From Headlines to Verdicts: Examining the influence of Media Coverage on the Right to a Fair Trial

I. Introduction

The media is often considered as the fourth branch of government as it plays such an essential role ensuring and upholding the principles of a free and democratic society. Its necessity is widely acknowledged and deeply valued. Under Part III of the Indian Constitution, fundamental rights are guaranteed which includes the “right to freedom of speech and expression” as enshrined in Article 19(1)(a)². This right, though not entirely absolute, can be constrained reasonably such as those given in Article 19(2)³ of the constitution of India under the “security of state” clause. In Romesh Thappar v. State of Madras⁴ case, the supreme court of India held that freedom of the press falls within freedom of speech and expression thereby ensuring it to have related protection and restrictions. But maintaining the independence of the media against ensuring its judicious employment has been a point of controversy.

Historically, the media has been drastically important in India. Especially during the British colonial era, when it was used as an instrument for securing freedom in India. Consequently, rising influence of the media culminated into several legislations aimed at taming it as directed by the colonial government in India. Since then, print media has fallen out of favour to audio-visual and digital platforms. These developments have dramatically expanded its influence on both individual lives and society.

The media is omnipresent in practically every aspect of life, including personal life, as a result of its pervasiveness in modern society, which suggests that it has influenced almost every aspect of our everyday lives. This all-encompassing impact has provoked questions about whether the use of press should be restricted when it comes to legal matters. The press often conducts prejudiced reporting which may damage somebody's reputation or violate an individual's rights as it seeks sensationalism while looking for popularity trying to hit higher rates. This sometimes results in the media influencing how the public sees judicial systems.

The Indian Constitution guarantees fundamental rights that are considered the basic structure of the constitution, including the right to a fair trial. The media, under the freedom of speech and expression, is empowered to publish opinions about individuals. Nonetheless there are some restrictions on this right. The standards of justice are violated when media reports err on the side of defamation or biased reporting. Instances such as the coverage of Sushant Singh Rajput's suicide and the Aarushi Talwar⁵ murder case exemplify how media can sometimes pre-empt legal proceedings, potentially influencing public opinion and judicial outcomes before a verdict is reached. These cases highlight the need to strike a balance between the freedom of the press and the right to a fair trial because media trials, in which journalists serve as juries and judges, frequently violate both the fundamental precept that all parties are innocent unless and until proven guilty and the right to an impartial trial.

This study purports to delve into the issue of media trials in relation to the administration of justice and explore measures to counteract the negative consequences of such in the same. It intends to look into how media reports connect with legal processes and peoples’ liberties in the context of media-judicial interaction. By addressing these issues, the research seeks to create a scenario which will safeguard both the free press and the right to fair hearing. It is going further to suggest some ideas that will make sure media practice does not obstruct the objectivity of the judiciary system that would enable it serve efficiently hence leading to a more equitable society.

II. The concept of fair trial: historical and modern perspectives

The concept of a fair trial has been recognized since ancient times to ensure justice through impartial proceedings. Unlike modern legal systems rooted in complex code approach, ancient justice relied on interpretations by rulers. The Indian justice system incorporates numerous interpretations based on English jurisprudence, derived from the English legal system. A fair trial involves an unbiased individual or group conducting proceedings to ensure justice in specific cases.

(A) Fair Trial in Ancient India

Sources

Social, political, ethical, legal, and religious principles that regulate the way a society should behave have always been at the core of law in India from the most remote antiquity up to now. Without any doubt, this extensive realm of human relations and behaviours seems to have been governed by various ancient texts such as Brihaspati, Manusmriti, Kantaksodhna, Narada.

King’s Court

Kings who were seen as upright and fair used to provide justice. These kings were invested with constitutional and legal powers to adjudicate cases and when need arose, they would appoint Brahmins to help sort out issues.

Hierarchy of Courts

The judicial hierarchy: included says to the Brihaspati (Smriti is attributed) family arbitrators, judges, chief justice (Praadvivaka or Adhyaksha), and finally, the King’s court.

Court Procedure

Cases were filed by petitioners, and written plaints were required. Bagatelles were often dismissed, but cases of physical injury were rocketed to the top of court schedule. The plaintiff appealed to the King and the accused person was taken into custody during that time.

