Press in a democratic setup is often regarded as the fourth pillar of democracy[1] and has since then acted as the voice of the people. There is a difference in the usage and the actual meaning of the term press. In the real world it refers to the print media which includes newspapers, journals, magazines, pamphlets, leaflets and the canopy of the press spreads over a multitude of different form of journalistic and mass communication aspect, with the advancement of technology the condition of newspapers and other print media can be seen deteriorating and the digital media is gaining more popularity. This has had a severe impact on the print media since.

Despite these changes there has been a body or an authority that has been governing the press. The press has been the voice of the people which can be seen in the Indian freedom movement from inciting the feeling of patriotism and nationalism to unifying the whole nation under a common cause. The Press, soon became a tool for the commoners in order to raise the voice, communicate their ideas and opinions, and reach the authority with grievances, and carrying the responsibility of keeping a vigilant eye on the government and the administration.

It came as a hope to these people that their voice will be heard. Overall, the press acted as a bridge between the Authority and the people. As stated earlier, it is clear that the press had played an active role in Indian freedom struggle though there has been instances where it had to face the wrath of the then British government, where several laws were passed in order to regulate and censor the facts being delivered to the common people, to times when presses were tried for serious offences such as sedition.[2]

Thus, the rich history of "Evolution of Press" in the background of freedom struggle of Indians from the Britishers and then as a question of "freedom of speech and expression", begs to be analysed. In the sections that follow, we will be discussing the historical background of Press laws in India, critically analysing the freedom of press through landmark judgements and the law of sedition all revolving around the central Idea of this paper, which is the "PRESS."

Historical background of The evolution of press in India
Indian Press has come a long way, and to get there it has witnessed a long and hard-fought battle with repressive laws at one time, to despotic, manipulative and down right anarchic rules and rulers at others. But to every great story is a beginning, albeit unassertive and humble. And that is, where we begin. The "Portuguese" were the first European country that brought a "Printing Press" to India back in 1556.

And the person who was responsible for setting up the new press was "Joao De Bustamante" who printed several books. The first book to be published in India was by "Jesuits of Goa" in 1557. Later on, it was the "East India Company" that set up a printing press in "Bombay" in 1684. However, the Press lay nascent for a long period of time as the "East India Company" was concerned that the newspapers could negatively affect their reputation in front of the Indian subjects as well as inform the Crown, back in England about the misuse of their powers.

But not all officers and servants of the "East India Company" were pleased. There were a few disgruntled employees who wanted to "publish" and "expose" the "company's" and its territories' malpractices. One such attempt was made by "William Bolts" in 1776, who was annoyed by the "Company's" Court of Directors and tried to publish a newspaper, but failed. In 1780, "James Augustus Hickey (considered as the Father of the Indian Press)" launched the first newspaper in India, the "Bengal Gazette" or "Calcutta General Advertiser." But because of his outspoken nature, his press was seized in 1782.

After that a few more attempts were made to publish newspapers such as: "The Calcutta Gazette 1784, The Bengal Journal 1785, The Oriental Magazine of Calcutta 1785, The Calcutta Chronicle 1786, The Madras Courier 1788, The Bombay Herald 1789", none of which were as brutal as critics of the "East India Company" as "James Augustus Hickey."

The 1790's were a period of unrest for the "East India Company" with the rise and coming up of more newspapers and journals that led to apprehension in the minds of the Company's officers that this development might bring their lavish and undisputed rule in India to an end, if word reached London of their gross misdeeds.[3] Thus, with the objective to curb this inconvenience several "Press Acts" were established which will be discussed in the following sections:

Censorship of Press Act, 1799
In anticipation of "The French Invasion" of India, "Lord Wellesley" enacted the act to stop the "French" from Publishing anything that could be detrimental to the reputation of the Britishers in India, thus imposing severe Press restrictions which included "Pre-Censorship." The act made it compulsory for all the newspapers to undergo rigorous scrutiny via the Government.

