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Anuradha Basin v/s Union Of India: An Analysis based on Natural Law

Natural law is often depicted as an abstract structure suspended in the heavens, of which positive law is merely a doppelganger. Man's law of self-preservation or an operative law of nature constraining man to a certain course of conduct has been envisioned as the natural law. Article 19 of India's constitution grants certain human rights.

Article 19(1) states the freedom of speech and expression.[1] India, is the world's most populous country and has the world's largest democracy. It has a broad need to safeguard the freedom of speech and expression. After a major element of American jurisprudence, the right is taken from English law. �Article 19(1)(g) provides rights to practise any profession or to carry on any occupation, trade or business.[2]

Under Section 144 of The Code Criminal Procedure, Any executive magistrate empowered by the state has power to issue orders in urgent cases of nuisance or apprehended danger.[3]

In the case of Anuradha Basin Vs Union Of India writs were filed due to the violation of these fundamental rights after the suspension of internet services in Jammu and Kashmir. The Indian Supreme Court ruled that an arbitrary closure of internet access would be unconstitutional under Indian law, and that directives to close down the internet would pass the requirement and proportionality checks. The case concerned internet and travel restrictions levied on August 4, 2019 in India's Jammu and Kashmir area in the name of maintaining public order.

However, the Court did not remove the internet limits, instead directing the government to revisit the shutdown directives under the criteria laid out in its decision and lift those that were not required or had no time limit. The Supreme Court reaffirmed that the Constitution protects online freedom of expression, but that it can be limited in the interest of national security. Despite the fact that the government has the power to fully shut down the internet, the Court held that any decree enacting those restrictions had to be made official and was open to judicial review.

This research is for analyzing the case and draw a link to natural Law.

Anuradha Basin v/s. Union Of India -(2020 Scc Online Sc1725)
Judges/ Bench - N.V. Ramana, V. Ramasubramanian - Supreme Court, January 2020

Review Of Literature
  1. Professor R.W.M, Dias writes that the natural Law theory has a history reaching back centuries B.C. and the vigor with which it flourishes is a tribute it's vitality. There is no one theory of natural law and there are many versions of it. However, there is no other firmament of legal or political theory which is bejeweled with the stars as that of natural law which scintillates with contributions from all the ages.

    The term natural law has been understood to mean a variety of things to different people at different times viz., ideals which guide legal development and administration, a basic moral quality in law which prevents a total separation of the 'is' from the 'ought', the method of discovering perfect law, the content of perfect law deducible by reason and the condition sine quibus non for the existence of law.

    There are wide differences among those who are normally classes as naturalists and positivists. Natural Law thinking in one form or another is pervasive and is encountered in various contexts. Natural Law theory has tried to meet e-paramount needs of successive ages throughout history.[4]
  2. According to a Greek thinker Plato, God gave humanity a sense of justice and ethical respect in equal measure so that they could create a lasting union of collective preservation in the struggle of life. He discovered the essence of practical existence in the primal ethical feeling that drives men to unite in community and state. Since a man is a product of nature, he should be able to put his skills to use.
  3. Under the colonial era, the liberties of the Indians were at a complete stake. The atrocities of the British Empire actually curbed the freedom of expression and speech of the Indian masses. From the Sedition laws imposed by the English in 1870 to Section 295A of the Hate speech law, the British took every possible way to curb opinion making among Indians in order to suppress the revolutionary sentiments prevailing the masses to an independent struggle.

    The Prevention of Seditious Meeting Act, 1907 [5] which prevented open discussions and formation of Unions was also the driving force behind the very fundamental freedom of speech and expression being guaranteed to the citizens which they were earlier deprived of. The framers and the architects of the Constitution of India have also borrowed the idea of freedom of speech from the democratic ideas laid in the American Constitution. Freedom of speech and expression is a significant feature of the American Constitution.
  4. Article 19 of Universal Declaration of Human Rights �Everyone has the right to freedom to opinion and expression[6]. This privilege applies to anyone with a view, thoughts, or knowledge and the ability to communicate with them through any medium, despite their location.
  5. Aquinas speaks of these basic goods as:
    Those things to which man has a natural inclination leading some to claim that natural law bases moral norms on sub-rational desires inherent in human nature, thus denying the Humean fact-value distinction by implying that an ought can be derived from a mere is.[7]
  6. The European Court of Human Rights has noted:
    Freedom of expression constitutes one of the essential foundations of a democratic society, one of the basic conditions for its progress and for the development of every man.[8]
  7. (Goel, 2018) The Indian legal system has many clauses that support the government's decision to ban internet services. The first degree of safeguarding' is built into the contract's terms. Internet and mobile service providers are often required to sign contracts with policy providers, which require the providers to suspend services through relevant notifications and make it mandatory for the providers to comply with such notices.
  8. Right to access and distribution of information, the right to access and distribution of information [9] has been protected under freedom of expression enshrined in Article 19(1)(a)[10] of the Indian Constitution. In one of the landmark judgments of Maneka Gandhi Vs UOI,[11] The Indian Supreme Court ruled that basic rights should be widely understood and rights secured. Afterwards, the internet is an offshoot of free speech rights.