Witnesses and Documents

Narada told the story of witnesses who had seen the issue themselves. Witnesses of any caste might be considered honest.⁶ Brihaspati classified documents into 3 groups: those written by professional scribes, royal ones, public ones, and those personally written and witnessed by common people.

Lawyers and Secret Agents

There was no specific group of lawyers, but individuals well-versed in Smriti laws represented parties.⁷

Open Trial

Trials were public, with the King acting without biasness. Judgments were announced publicly, and appeals could be made to the King. Offenders found guilty were punished.⁸

Laws and Legal Principles

There were other settings for trials in which the rules of natural justice were not adhered to, as the king could not grant pardons, due process had to be followed in criminal cases, and much evidence was required to prove guilt. Hindu judges were eager to expedite judgments, comply with principles of equity, and natural justice which referred to the idea that one is considered innocent until proven guilty, highly and irrebutatably guilty is proven.

(B) Fair Trial in Medieval India

Sources

During the medieval period, the Mughal Sultanate governed India, relying on Muslim legal sources like the Quran, Ijma, and Hadith, with the Quran being the primary source.⁹

Hierarchy of Courts

The Sultan appointed Qazis, who handled cases within their jurisdiction. The court hierarchy included a supreme court, high courts, and district courts.

Witnesses and Evidence

Four witnesses were required to establish facts. All Muslims, except those punished or identified as liars, could testify. The evidence law was rigid and technical, mandating witnesses to be present and testify.

Trial

Trials employed eight judicial proceedings: judges, accountants, law books, assessors, scribes, gold, fire ordeal, and water. Both parties needed to be present, and Qazis could not decide ex-parte.

(C) Fair Trial in Modern India

Warren Hastings’ Plan, 1772

Under Warren Hastings, the British introduced the first major step towards establishing a justice system. The Judicial Plan of 1772 set up courts where trials were conducted based on legal principles, fairness, and moral conscience.¹⁰

Judicial Reforms and Plans

Subsequent reforms by Warren Hastings and Lord Cornwallis established various judicial plans, including the Judicial Plan of 1774, the reorganization of Adalats in 1780, and further reforms in 1781. These reforms aimed to separate revenue from judiciary functions, extend court jurisdictions, and enhance the administration of justice.

III. Principal features of a fair trial

Presumption of Innocence

This fundamental principle dictates that the accused should not be treated as a criminal upon filing a complaint. The prosecution bears the burden of proving guilt beyond a reasonable doubt. The Supreme Court upheld this in the case of State of U.P. v. Naresh and Ors¹¹.

Independent and Impartial Judges

An independent, impartial, and competent judge is crucial for a fair trial, ensuring unbiased justice. The judiciary's independence, separate from the legislature and executive, is vital for protecting constitutional rights. In Shyam Singh v. State of Rajasthan¹², the court emphasized impartiality in the judiciary.

Venue of Trial

The trial's venue should be convenient for both parties to ensure fairness. Jurisdiction is based on the location of the crime, ensuring that trials are accessible and fair. Section 177-189 of the Cr. P.C outlines jurisdiction provisions.¹³

Adversary System

The criminal trial system in India follows the adversarial method, ensuring fairness through an impartial judge and equal opportunities for both parties. Courts actively frame charges and ensure justice, as affirmed in Himanshu v. State of M.P¹⁴.

Expeditious Trial

A speedy trial is essential to prevent unnecessary hardships. Section 309(1) of the Cr. P.C mandates expeditious proceedings. In Husainara Khatoon v. State of Bihar¹⁵, the Supreme Court recognized speedy trials as a right under Article 21 of the Constitution.

A fair trial is fundamental for justice, protected by criminal laws and constitutional provisions. Ensuring a fair trial is crucial for societal peace and order, protecting the rights of the accused, and maintaining justice.

IV. Legal perspective on media trial in india

Before the passing of the 1950 Constitution, press’s history in India is traceable all the way from the arrival of the Portuguese and subsequent significant advancement under British colonialism. The direction of the Indian press has been characterized by its evolution from an instrument of conversion and domination to an effective instrument for political defiance, national consciousness, and awareness. The Portuguese were the first to introduce the printing press in India, but it was during the 18th century under British colonial rule that the press saw substantial development. The vernacular press played a pivotal role in gaining the trust of Indian society, becoming a crucial medium for the national movement. Newspapers began publishing in various Indian languages such as Hindi, Urdu, Bengali, Telugu, and Tamil, fostering a sense of unity and political consciousness among the diverse Indian populace. The British government, recognizing the growing influence of the press, enacted several regulations to control and suppress its reach. The few enactments of that time were: Regulations, 1799; Adam's regulation, 1823; Lord Canning’s Act, 1857; Indian Penal Code, 1860; Newspapers (Incitement to Offences) Act, 1908; Indian Press Act, 1910; Press Law Repeal and Amendment Act, 1922; India Press (Emergency Powers) Act, 1931.