It stated that all newspapers from now on should carry the name of the printer, the editor and the proprietor and in case of any breach the violators will be dealt with harshly, even facing deportation in extreme cases. In 1807 the act was extended to include even books, magazines, pamphlets and journals. These restrictions were however relaxed under "Lord Hastings" when he came to power in the year 1818, all because of his modern and progressive view.

Licensing regulations, 1823
Enacted by the then acting "Governor General" John Adams, the act brought about various regulation with regards to the operation of press. According to the regulations, every publisher and printer is directed to acquire a license from the Government to start a press.[4] However, even if the permission was given for such developments, the government had every right to cancel the License, if and when it saw fit. Any person who defaults against these regulations shall be fined a sum of four hundred rupees and their press operation will be seized by the government.

The reason these restrictions were put in place was chiefly directed against "Indian vernacular language" newspapers or those edited by Indians. The Britishers were increasing wary of the growing essence of "Indian Nationalism" movements making headways all across the country. One prime example of this was "Raja Rammohan Roy's Mirat-ul-Akbar" which had to stop publication because of growing pressure from the Britishers.

The Press act of 1835
The act which also goes by the name of the "Metcalfe Act" was introduced by "Charles Metcalfe", after being dissatisfied by the grossly obnoxious "Licencing regulations ordinance" passed in 1823. This act was seen as a ray of liberation and thus earned Metcalfe a respectable title of "Liberator of the Indian Press."

The "Press Act (1835)" required:
"A printer/publisher to give a precise account of premises of a publication and cease functioning, if required by a similar declaration."

What this preceded was a period of rapid growth of Newspapers in lieu of the Liberal policy which was enacted. However, as all good things must come to an end, the "East India Company" annoyed by the liberal nature of this new act, pressurised Metcalfe to resign from his post as a Governor in 1836.

The Licensing act, 1857
Due to the "Revolt of 1857", this Act emerged, which imposed "licencing restrictions" in addition to the pre-existing "registration procedure" as established by the "Metcalfe Act". As in cases mentioned previously, in case of this act as well, the authority and power to prohibit the Publication and distribution of any form of print media be it newspapers, books or magazines was given to the Government.

The Registration act, 1867
The act was the successor to the "Metcalfe's act of 1835" and at its core was "Regulatory" in nature rather than being "Restrictive" like its predecessor. It formulated various rules under which the print media should function. The act made it mandatory for every article of print, be it a newspaper or a book to have the names of the printers, publishers and the places of publication, printed on them. And every published entity should be produced before the local government within the period of a month, since the original date of publication.

The Vernacular Press Act, 1878
Introduced by the then Viceroy of India "Lord Lytton" in whose words the Vernacular language newspapers were "mischievous scribblers preaching open sedition", "The Vernacular Press Act, 1878" came as a crushing blow to the freedom of "Vernacular Press" in India. Since its objective was to subdue the growing voice of Protest via Press in Vernacular languages of India, as well as to curb Seditious writings, it was also known as "The Gagging Act." It was "Lord Lytton" under whose leadership, some of the most controversial press policies were enacted in India. There were various provisions of the act as discussed below:

The "District Magistrate" was provided with the complete authority to strong-arm the "printer and publisher" of any "vernacular newspaper" to:

"Enter into a bond with the Government undertaking not to cause disaffection against the Government or antipathy between persons of different religions, castes, or races through published material."

Going against any of the regulations prescribed in the Act would lead to seizure of "Press Equipment," on top of which the printer and publisher were required to deposit security, which could be forfeited if the regulation were hampered in any way. The judgement of the "District Magistrate" was binding and no provisions for issuing appeals in court of law were present.

A "Vernacular Newspaper", however, may get exempted from this act on submission of proofs to a "Government Sensor." It was apparent on the very onset of the Act that it was discriminatory to the vernacular press, while turning a blind eye towards the English Press. Furthermore, there was no provision anywhere in the act for any form of appeal in case any party believed that they were discriminated against.