    In the case of Shreya Singhal vs UOI,[12] The Court acknowledged the Internet as a critical medical for the promotion of the constitutional right to freedom of expression and freedom of speech.
  9. Internet Shutdowns in India are governed by two laws:
    Section 144 of the code of criminal procedure of 1973[13] and Section 5 of the Indian Telegraph Act of 1885 [14] in consonance with the Temporary Services (Public Emergency and Public Safety).
  10. Article 13 of American Convention on Human Rights:
    Everyone has the right to freedom of thought and expression. This right includes freedom to seek, receive, and impart information and ideas of all kinds, regardless of frontiers, either orally, in writing, in print, in the form of art, or through any other medium of one's choice.[15]

Facts Of The Case / Background
Jammu and Kashmir are Indian territories which border Pakistan, subjecting the two nations to a decades-long dispute. Under Article 370[16] of the Indian Constitution, The region had a special status and was not permitted to buy land or property under its own Constitution and the Indian people of other States of the nation.

The matter begins with a Civil Secretariat, Home Department, Jammu Government and Kashmir security advisory announcing that the stay will be shortened and their safe arrangements made. In the meantime, schools and workplaces were also shut down before further directives were received. Up until further orders, internet services, telephone connectivity and the flag were shut down.

The President of India was issued the Constitutional Order No. 272 extending to Jammu and Kashmir all terms of the Indian Constitution, excluding it from separate status that had been in force since 1954. On the same day the District Magistrate passed an order limiting the movement and public meetings, and apprehending violations of harmony and tranquilly due to the prevailing conditions under Section 144 of CrPC.[17]

As a result, the movements of journalists were limited and challenged by Article 19[18]of the Constitution which guarantees freedom of speech, expression and trade or occupation. The internet interruption and restrictions of movement (restrictions) restricted journalists' right to travel and to report and were consequently challenged by court for their violations of Article 19 [19] of India's Constitution which guarantees the right to freedom of expression.[20]

W.P.(C) No. 1031 of 2019
  • Ms. Anuradha Basin submitted this request. She was Kashmir Times executive editor Srinagar, arguing that the internet was vital to the modern newspaper. By stopping it, the authorities have pressured the press to stop. Since then, because of these, her newspaper has not been published. The government itself did not understand the reasonableness and proportionality of the internet shutdown. She argued that the restrictions were passed in the belief that there would be �a danger to law and order.[21]The public order, though, is not identical to law and order and was not at risk until the order was passed.
  • The point of the appellant was that the government did not have a legitimate explanation why an order could be issued as provided by the rules of suspension. She further indicated that it was purely on the basis of sheer fear of danger from practitioners of law and order who had not passed such orders. The petitioner's argument was that the Government has to find a way to reconcile, on the one hand, national security policies and citizens' rights. The State, however, lays the foundation for passing the order restricting citizens' rights. He claims that limitations should be temporarily enforced, but that they should be applied over longer than 100 days.
  • An intervener argued that the steps needed to safeguard national security and to curb terrorism need to be balanced into the interests of civilians adopted by courts of different jurisdictions. By stating the situation in Jammu and Kashmir, the state is justifiable and justifying rejections, given that it gives the state too large powers in certain circumstances to enforce restrictions.

    It subsumes the interests of individuals over social order. He submitted that restrictions imposed are in contravention of Indian National Telecom Policy, 2012. [22]Lastly, the Commissioner pointed out that the limits introduced were provisional in nature but they are being imposed for over 100 days.
  • Another intervener suggested that under the conditions on which the dominant directives were passed the importance of testing the order. Natural justice also includes the need to publish orders and make them available to the public. For failure to deliver decisions, the State cannot invoke any immunity before the Court. In addition, he said that the Court upheld the proportionality test which could be seen as a fair or unreasonable constraint on citizens' constitutional rights. He also pointed out that:
    It is not just the legal and physical restrictions that must be looked at, but also the fear that these sorts of restrictions engender in the minds of the populace, while looking at the proportionality of measures.

