximum number of pages, was struck down by
the Court holding it to be violative of provision of Article 19(1)(a) and not to be reasonable
restriction under Article 19(2). The Court also rejected the plea of the Government that it
would help small newspapers to grow.

18
1962 AIR 305.
19
AIR 1973 SC 106.

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 NEED OF FREEDOM OF PRESS
In a democracy, freedom of press is regarded extremely vital and crucial. A free press is not
only a necessary adjunct of democracy; it is the sine qua non for the proper functioning of a
democratic society. Freedom of press is essential to political liberty and proper functioning of
democracy. When men cannot freely convey their thoughts to one another, no freedom is
secured where freedom of expression exists the beginning of a free society and means for
every retention of liberty are already present.

Status of press freedom worldwide

Beyond legal definitions, several non-governmental organizations use other criteria to judge
the level of press freedom around the world. Some create subjective lists, while others are
based on quantitative data:

Reporters Without Borders considers the number of journalists murdered, expelled or

harassed, and the existence of a state monopoly on TV and radio, as well as the existence of
censorship and self-censorship in the media, and the overall independence of media as well as
the difficulties that foreign reporters may face to rank countries in levels of press freedom.

The Committee to Protect Journalists (CPJ) systematically tracks the number of journalists
killed and imprisoned in reprisal for their work. It says it uses the tools of journalism to help
journalists by tracking press freedom issues through independent research, fact-finding
missions, and a network of foreign correspondents, including local working journalists in
countries around the world. CPJ shares information on breaking cases with other press
freedom organizations worldwide through the International Freedom of Expression
Exchange, a global network of more than 119 free expression organizations. CPJ also tracks
impunity in cases of journalist murders. CPJ staff applies strict criteria for each case;
researchers independently investigate and verify the circumstances behind each death or
imprisonment.

Freedom House studies the more general political and economic environments of each nation
in order to determine whether relationships of dependence exist that limit in practice the level
of press freedom that might exist in theory. Panels of experts assess the press freedom score
and draft each country summary according to a weighted scoring system that analyzes the
political, economic, legal and safety situation for journalists based on a 100-point scale. It
then categorizes countries as having a free, party free, or not free press.

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 COMPARISION OF PRESS FREEDOM INDEX

Every year, Reporters Without Borders establish a subjective ranking of countries in terms of
their freedom of the press. Press Freedom Index list is based on responses to surveys sent to
journalists that are members of partner organizations of the RWB, as well as related
specialists such as researchers, jurists, and human rights activists. The survey asks questions
about direct attacks on journalists and the media as well as other indirect sources of pressure
against the free press, such as non-governmental groups.

In 2016, the countries where press was the most free were Finland, Netherlands, Norway,
Denmark and New Zealand, followed by Costa Rica, Switzerland, Sweden, Ireland and
Jamaica. The country with the least degree of press freedom was Eritrea, followed by North
Korea, Turkmenistan, Syria, China, Vietnam and Sudan. 20

The problem with media in India, the world's largest democracy, is enormous. India doesn't
have a model for a democratic press. The Canadian Journalists for Free Expression (CJFE)
has published a report21 on India stating that Indian journalists are forced—or feel compelled
for the sake of job security—to report in ways that reflect the political opinions and corporate
interests of shareholders. The report written by Ravi S Jha says "Indian journalism, with its
lack of freedom and self-regulation, cannot be trusted now—it is currently known for
manipulation and bias."

Freedom of the Press is a yearly report by US-based non-profit organization Freedom House.
It is known to subjectively measure the level of freedom and editorial independence that is
enjoyed by the press in every nation and significant disputed territories around the world.
Levels of freedom are scored on a scale from 1 (most free) to 100 (least free). Depending on
the basics, the nations are then classified as "Free", "Partly Free", or "Not Free".

The Indian Constitution, while not mentioning the word "press", provides for "the right to
freedom of speech and expression" (Article 19(1) a). However this right is subject to
restrictions under sub clause, whereby this freedom can be restricted for reasons of
"sovereignty and integrity of India, the security of the State, friendly relations with foreign

20
"2016 World Press Freedom Index". Reporters Without Borders. 2016. Retrieved 07/09/2019.
21
"India's Free Press Problem: Politics and Corporate Interests Invade Journalism".

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States, public order, preserving decency, preserving morality, in relation to contempt, court,
defamation, or incitement to an offense". Laws such as the Official Secrets Act and
Prevention of Terrorist Activities Act (PoTA) have been used to limit press freedom. Under
PoTA, person could be detained for up to six months for being in contact with a terrorist or
terrorist group. PoTA was repealed in 2006, but the Official Secrets Act 1923 continues.