(A) Regulating Media Trials in India

The Indian Constitution enshrines the freedom of the press as a fundamental right under Article 19(1)(a)¹⁶. However, this right is not absolute and is subject to reasonable restrictions outlined in Article 19(2)¹⁷. These restrictions are essential to prevent the misuse of the right and ensure the protection of public interest.

Several laws and regulations govern media trials in India, aimed at maintaining a balance between the freedom of the press and individual rights. Here's an overview of key legislations:

1. Constitution of India:

Under Article 19(2), reasonable restrictions can be imposed on the freedom of speech and expression in the interest of security, sovereignty, public order, decency, and morality, among other grounds.

2. Indian Penal Code (IPC):

Sections 499 and 500 of the IPC deal with defamation, making it an offense punishable by imprisonment or fine. Defamation can occur through spoken or written words that lower the reputation of an individual.

3. Criminal Procedure Code (Cr.P.C.):

The Cr.P.C. ensures fair trial principles, emphasizing the presumption of innocence until proven guilty and the need for impartial courts. Media trials undermine these principles and are contrary to the rule of law.

4. Press Council of India Act:

Established to oversee press activities, the Press Council of India regulates ethical conduct, handling complaints against newspapers, editors, and journalists. It aims to maintain standards and accountability in the press.

5. Contempt of Court Act:

This act addresses disrespect or disobedience toward the judiciary. Media trials that prejudge or influence ongoing cases amount to contempt of court, punishable by imprisonment or fine.

6. Right to Information Act (RTI):

While not directly related to media trials, the RTI Act promotes transparency and accountability in governance. It restricts the disclosure of personal information unless justified by public interest.

7. Prasar Bharati Act:

Established an autonomous broadcasting body to regulate public broadcasting services, ensuring fairness and balance in news broadcasting.

8. Cable Television Network Act:

Regulates cable TV networks, ensuring the broadcast of programs that are not obscene or defamatory. It empowers the government to seize equipment for improper registration.

9. Press and Registration Books Act:

Requires newspapers and presses to declare ownership and maintain transparency in publication. The act also mandates registration with authorities.

These laws collectively aim to uphold the integrity of the media while safeguarding individual rights and ensuring a fair and impartial judicial process. By imposing reasonable restrictions and promoting accountability, they seek to prevent the misuse of media for unethical or unlawful purposes.

V. Global standards & instruments safeguarding fair trial rights

Freedom of speech and expression are foundational pillars of liberty, vital for the functioning of democracies worldwide. Nations like India and the United States have long recognized the significance of these rights, viewing them as crucial for preserving democratic identity. Over time, the interpretation of freedom of expression has evolved, with courts acknowledging its broad scope and importance in ensuring an informed citizenry.

However, the exercise of free speech, particularly by the media, has raised complex legal questions, often intersecting with the rights of individuals, including the right to a fair trial. Media trials, characterized by sensationalized coverage of high-profile cases, pose challenges to the principles of fair trial and justice.

International conventions play a crucial role in safeguarding fair trial rights on a global scale. The Universal Declaration of Human Rights (UDHR), adopted by the United Nations General Assembly, enshrines the right to a fair and public hearing before an independent tribunal. Similarly, the International Covenant on Civil and Political Rights (ICCPR) emphasizes equality before the courts, the presumption of innocence, and protection against double jeopardy.

In Canada, the Charter of Rights and Freedoms guarantees essential legal rights, including timely trials and the presumption of innocence. Meanwhile, the European Convention on Human Rights outlines minimum rights for the accused in criminal proceedings, ensuring access to legal representation and a fair trial.

By addressing the challenges posed by media trials, international conventions emphasize the protection of individual rights against arbitrary interference and defamation. The Universal Declaration of Human Rights underscores the right to life and personal liberty, essential elements undermined by media sensationalism. Similarly, the International Covenant on Civil and Political Rights protects freedom of speech while acknowledging the need for a fair trial process.