W.P.(C) No. 1164 of 2019
  • Mr Ghulam Nabi Azad submitted the request (Member of Parliament). He maintained that there was no derogation or right for the State to issue the directives before the courts. He also said that in a restricted situation it was possible to report a national emergency, but that there was no need to declare an emergency in the present case for any �internal disturbance or �external attack. To pass order under �Section 144 of CrPC,[23]A 'law and order' condition must arise in which there is in this case no actual problem or fear of legislation and order. Restrictions on the community of persons arrested in order to violate peace should be placed individually and not the state as a whole. The state has to implement the least restrictive legislation and to align citizens' basic rights with people's welfare. It also affects the free speech and right to carry out any trade, profession, profession or career by putting limits on the internet.

W.P. (Crl.) No. 225 of 2019
  • In certain countries, the appeal was removed but the Court acknowledged that the prohibitions caused extensive damage even to ordinary citizens. The restraints were advocated by the Indian Attorney General and Solicitor General.

Order as part of natural justice must be published and also made available to the public in general. The state cannot assert right with no other judgements before the court. In addition, the Court upheld the proportionality test which could be seen to be fair or unreasonable limitations on citizens' constitutional rights.

The Solicitor General, Mr Tushar Mehta, said the aim was to protect the people, who are the primary responsibility of the State. He saw these directives as important for stability in the state.

He argued that, based on current conditions, these directives are routinely relaxed.

The judges reasoned that almost complete relaxation was previously enforced on the basis of the interpretation of a challenge. Both TV, radio and journals run also where the petitioner works. All TV stations are functional. The orders passed under �Section 144 of CrPC[24] can be preventive for the safety of the citizens. HeHe argued that separating those who are agitators from peacemakers is not possible. He maintained that in Jammu and Ladakh the internet had never been restricted. Nevertheless, posts from social media can be sent and received for kerfuffle.

In certain countries, the goal was to censor the Internet, not just social media but the dark internet, which enables illicit firearms to be sold and bought. He concluded that all the directives passed were subject to the suspension rules protocol and are subject to stringent scrutiny.

  • On August 2, the Civil Secretariat, Home Department, Government of Jammu and Kashmir, advised tourists and Amarnath Yatra pilgrims to leave the Jammu and Kashmir area in India. Subsequently, schools and offices were ordered to remain closed until further notice.
  • On August 4, 2019, mobile phone networks, internet services, and landline connectivity were all shutdown in the region. The District Magistrates imposed additional restrictions on freedoms of movement and public assembly citing authority to do so under �Section 144 of the Criminal Penal Code.[25]
  • The issue begins right from 05.08.2019, when Constitutional Order 272 was issued by the President, applying all provisions of the Constitution of India to the State of Jammu and Kashmir, and modifying �Article 367[26], the Interpretation of it in its application to the State of Jammu and Kashmir.
  • The petition W.P. (C) No. 1031 of 2019, was filed by Ms Anuradha Bhasin. She was the executive editor of the Kashmir Times Srinagar Edition who argued the internet to be essential for the modern press. The petitioner pointed out that print media could come to an end without the internet since the newspaper had not been published from 06.08.2019.
  • The subsequent petition W.P. (C) No. 1164 of 2019 was filed by Member of Parliament, Mr Ghulam Nabi Azad, whose argument was that the state cannot claim any kind of privilege before the court for not producing such orders.
  • On the other hand, the respondent sided Mr K.K. Venugopal the Attorney General submitted that the condition of Jammu and Kashmir having militancy has to be taken into account.

  • Government's action of prohibiting internet access was violating freedom of speech and expression as a natural law or not.
  • Is the freedom to press and access to the internet equivalent as natural law or not.

  1. Article 19(1)(a) of Indian Constitution
    This article gives rights to freedom of speech and expression to every citizen of India.[27]
  2. Article 19(1)(g) of Indian Constitution
    This article gives rights to practice any profession, or to carry on any occupation, trade or business.[28]
  3. Section 144 The code of Criminal Procedure, 1973
    Section 144 of the Criminal Procedure Code (CrPC) of 1973 authorized the Executive Magistrate of any state or territory to issue an order to prohibit the assembly of four or more people in an area.[29]

Section 5 The telegraph Act 1885
This section provides power for the Government to take possession of licensed telegraphs and to order interception of messages.[30]

Article 19 of Universal Declaration of Human Rights
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.[31]

Research Analysis And Discussion
Freedom to speech and expression under Article 19 (1)(a)[32] of Indian Constitution is a fundamental law provided to every citizen of India. Freedom to opinion and expression is a human right declared under Universal Declaration Human Rights Article 19[33].These rights are governed by the nation as well as the United Nations.