For the first half-century of independence, media control by the state was the major constraint
on press freedom. Indira Gandhi famously stated in 1975 that All India Radio is "a
Government organ, it is going to remain a Government organ..." With the liberalization
starting in the 1990s, private control of media has burgeoned, leading to increasing
independence and greater scrutiny of government.

It ranks poorly at 140th rank out of 180 listed countries in the Press Freedom Index 2018
released by Reporters Without Borders (RWB). Analytically India's press freedom, as could
be deduced by the Press Freedom Index, has constantly reduced since 2002, when it
culminated in terms of apparent freedom, achieving a rank of 80 among the reported
countries. In 2019, India's freedom of press ranking declined to 140. In explaining the
decline, RWB cited growing intolerance from Hindu nationalist supporters of Indian Prime
Minister Narendra Modi, and the murders of journalists such as Gauri Lankesh. 22

India’s score in 2019 World Press Freedom Index is heavily affected by the situation in
Kashmir where, after rescinding the state’s autonomy, the federal government shut down
fixed line and mobile Internet connections completely for several months, making it virtually
impossible for journalists to cover what was happening in what has become a vast open
prison.23

In 2020, India had dropped two places on the global press freedom index — from 140 to 142.

India’s rank went from 122 in 2010 to 142 this year, falling 20 places in a decade.

22
"India's ranking in press freedom falls to 140". The Hindu. 26 April 2018. Retrieved 07/09/2019.
23
https://rsf.org/en/india

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 CONCLUSION

In democracy, the Government cannot function unless the people are well informed and free
to participate in public issues by having the widest choice of alternative solutions of the
problems that arise. Articles and news are published in the press from time to time to expose
the weaknesses of the governments. The daily newspaper and the daily news on electronic
media are practically the only material which most people read and watch. The people can,
therefore, be given the full scope for thought and discussion on public matter, if only the
newspapers and electronic media are freely allowed to represent different points of views,
including those of the opposition, without any control from the Government
In words of the Father of the Nation Mahatma Gandhi, "The role of journalism should be
service. The Press is a great power, but just as an unchained torrent of water submerges the
whole countryside and devastates crops, even so an uncontrolled pen serves but to destroy."
There are three pillars of a democracy viz. the legislative, the executive & the judiciary. The
press acts as the fourth pillar of a democracy. The press has played many significant roles in
delivering justice, public welfare etc.
The National Commission to Review the Working of the Constitution (NCRWC) has in its
final report submitted to the Government recommended that Article 19(1)(a) which deals
with “freedom of speech & expression” must expressly include the freedom of the press and
other media, the freedom to hold opinion and to seek, receive and impart information and
ideas.
It has been sixty years since India became Republic & commencement of the Constitution
there is been a lot of ups & down in our democracy & the press also has come across age. As
being a subject of the largest democracy of the world we should remember the words of our
former Prime Minister Rajiv Gandhi, “Freedom of Press is an Article of Faith with us,
sanctified by our Constitution, validated by four decades of freedom and indispensable to our
future as a Nation.”
Thus, we can conclude that the time has come for the press of largest democracy of the world
to work with hand-in-hand with judiciary for the welfare of its subjects. The day is not far
away when there will be no eclipse of injustice & the sun of justice will shine brightly
forever.

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 BIBLIOGRAPHY

PRIMARY SOURCES

(i) Indian Penal Code, 1860.

(ii) Constitution Of India,1950.
(iii)Contempt of Courts Act, 1971.

SECONDARY SOURCES

BOOKS-

 Pandey, J. N., Constitutional Law of India, 42nd ed. (2005), Central Law Agency,
Allahabad.
 Gaur, K.D., Textbook on The Indian Penal Code, 4th ed. (2010), Universal Law
Publishing Co., Delhi.
 Rai, Kailash, the Constitutional Law of India,7th ed. (2008), Central Law
Publications, Allahabad
 Tiwari, Dr. Mahendra, Freedom of press in India: Constitutional Perspectives, (2006)

WEBSITES-

(i) https://qrius.com/need-ensure-freedom-indias-free-press/
(ii) https://www.iaspaper.net/importance-freedom-press/
(iii)https://www.thehindu.com/opinion/lead/freedom-of-the-press-and-journalistic-
ethics/article2071551.ecehttps://www.thehindu.com/opinion/lead/freedom-of-the-
press-and-journalistic-ethics/article2071551.ece
(iv) https://www.prsindia.org/theprsblog/regulation-media-india-brief-overview

19 | C h a n a k y a N a t i o n a l L a w U n i v e r s i t y , P a t n a