The Convention on the Rights of the Child recognizes children's right to freedom of expression, underscoring the role of the media in providing information to young individuals. However, this right is balanced against considerations of public order and interest.

Conferences and summits, such as the Madrid Principles and UNESCO's World Press Freedom Day, provide forums for discussing the delicate balance between freedom of speech and the integrity of judicial processes. The Madrid Principles emphasize the need to restrict media interference in criminal proceedings to prevent prejudice to defendants and uphold the presumption of innocence.

The World Summit on the Information Society and the International Telecommunication Union work to establish regulatory measures and international standards for information and communication technologies, promoting cooperation and infrastructure development worldwide.

Therefore, while freedom of the press is essential for democracy, it must be balanced with the principles of fair trial rights. International standards and conventions provide guidance on preserving these rights while ensuring the integrity of judicial processes in an increasingly interconnected world. By adhering to these standards, nations can navigate the complexities of media trials while upholding fundamental principles of justice and human rights.

VI. Effects of media trial on the right to fair trial: perspective on article 19 of the constitution

A noted jurist, F.S Nariman once said that “A responsible press is handmaiden of effective judicial administration. The Press doesn’t simply publish information about cases and trials but subject the entire justice hierarchy (Police, Prosecutors, Lawyers, Judges and Courts) as well as the judicial processes into public scrutiny. Free and robust reporting, criticism and debate contribute to public understanding of the rule of law, and to better comprehension of the entire justice system. It also helps to improve the quality of that system by subjecting it to the cleansing effect of exposure and public accountability¹⁸.

Understanding the concept of a trial is essential to take hold of the notion of a media trial. Although our legal codes don't explicitly define "trial," its general definition involves a formal examination of evidence by the court, typically overseen by judges, aimed at determining guilt in criminal cases and fault in civil ones.

In the context of media trial, it occurs when the media, based on evidence collected regarding a crime, publicly pronounces the guilt of an accused individual. This activity violates the judiciary's role as the entity responsible for dispensing judgment and ascertaining truth. The power of the judiciary to administer justice independently makes media trial activities beyond the jurisdiction of the media.

Media trial also refers to the influence of media, such as television, newspapers, and the internet, on the public perception of a crime, often leading to presumptions of guilt before any court verdict. High-profile cases frequently attract media attention, resulting in coverage that can impact the principles of fair trial and judicial procedure.

The origins of media trial can be traced back to the 20th century, notably in the US, where cases involving public figures like Roscoe "Fatty" Arbuckle and O.J. Simpson¹⁹ garnered significant media attention, affecting the reputations and outcomes of the accused.

In India, media trial has become increasingly prevalent, with numerous cases receiving extensive coverage that has influenced public opinion and legal proceedings. While media coverage has sometimes played a positive role in bringing attention to injustices, it has also led to prejudicial reporting and interference with the judicial process.

Examples include cases like Priyadarshini Mattoo²⁰ and Jessica Lal²¹, where media coverage prompted retrials and influenced verdicts. However, such coverage has also led to instances of prejudice, as seen in the Aarushi Talwar²² case, where the accused faced public condemnation despite later being acquitted.

Media trial's impact can be both positive and negative, but when it encroaches on the administration of justice, it poses a significant threat.

VII. Implication of media trial

(A) Media Trial and Freedom of Speech and Expression

Freedom of speech and expression, enshrined in Article 19(1)(a)²³ of the Indian Constitution, is a cornerstone of democracy. This right extends to the media, encompassing freedoms of circulation, publication, and access to public information. However, it's not absolute and can be curtailed under Article 19(2)²⁴ to safeguard public and state interests. Recent shifts in the interpretation of this right reveal a concerning trend where media, instead of being a force for public good, manipulates public opinion for sensationalism.

Examples like the Agrima Joshua²⁵ incident, where a comedian faced public backlash for a historical joke misconstrued by media, highlight how the essence of free speech is evolving. Similarly, the PewDiePie vs. T-Series²⁶ clash exemplifies how media provocations can incite public hostility, straying from constructive discourse.

The emergence of media trials, a phenomenon where media outlets pre-emptively convict individuals before legal verdicts, underscores a dangerous departure from journalistic responsibility. By assuming quasi-judicial roles, media undermines the judiciary's authority, disrupting the fair dispensation of justice.