In India with the case of Shreya Singhal Vs Union of India,[34] The Court acknowledged the Internet as a critical medical for the promotion of the constitutional right to freedom of expression and freedom of speech.

The fundamental right of freedom to Press under freedom to speech and expression - �Article 19(1)(a)[35] is not specifically mentioned in the article of the constitution. Dr. Ambedkar, Chairman of the Drafting Committee, clarified in the Constituent Assembly debates, that no particular attention to press freedom was required because the press and an individual or a resident are identical as regards their right to express themselves.

In the Article 19(1)(a) [36]of Indian Constitution, the fathers viewed press freedom as an integral aspect of freedom of expression. In the case of �Romesh Thapar Vs State of Madras[37] and Brij Bhushan vs State of Delhi,[38]

The Court considered it an integral element of the right to freedom of expression and expression to be freedom of the press.

It was observed by Justice Patanjali Sastry in:
Romesh Thaper case that freedom of speech and expression included propagations of ideas and that freedom was ensured by the freedom of circulation.[39]

Democratically speaking, the free expression of opinions and opinions by people with their own analyses is important to people. The press is one of the strong expressive media and should be free to play its part in creating a strong, viable community. Denying people freedom of the press will inevitably diminish democratic influence and counter democracy.

Thomas Jefferson's famous declaration:
Were it left me to decide whether we should have a government without newspaper or newspaper without government, I should not hesitate a moment to prefer the latter. [40]

Equality of speech and expression is a natural rule, rather than a vicious one for democracy. Language is the gift of God to mankind. A person transmits his ideas, emotions and feelings to others through speech and expression. Freedom of expression and freedom of speech is therefore a fundamental right earned by an individual at birth. Consequently, it is a fundamental right. Equality of expression and speech was considered the first prerequisite of freedom. It holds a significant and preferential place in the hierarchy of rights; about freedom of expression it is actually claimed to be the mother of all other freedoms.

Freedom of speech and expression means the right to express one's own convictions and opinions freely by words of mouth, writing, printing, pictures or any other mode. It thus includes the expression of one's ideas through any communicable medium or visible representation, such as, gesture, sighs and the like.[41]

It is generally agreed in modern times that the right to freedom of expression is the cornerstone of a free society and must therefore be guaranteed. An unbroken exchange of words in an open forum were the first principles of a democratic society.

Human rights are regarded as freedom of speech and expression. The principle of human rights as of law in general demands the true philosophical connotation of the word, which was defaced by the rationalism of the eighteenth century, in its realistic dynamism and modest reliance on nature and experience. The essence of the human being and culture is at the roots of human rights.

In the universe of experience, tradition and truth, it imposed a moral obligation that can be uniformly acceptable and that can provide the constant precept, the primal, the general principles of right and duty, as well for conscience and written law. Natural law to be completed by the contingent disposition of human nature as appropriate for time and situation.

The notion of natural law has been used in such a way that many minds declare themselves wearied of this thought in our day, it is not shocking. The tradition of civil rights and the history of common law have become one since Hippias and Alcidamas. As Mr. Laserson wrote �The Doctrine of natural law must not be confused with the natural law itself.

The doctrine of natural law, like any other political and legal doctrines may profound various arguments or theories in order to substantiate or justify natural law, but the overthrow of these theories cannot signify the overthrow of natural law itself, just as the overthrow of some theory or philosophy of law does not lead to the overthrow of law itself.

The victory of juridical positivism in the nineteenth century over the doctrine of natural law did not signify the death of natural law itself, but only the victory of the conservative historical school over the revolutionary rationalistic school, called for by the general historical conditions in the first part of the nineteenth century.

The best proof of this is the fact that at the end of that century the so-called "renaissance of natural law" was proclaimed.[42]Human rights and natural rights have shown to be related, and it is also true to state that freedom of expression and speech is a natural law.

In the Case of Anuradha Basin Vs Union of India,[43] Internet blackouts were enforced by the authorities. Technology is increasing in every field with the progressive nature of the world. The post lockout was locked with three writs. Two writings focusing on breaches of press freedom and the freedom of expression and speech.