Under the "VPA" proceedings were started against various newspapers such as: "Som Prakash, Bharat Mihir, Dacca Prakash and Samachar." But there was no shortage of fightbacks from the opposition, a primary example of which is the story of how "Amrita Bazar Patrika" transformed into an "English newspaper" in the matter of a day to escape the pangs of the "VPA."

Later on, the "Pre-Censorship" clause of "VPA" was overruled, leading to the appointment of a "Press Commissioner" who's duty was to make way for genuine and up-to-date Press information. Despite the changes to the act, it had already done a lot of damage, thus leading to strong oppression from all corners leading to the act finally getting repealed by the Viceroy "Lord Ripon" in 1882.

However, this didn't bring an end to the problems faced by Indians, and rather gave way to another era of constant controversies fuelled by cry of freedom of Indians from one end to the vicious howls of Britishers on the other, a true power struggle.

It was in 1883 when "Surendranath Banerjea" was thrown in jail because of his critical comments on a Judge of the "Calcutta high court" via his editorial "The Bengalee Banerjea." In the editorial Banerjae talked about how the judge dealt insensitively with the religious sentiments of Bengolis in his judgements.

The growth of "Nationalist" sentiments among Indians wasn't a surprise to the Britishers, but it surely troubled the colonisers whenever discussion of brewing discontent among the colonised masses reached their quarters. One such case was of "Balgangadhar Tilak", who was an extreme nationalist who was fighting for the freedom of press by building "Anti-imperialist" emotions among the common masses via his newspapers "Kesari and Maharatta" as well as various religious festivals such as:
"Ganapati festivals (started in 1893), Shivaji festivals (started in 1896)" which acted as a means to glue the masses together and cause an uproar. He also organised various Campaigns from boycotting foreign garments in reply to "excise duties" announced on cotton to initiation of no tax campaign in Maharastra.

The Britishers were growing anxious of the recent developments and wanted to send a message to the Indians and thus decided to make Tilak their scapegoat. He was arrested in connection to the "Murder of Rand" by use of vague accusations on a poem "Shivaji's Utterances" and a speech by him, at a festival, where he had narrated those while justifying "Afzal Khan's murder by Shivaji." The Prosecution twisted the facts to portray his words in a way that indicated that he was trying to incite the public to kill the British officials. Tilak was declared guilty and was given "Eighteen months of rigorous imprisonment."

In 1898, The "British Government" amended "Section 124A" of the IPC which deals with the "Sedition Laws" in India, and also added "Section 153A" which made it a criminal offence for anyone: "to bring into contempt the Government of India or to create hatred among different classes, that is, vis-a-vis the English in India." This led to protests throughout the nation.

Newspaper (Incitement to Offences) Act, 1908
This act gave powers to magistrates to seize press property that published questionable material that was likely to incite murder/violence against Extremist nationalist activity.

Indian press act, 1910
"We are overwhelmed with a mass of heterogeneous material, some of it misguided, some of it frankly seditious."- Lord Risley

If reincarnations are considered as blessings, then "The Indian Press Act, 1910" is a disgrace in the name of reincarnations. Acting as a revived form of the "VPA" this act brought back the worst provisions of the older act. It was passed by "Lord Minto" on 8th of February 1910, after "Lord Risley" introduced the bill to empower local governments to demand "financial securities" in the range of 500 to 5000 rupees from the publishers and printers of newspapers to be deposited at the Magistrate's office, that will make these people vulnerable to confiscation of these securities in case of any breach to these provisions.

On top of this the newspaper agencies were directed to submit 2 copies of every issue of their papers to the local governments free of any change. Local governments also had the authority to close down any newspapers or form of print media as they wish. All these regulations were made to exercise control over the press and its publishers and to suppress any seditious print media to make its way into the lives of common people. Leaders like ""Balgangadhar Tilak" were tried on charges of sedition, leading to countrywide protests.