(B) Media Trial and Privacy

Privacy, integral to personal liberty under Article 21²⁷ of the Constitution, faces unprecedented challenges in the digital age, particularly with social media's unregulated sphere. While laws like the Information Technology Act, 2005 provide some safeguards, the absence of robust data privacy legislation leaves individuals vulnerable to media intrusion.

Media exploits the right to information, often crossing ethical boundaries by exposing private matters without consent. Even as legislation like the Personal Data Protection Bill, 2019²⁸ is proposed, its exemptions for journalistic purposes fail to address the pernicious effects of media trial on privacy rights.

Precedents like the R. Rajagopal²⁹ case underscore the delicate balance between press freedom and individual privacy. Media's responsibility lies in exercising restraint, respecting personal boundaries, and navigating the nuances of public interest reporting without trampling on privacy rights.

(C) Media Trial and Defamation

Defamation, both civil and criminal, presents significant legal and ethical dilemmas in the context of media trial. Media's unchecked dissemination of unverified information can irreparably damage reputations, impacting livelihoods and personal well-being.

Instances like the Raj Kundra³⁰ case illustrate how media sensationalism exacerbates defamation, perpetuating false narratives and prejudicing public opinion. Such actions not only violate journalistic ethics but also undermine the presumption of innocence until proven guilty, a fundamental tenet of justice.

The judiciary's response to media trial must include stringent measures to curb defamation, ensuring accountability for irresponsible reporting. Civil and criminal statutes, like Section 499³¹ of the IPC, provide avenues for legal recourse against defamatory content, reinforcing the principle of justice and fairness.

(D) Media Trial and Legal Representations

Media trial not only subverts the legal process but also obstructs the ability of accused individuals to mount a robust legal defence. Lawyers representing the accused often face character assassination by media, hindering their professional integrity and impeding access to justice.

Renowned legal figures, such as Ram Jethmalani, have fallen victim to media scrutiny, highlighting the dire consequences of media trial on legal representations. By vilifying defence counsel, media jeopardizes the constitutional right to a fair trial and undermines the integrity of the legal profession.

Moreover, media interference in police investigations adds complexity to legal proceedings, impeding the pursuit of justice. The sensationalization of cases by media outlets pressures law enforcement, potentially compromising the integrity of investigations and eroding public trust in the legal system.

(E) Media Trial and Fair Trial

Media trial poses a grave threat to the principle of a fair trial, essential for upholding the rule of law and ensuring justice. By prejudicing public opinion and pre-emptively branding individuals as guilty, media trial undermines the presumption of innocence and erodes confidence in the judiciary.

Fair trial protections enshrined in various legal provisions, including the Contempt of Courts Act and constitutional safeguards, are essential for preserving the integrity of the legal process. However, media sensationalism often disregards these protections, perpetuating injustice and endangering the rights of the accused.

The doctrine of postponement, as endorsed by the Supreme Court, provides a mechanism to mitigate the prejudicial effects of media trial on fair trial rights. By allowing courts to delay media coverage in sensitive cases, this doctrine upholds the principles of justice and protects the sanctity of legal proceedings.

Thus, media trial represents a profound threat to the principles of justice, fairness, and democracy. By subverting legal norms, infringing on privacy rights, and undermining the rule of law, media trial undermines the very foundations of a democratic society. It is imperative for stakeholders, including legislators, judiciary, and media professionals, to collaborate in addressing this pressing issue and safeguarding the integrity of the legal system.

VIII. Conclusion & suggestions

Media plays an indispensable role in society, functioning as the fourth estate alongside the legislature, executive, and judiciary. It is a crucial source of information, fostering public awareness regardless of language or region, shaping public opinion, and safeguarding democratic values. Historically, the media in India emerged as a force for freedom, amplifying the voices of freedom fighters against British rule. This legacy underscores the media's pivotal role in informing and mobilizing the populace.

Post-independence, the framers of the Indian Constitution recognized the necessity of free speech and expression for the press, enshrining these rights under Article 19(1)(a). However, these rights are not absolute and can be restricted under Article 19(2) to prevent misuse. While a free and independent media is essential, its unregulated power can infringe on individual rights, such as privacy.

The contemporary media landscape has expanded significantly, leading to both positive and negative impacts. While it keeps the public informed about government actions and policies, it often oversteps by interfering in judicial matters, conducting trials by media, and potentially compromising the fairness of judicial proceedings. Such actions can prejudice public opinion, hinder the judicial process, and violate the accused's right to a fair trial.