Freedom of expression absolutism is, firstly, a stance which lacks a foundation for Founders' political ideology, the original public significance of the Free Speech Clause or the fact that only a person able to restrain his zeal can safeguard self-government. The desire to see principled distinction between a speech which can injure a republican government's civil virtue and a critical discourse for a republican government is transferred to moral nihilism.

Instead of emphasising the lack of acceptance of absolutism in our Foundation or for self-government conditions, the Right seems to be attractive in terms of the radical anti-conservative militancy of the main cultural movements. Yet fear of distinguishing the principle is not a conservative principle. Conservatives interested both in preserving the Constitution and in the principle of freedom embodied in it have reason to reconsider an absolutist freedom of speech.

In the case of Indian Express V. Union of India[44] proclaimed the right to print proclaimed independence is an integral right under Article (19)(1)[45]. The internet is a basic right of the article, and the freedom of speech and expression is a constitutional right to broadcast information via the internet. The Law can enforce fair constraints, however.

The Court holds that freedom of expression and speech under �Article 19 (1)(a)[46] and Constitutionally covered is the use of the medium to communicate views. In addition to maintaining peace and calm, the Court will notice that freedom of speech and expression should not impose an undue pressure.

The court refused the plea calling the freedom of the press into question. It is undoubtedly one of the main features of a society so well preserved by the Constitution there is freedom of the press. The complainant could not provide proof that the state order placed limits on press rights, including the publishing and circulation of newspapers.

In addition, the Court found that the internet ban would only be applicable in some conditions otherwise. Thus, the court ordered the proportionality test to see that no breach of natural justice occurs. This imposition affects the people's fundamental rights.

But the judgement extended an understanding of freedom of speech and expression by including the right to access the Internet, an integral aspect of the Article that was limited only in the context of national security. The Court did not lift limitations on the internet or the travel of people.

This decision did not immediately alleviate the people impacted by these orders, but set down the principles for subsequent suspension orders and their procedures in order to avoid the misuse of authority by the State. This is a solution to additional problems.

With the understanding of this case with the base of Natural Law, the internet plays a crucial role in this period. With the pandemic most of the activities are conducted through online platforms. Until 6 months post the judgement no new regulations for internet shutdown was published. Knowing that schools across the country are conducting classes online. This internet shutdown might be affecting their education. Freedom to education can be another human right and natural law which could be discussed.