Indian press act, 1931
The British Government was still reeling from the aftershock of the "Civil Disobedience Movement, 1930" and in that hurried scramble, brought forth this act which provided sweeping powers to the government to supress any "Propaganda" surrounding the movement. It was extended to punish all such activities that undermines the authority of the "British rule"

Critical analysis of the freedom of Press in India
"Freedom of Press is an article of faith with us, sanctioned by our Constitution, validated by four decades of freedom and indispensable to our future as a Nation."- Rajiv Gandhi.

The phrase "Freedom of Press" can be found nowhere in the constitution but what exists under "Article 19(1)(a)"[5] is the "freedom of speech and expression". Dr. B.R Ambedkar, chairman of the "Drafting Committee" stated: "no special mention of the freedom of press was necessary at all as the press and an individual or a citizen were the same as far as their right of expression was concerned."

Every citizen of this democratic country is entitled to it and must exercise it as their right to liberty and freedom. The practice of lowering the voice of the press and molding it in a way that is convenient for the party in power has been perpetuated for so long that it has now become a custom. But like the truth which cannot be hidden, the voice of the people seeks various mediums through which it can reach out and the press acts as one of those mediums.

The very idea of "freedom of speech and expression" allows the propagation of differing views via written materials and/or orally. However, like an individual has the liberty to practice his or her rights but shouldn't act in a way that is detrimental to the rights of others, the press has certain limitations too.[6] These limitations or restrictions have been incorporated keeping in mind the interests of the public under "Article 19(2)" which states:

"Nothing in sub clause (a) of clause (1) shall affect the operation of any existing law, or prevent the State from making any law, in so far as such law imposes reasonable restrictions on the exercise of the right conferred by the said sub clause in the interests of the sovereignty and integrity of India, the security of the State, friendly relations with foreign States, public order, decency or morality or in relation to contempt of court, defamation or incitement to an offence."

In the sections that follow, a number of Landmark cases[7] that deal with "Freedom of speech and expression" will be analysed from the perspective of law.

Romesh Thappar v State of Madras
Romesh Thappar, a journalist and a known Marxist ideologue published an article in an English weekly journal in the state of Madras known as the "Cross Roads". The journal was mostly known for its criticism of the then Congress policies. Under the "section 9(1 A)" of the "Madras Maintenance of Public Order Act, 1949" Madras government banned the circulation of Cross Roads to maintain public safety and order of the state.

Thappar challenged the State Government and Section 9 (1 A), stating it is as the violation of his fundamental right under "Article 19 of the Constitution" which provides "Freedom of Speech & expression" under which he has the absolute right to Write and circulate his magazine. The State Government held the statement under "Maintenance of Public Order Act, 1949" an act for the security of the state and the decisions under it is for a "reasonable restriction" on the Freedom of speech and expression.

The State objected that the petitioner moving the Supreme Court directly exhausted the alternative remedy under Article 226 of availing the recourse under the jurisdiction of a high court. However, the Court held the decision that Security of the State is a reasonable restriction under the "Article 19(2)" of the Constitution. But restriction under the "Madras Maintenance of Public Order Act, 1949" was broader than what was permissible under The Constitution as a restriction on the Freedom of expression.

The Supreme Court of India held that the Freedom of Speech and expression also includes Freedom of propagate Ideas which also includes Freedom of Circulation of a Publication. Hence, the court held the emphasis on the word "Reasonable."[8] In "Re Daily Zemmedar" the final verdict as stated by the judiciary was that the media has the right to freedom of expression which cannot be curtailed and that media has every right to print facts.[9]

Brij Bhushan v State of Delhi
The Issue raised in the case was "Can Pre-Censorship or any Condition be laid down on the Freedom of Press & Expression?".