Despite these challenges, media freedom remains vital for any democratic state. Completely curtailing this freedom due to media trials would be detrimental. Instead, regulation through appropriate legislation and the establishment of regulatory bodies with penal powers is necessary to balance societal and individual interests.

(A) Suggestions

Based on the above conclusion, the following suggestions are proposed:

1. Compensatory Provisions: Incorporate statutory provisions for substantial compensatory amounts in cases of media trials. Currently, the judiciary imposes costs in only a few cases based on violations of Article 21.

2. Priority for Postponement Cases: Address cases of postponement of publication on a priority basis to limit media interference in ongoing criminal trials.

3. Definition of Digital Journalists and Agencies: Statutorily define “digital journalists” and “digital news agencies,” and clearly distinguish between “offline” and “online” news media to facilitate better regulation.

4. Disclosure of Information Sources: Amend rules to allow the disclosure of information sources in appropriate cases before competent authorities.

5. Self-Regulatory Mechanism: Enhance the effectiveness of self-regulatory mechanisms like the News Broadcasters Association (NBA). The government should set regulatory standards but delegate enforcement to the regulatory body, similar to the UK model.

6. Annual Compliance Statements: Mandate the submission of annual compliance statements by media outlets to uphold responsible and ethical journalism, following the UK's example.

7. Mandatory NBA Membership: Require all news channels to join the NBA to extend the jurisdiction of the News Broadcasting Standards Authority (NBSA). Empower the NBSA to suspend licenses and impose heavy fines for code of conduct violations.

8. Appoint Appropriate Authorities: Under the Cable T.V. Network Regulation Act, 1995, appoint specialized authorities instead of District Magistrates to address the peculiarities of media-related matters.

These suggestions aim to strike a balance between preserving media freedom and ensuring responsible journalism, thereby protecting both public interest and individual rights.

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IX. References

• Dd Basu: “Law of the Press”
• Madhavi Divan Goradia: “Facets of Media Law”
• V.N Shukla: “Constitution of India
• Shohini Ghosh, ―Mistrial by media‖, Indian Express (October 14, 2017), available at:https://indianexpress.com/article/opinion/columns/mistrial-by-media-aarushi-talwar-murder-case-4889249/.
• Chakradhar Jha, History and Sources of Law in Ancient India 198 (Ashish Publishing House, New Delhi, 1986).
• P.V. Kane, History of Dharmashastra (Bhandarkar Oriental Research Institute, 1962).
• M. Rama Jois, Legal and Constitutional History of India: Ancient Legal, Judicial and Constitutional System 539 (Universal Law Publishing, Delhi, edn., 2001).
• H.V. Sreenivasa Murthy, History of India part-I 192 (Eastern Book Company, Lucknow, 2000).
• B.S. Jain, Administration of Justice in Seventeenth Century India 119 (Metropolitan Book Co. Private Ltd. Delhi, 1st edn. 1970).
• M.S. Sri Sai Kamalini, “Concept of Fair Trial” ILS (2019).
• F.S Nariman, Media and the Law, Seminar, University Law College, Vidhi Bhawan, University of Rajasthan, (Rajasthan - May 27th, 2006).
• The People of the State of California v. Orenthal James Simpson (1995).
• Santosh Kumar Singh v. State through CBI, (2010) 9 SCC 747.
• Siddhartha Vashisht @ Manu Sharma v. State (NCT Of Delhi), (2010) 6 SCC 1.
• Rajesh Talwar v. CBI, (2014) 1 SCC 628.
• Janhavi Sawant, “Agrima Joshua Announced Shivaji in Stand-Up Comedy Made the Netizens Furious”, Headlines of Today, July 11, 2020.
• Archit Mehta, “PewDiePie’s Diss tracks, PUBG and TikTok: Battle of Bans in India 2019”, The Hindu, April 23, 2019.
• Anurag Vaishnav, “Personal Data Protection Bill, 2019: All You Need to Know” PRS Legislative Research (2019).
• R. Rajagopal v. State of Tamil Nadu, (1994) SCC 6 632.
• Special Correspondent, “Raj Kundra Arrested in a Case Related to Creation of Porn Films”, The Hindu, August 6, 2021.

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