  • Anuradha Basin v/s Union of India (2020) SCC OnLine SC 1725
  • Brij Bhushan And Another vs The State Of Delhi 1950 AIR 129, 1950 SCR 605
  • Lowell v. Griffin, (1939) 303 US 444.
  • Indian Express Vs. Union of India (1985) 1 SCC 641(India)
  • Shreya Singhal Vs Union of India (2015) SCC 1 (India)
  • Romesh Thapar V. State of Madras 1950 AIR 124, 1950 SCR 594
  • India Const. art. 367
  • India Const. art.19, cl. 1 (a)
  • India Const. art.19, cl. 1 (c)
  • India Const. art.19, cl. 1 (g)
  • Sec. 144, The Code of Criminal Procedure 1973, No. 2, Act of Parliament, 1973 (India)
  • Universal Declaration of Human Rights art.19
  • V.D. Mahajan Jurisprudence and Legal Theory 595-632 (4th ed. EBC 1987)
  • Yacine Ait Kaci Universal Declaration of Human Rights 4 UDHR 40 (2015)
  • Jacques Maritain, Man and the states 80-81 The Chatolic University of American Press 1878
  • Aquinas, Thomas, Summa Theologiae, I-II, q.90-97
  • Handyside v. United Kingdom, 7 December 1976, Application No. 5493/72, 1 EHRR 737, para. 49.
  • Thomas Jefferson Extract from Thomas Jefferson to Edward Carrington Quotes by and about Thomas Jefferson (January 16, 1787
  • Anuradha Basin Vs. Union of India Global Freedom of Expression (2020)
  • Amesha Kaur Gupta Natural Law and Rights Research Gate (November 2019)
  • Bhavya Arora Anuradha Bhasin v/s Union of India Legal Service India (2020)
  • Ayush Verma Anuradha Bhasin Vs Union of India- Case Analysis iBlog Pleader (April 15, 2020)
  • Legal Positivism vs. Natural Law Theory
  • Anubhav Pandey Evolution of Freedom of Speech under the Indian Constitution iBlog Pleader (September 4, 2017)
  • David S. Bogen The Origins of Freedom of Speech and Press Vol. 42 Issue 3 Maryland Law Review (1983)
  • Pradyumna K. Tripathi Free Speech in The Indian Constitution: Background and Prospect vol. 67: 384 YALE LAW JOURNAL
  • Right To Freedom Of Speech And Expression Vis A Vis Freedom Of Press Indian Institute of Legal Studies,pictures%20or%20any%20other%20mode.
  • Felix Morley The Natural Law and The Right to Self Expression National Law Institute Proceedings 77 (97-98)
  • Gehan Gunatilleke Justification of Limitation on the Freedom Of Expression Human Rights Review (November 01, 2020)
  • Robert P. George Recent Criticism of Natural Law Theory The University of Chicago Law Review vol.55 1371
  • Philip A. Hamburger Natural Rights, Natural Law and American Constitution Columbia Law School Review (1993)
  • Aqa Raza Freedom of Speech and Expression as a Fundamental Rights in India and the Test of Constitutional Regulation: The Constitutional Perspective 22
  1. India Const. art 19, cl. 1(a
  2. India Const. art.19, cl. 1 (g)
  3. Sec.144 The code of Criminal Procedure, 1973,No. 2, Act of Parliament, 1973 (India)
  4. V.D. Mahajan Jurisprudence and Legal Theory 595-632 (4th ed. EBC 1987)
  5. The Prevention Sedition Act, 1907 Act of Parliament 1907 (India)
  6. Yacine Ait Kaci Universal Declaration of Human Rights 4 UDHR 40 (2015)
  7. Aquinas, Thomas, Summa Theologiae, I-II, q.90-97
  8. Handyside v. United Kingdom, 7 December 1976, Application No. 5493/72, 1 EHRR 737, para. 49
  9. India Const. art.19
  10. India Const. art.19, cl. 1(a)
  11. Maneka Gandhi Vs Union of India 1978 AIR 597, 1978 SCR (2) 621 (India)
  12. Shreya Singhal Vs. Union of India
  13. Sec. 144 The code of Criminal Procedure, 1973, No. 2, Act of Parliament, 1973 (India
  14. Sec.5, The Telegraph Act, 1883, No. XIII of 1885, Act of Parliament, 1883 (India)
  15. American Convention on Human Rights "Pact of San Jose, Costa Rica" (B-32), 1969 U.S.C
  16. India Const. art.370
  17. Sec.144 The code of Criminal Procedure, 1973 , No. 2, Act of Parliament, 1973 (India)
  18. India Const. art.19
  19. India Const. art.19
  20. India Const. art.19 cl.1(g)
  21. Sec.144 The code of Criminal Procedure, 197 , No. 2, Act of Parliament, 1973 (India)
  22. Indian National Telecom Policy, 2012 Act of Parliament 2012(India)
  23. Sec.144 The code of Criminal Procedure, 1973, No. 2, Act of Parliament, 1973 (India)
  24. Sec.144 The code of Criminal Procedure, 1973 ,No. 2, Act of Parliament, 1973 (India)
  25. Sec.144 The code of Criminal Procedure, 1973, No. 2, Act of Parliament, 1973 (India)
  26. India Const. art. 367
  27. India Const. art.19, cl.(1)(a)
  28. India Const. art. 19, cl(1)(g)
  29. Sec.144, The Criminal Procedure Code, 1973 No. 2, Act of Parliament, 1973 (India)
  30. Sec.5, The Telegraph Act 1885, No. XIII of 1885, Act of Parliament, 1883 (India)
  31. UDHR. art.19
  32. India Const. art. 19, cl.(1)(a)
  33. UDHR art.19
  34. Shreya Singhal Vs Union of India (2015) SCC 1 India
  35. India Const. art.19, cl.(1)(a)
  36. India Const. art.19, cl.(1)(a)
  37. Romesh Thapar V. State of Madras 1950 AIR 124, 1950 SCR 594
  38. Brij Bhushan Vs State of Delhi 1950 AIR 129, 1950 SCR 605
  39. Romesh Thapar V. State of Madras 1950 AIR 124, 1950 SCR 594
  40. Thomas Jefferson Extract from Thomas Jefferson to Edward Carrington Quotes by and about Thomas Jefferson (January 16, 1787)h
  41. Lowell v. Griffin, (1939) 303 US 444.
  42. Jacques Maritain, Man and the states 80-81 The Chatolic University of American Press 1878
  43. Anuradha Basin Vs Union of India (2020) SCC OnLine SC 1725
  44. Indian Express Vs. Union of India (1985) 1 SCC 641
  45. India Const. art. 19, cl (1)
  46. India Const. art. 19, cl.(1)(a)
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