The Delhi chief-commissioner issued an order against the daily newspaper that before circulating the new regarding Communal topic or any News related to Pakistan the Press has to take the approval of the State Government. The Court nullified "Section 7(1)(c)" of "East Punjab Safety Act 1950" and held that the order is unconstitutional and Pre-Censorship cannot be imposed on a Publication body before its publication and unless justified it is violation in the eyes of law.[10]

Sharma v Srikrishna
One of the members of "Patna Legislative Assembly" used derogatory remarks in his speech. The Speaker ordered that the unparliamentary language and derogatory remarks should be removed from the speech and prohibited it from publishing. The Editor of a magazine published the entire speech. A notice was issued by the assembly that the Publication body prohibited the parliamentary privilege and necessary action should be taken against them.

The Supreme court held that there is no conflict between the two parties per se and the Fundamental Rights cannot over-ride the parliamentary privileges.[11] And that there should be a Harmony of Interpretations and the press cannot publish any proceedings without the consent of the speaker.

Furthermore, the Hon'ble Supreme Court has held that printing of views includes not only the editors' or authors' views, but also the views of any other people who have printed the views under the editor's, author's, or publisher's direction. The right to freedom of press includes not only the right to publish opinions, but also the right to disseminate and circulate those opinions throughout society. The freedom of the press is violated not only by a direct ban on the circulation of a publication, but also by a government action that would have a negative impact on the circulation of the paper.

Sakal Papers (P) Ltd. v Union of India
In this case an order was being challenged which regulated the number of papers in the newspaper, size & type of advertisements as well as the price remunerated for each paper. "Government of India" claimed that the news agencies could be restricted on the ground of "Article 19(6): restrictions upon the freedom to practice any profession in the interest of the general public." and that the government is just regulating the practices of trade and businesses.

Court held that freedom is not only with respect to the matter but also with the freedom of circulation. And thus, the number of papers and the number of people to whom it is circulated cannot be restricted. Court also said that under the "freedom of speech and expression" one cannot take away the rights of individuals in putting any form of restrictions on their commercial activity.[12]

Indian Express Newspapers v. Union of India
The "Supreme Court" emphasising the essence of "Freedom of Press" stated the following:

"The expression freedom of the press has not been used in Article 19 but it is comprehended within Article 19(1)(a). The expression means freedom from interference from an authority, which would have the effect of interference with the content and circulation of newspapers. There cannot be any interference with that freedom in the name of public interest."

This case discussed "Article 19(1)(a)" of the "Constitution of India," which stands for freedom of expression, as well as the "reasonable restrictions" covered by "Article 19(2)." The "Supreme Court" requested that the Central Government review its taxation policy to determine whether it is putting a strain on the newspapers. The petitioners contended that because of the import duty, the price of the newspaper would inevitably rise, resulting in a decrease in overall circulation.

The Supreme Court ruled that the government can levy taxes on publications as long as they adhere to the "reasonable restrictions" outlined in "Article 19(2)," and that this does not infringe on their freedom of expression.[13] The Court also stated that because both the petitioner and the respondent failed to prove the excessive nature of the tax, it is now the government's responsibility to review the taxation policy.

Bennett Coleman & Co. v Union of India
The constitutional validity of the "Newsprint Import Policy 1972" or "Newsprint Control Order 1962" was challenged as the news print sector announced numerous restrictions, such as limiting the number of pages that could be published to ten as well as the advertisements making it tough for the publisher to publish news and adverts in a manner, they saw fit. The 1973 "Newspaper Regulation Policy" was challenged because of violating "Article 19(1)(a)". The Supreme Court ruled that this policy was unconstitutional and overturned it also stating how the restrictions imposed were not true to those of "Article 19(2)".

The Court stated that the people who publish a newspaper with fewer than ten pages and those who publish a newspaper with more than ten pages should be treated equally. It went on to say that the governments restriction on pages causes the individual's source of income to be restricted as well. It was also held that newspaper companies have complete control over the number of pages, the number of people who receive the newspaper, and the price of the newspaper. Thus, "Supreme Court" held that the Freedom of press is both "qualitative and quantitative" in nature and that Freedom lies in both "circulation and content".[14]

Analysing Freedom Of Press In India Through The Global Press Index
The Indian media has become the subject of mockery on global media forums, all stemming from the mere fact of thinly veiled illusion of true freedom. To understand this all one needs is to take a look on the "Global Rankings of Press freedom Index." The current rank of India is 142 out of 180 in the freedom of press index produced by Reporters without Borders (RSF), a French NGO. India was placed at 133 in 2016 and since then it has been climbing down and now it is at 142 and has maintained the same position since last year.

This is an adverse assessment for the largest democracy in the World and has impacted India's rank in the democracy index too. India's rank is now 53 out of 167 countries and has been classified as a flawed democracy, according to the global ranking released by the Economist Intelligence Unit (EIU). This is the nadir of the world's largest democracy.

The recent press conference with the senior leaders of the ruling party has shown how the media has been acting in front of them. The media was supposed to bring forward the grievances of the people instead the questions that were asked were vague and ancillary things. The Indian media has become the watchdog of the current regime and has forgotten the true objectives it set out to achieve.

Sedition Laws
Sedition laws under section "124 of the IPC" were implemented back when "Criminal Law" was codified in India after the "Revolt of 1857." In 1860, "Indian Penal Code" was introduced by "Lord Macaulay" but had no mention of "Section 124 A", it was in 1870 when the IV Chapter of IPC was introduced which talked about Offences against the State. Sedition laws are implemented to stop any entity that imposed a threat to the Government or was capable enough to cause an uprising against the Government.

The formation of sedition laws has a history filled with unjust and immoral actions. It came into existence in India, when the Britishers imposed strict laws against the freedom fighters to mute their voices and prevent it from spreading nationwide. The press played a major role as the perpetrator of these ideas and thus needed to be silenced. Right after India achieved its freedom, the constitution faced a dilemma of whether to continue or abolish the sedition laws.

Owing to the dissent against Sedition laws by eminent members and stern critics of the law, such as K.M Munshi and Bhupinder Singh Mann, it was removed from the constitution. But it lasted for a short span owning to its re-introduction in the first amendment under Jawaharlal Nehru. The Sedition laws have taken a negative form because of their incapability of defining what kind of actions are rendered seditious and what are not.

There have been several arguments and discussions on it, but have not led to any consequence as such. It is because of its nature that it has become kind of open to interpretation and is even moulded by the administration in ways that best suit their motives.[15] As stated by eminent figures such as "Justice Chandrachud", "Expression of views which is dissent and different from the opinion of the government cannot be termed seditious."

Contrary to this statement, Sedition law is now being held as a threat to "freedom of speech and expression". As evident by the arrest of the "journalist Vinod Dua", the administration has tried to carve the Sedition law into a weapon that forces citizens to comply with the government and hampers all sorts of protest and dissent against it. It is now on the verge of becoming a threat to democracy and needs immediate reforms.

Conclusion and Future Prospects
For the smooth functioning of the democracy there should be freedom of press which has inadvertently become the integral part of a democracy. The Indian constitution grants the right to freedom of press under the "article 19(1)(a)" which talks about the "freedom of speech and expression". The freedom of press is what makes the press the fourth pillar of a democratic set up which implies free flow of information and data to the citizens of the nation.

The press acts like a media between the Government and the citizens for the free flow of data and information and at times it is the voice to the usually considered mute public. If there is absence of freedom of press then it would create havoc in the state, and the state will slowly shift towards dictatorship or monarchy from being a democratic republic.

In the current scenario in India, it is palpable that the freedom of press is gradually fading. From being the voice of the people, the press has become a mere tool of the government to feed the people with the information that will favour the government in spreading its propaganda.

The government uses the press as a tool to consolidate the power and rule over the people and make the wrongs look right. In the recent times the amount of fake news and data are being circulated has increased substantially that it can be observed just by watching them, a mere peek in the news channel will tell you how ridiculous they sound.

It has become so pervasive that people have started buying that information. These trends in the news and the press have done nothing but has helped the government in achieving its agenda. So much so that if one questions the government they are immediately, without any delay labelled as an anti-national, these things have plummeted to such an extent that the proceedings are heard in the court room but the verdicts are delivered in the studios of the press houses.

It is high time for the citizens to become aware about how these repressive laws are moulding their lives, and chipping away from their sense of freedom in all walks of lives. The Laws warrant a much-needed transformation which is only possible if the citizens come together and voice their opinions and make the government hear them out, and bring in legislations that uphold the sanctity of our constitution as well as uphold our fundamental rights.

Bibliography:

• Rai D, 'The Fourth Pillar Of Indian Democracy: Freedom Of The Press' (iPleaders, 2021) accessed 14 December 2021.
• Soni K, 'Freedom Of Press - Indian Constitution' (Legalserviceindia.com, 2021) accessed 13 December 2021.
• 'History Of Journalism - Editors Guild Of India' (Editors Guild of India, 2021) accessed 12 December 2021.
• Gupta M, 'Freedom Of Press In India' (Legalservicesindia.com, 2021) accessed 14 December 2021.
• Malik R, 'Landmark Judgement On Freedom Of Press' (Legal Desire, 2021) accessed 13 December 2021.
• 'Pre-Independence Regulation Of Indian Newspapers' (Thehansindia.com, 2021) accessed 13 December 2021.
• Sapra T, 'Freedom Of Press & Media: All The Important Cases And Landmark Judgements - Law Circa' (Law Circa, 2021) accessed 14 December 2021.
• Singh M, 'Freedom Of Press - Article 19(1)(A)' (Legalservicesindia.com, 2021) accessed 14 December 2021.
• 'Media And Sedition: On Supreme Court Relief To Journalists' (The Hindu, 2021) accessed 14 December 2021.

End-Notes:

1. Diva Rai, 'The Fourth Pillar Of Indian Democracy: Freedom Of The Press' (iPleaders, 2021) accessed 14 December 2021.
2. Kriti s Soni, 'Freedom Of Press - Indian Constitution' (Legalserviceindia.com, 2021) accessed 13 December 2021.
3. History Of Journalism - Editors Guild Of India (Editors Guild of India, 2021) accessed 12 December 2021.
4. Pre-Independence Regulation Of Indian Newspapers' (Thehansindia.com, 2021) accessed 13 December 2021.
5. Manmeet Singh, 'Freedom Of Press - Article 19(1)(A) (Legalservicesindia.com, 2021) accessed 14 December 2021.
6. Mayukh Gupta, 'Freedom Of Press In India' (Legalservicesindia.com, 2021) accessed 14 December 2021.
7. Rashi Malik, 'Landmark Judgement On Freedom Of Press' (Legal Desire, 2021) accessed 13 December 2021.
8. Romesh Thappar v State of Madras, AIR 1950 SC 124.
9. Tanvi Sapra, 'Freedom Of Press & Media: All The Important Cases And Landmark Judgements - Law Circa' (Law Circa, 2021) accessed 14 December 2021.
10. Brij Bhushan v State of Delhi, AIR 1950 SC 129.
11. Sharma v Srikrishna, AIR 1959 SC 395.
12. Sakal Papers (P) Ltd. v Union of India, AIR 1962 SC 305.
13. Indian Express Newspapers v Union of India, 1985 SCR (2) 287.
14. Bennett Coleman & Co. v Union of India, 1973 SCR (2) 757.
15. Media And Sedition: On Supreme Court Relief To Journalists' (The Hindu, 2021) accessed 14 December 2021.