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Freedom of Speech and Expression and Sedition Law in India: A relative study

The freedom of speech and expression means the right to express one's thoughts, decisions, and/or opinions freely by word of mouth, writing, printing, pictures or any other mode. Granting this freedom to its citizens is a sine qua non for any democratic government. [1]

Article 19(1) (a) which comes under Part III of the Constitution of India guarantees all its citizens the freedom of speech and expression subject to certain reasonable restrictions as stated in 19(2). Also, if one reads the Preamble of the Indian Constitution, the idea behind this fundamental right can be found in the following lines LIBERTY of thought, expression, belief, faith and worship.

Scope of Freedom of Speech and Expression[2]:
  • This right is available only to a citizen of India and not to foreign nationals.
  • This right is not an absolute right, it allows the government to impose a reasonable restriction by framing certain laws in the interest of sovereignty and the integrity of the nation, security of the state, friendly relations with foreign states, public order, decency, and morality and to deter contempt of court, defamation and incitement to an offence. [Article 19(2)]

Over the years, judicial creativity, judicial wisdom, and judicial craftsmanship has resulted in the widening of the scope of freedom of speech and expression by including the following aspects:
  1. Freedom of Press:
    Unlike the US Constitution, Article 19(1) (a) does not expressly mention the liberty of the press i.e. the freedom to print and publish what one wants without any permission requirements. Romesh Thappar v. State of Madras[3] was amongst the oldest cases to be decided by the Supreme Court declaring the freedom of the press as a part of freedom of speech and expression.

    In that case, Patanjali Sastri CJ rightly observed that:
    Freedom of Speech and Press lay at the foundation of all democratic organizations, for without free political discussion, no public education, so essential for the proper functioning of the process of popular Government is possible.

    In the case of Indian Express Newspapers v. Union of India[4], it was held that the Press plays a very significant role in the democratic system. The courts have a duty to uphold the freedom of the press and invalidate all those laws and administrative actions which abridge that freedom.

    Freedom of Press includes freedom of publication, circulation, and freedom against pre-censorship.

    In Sakal Papers (P) Ltd v. Union of India[5], the Daily Newspapers (Price and Page) Order, 1960, which fixed the number of pages and size which a newspaper could publish at a price and in Benett Coleman & Co v. Union of India[6], the validity of the Newsprint Control Order, which fixed the maximum number of pages were struck down by the Supreme Court of India holding it to be violative of provision of Article 19(1)(a) and not to be reasonable restriction under Article 19(2).

    In the case of Brij Bhushan v. State of Delhi[7], the validity of order imposing pre-censorship on an English Weekly of Delhi, which directed the editor and publisher of a newspaper to submit for scrutiny, in duplicate, before the publication, all communal matters, all the matters and news and views about Pakistan, including photographs, and cartoons, on the ground that it was a restriction on the liberty of the press was struck down by the court.
     
  2. Freedom of Commercial Speech:
    In Tata Press Ltd. v. MTNL[8], the Supreme Court held that a commercial advertisement or commercial speech was also a part of the freedom of speech and expression, which would be restricted only within the limits of Article 19(2). Supreme Court held that advertising, which is no more than a commercial transaction, is nonetheless dissemination of information regarding the product advertised. The public at large is benefited by the information made available through the advertisements. In a democratic economy, the free flow of commercial information is indispensable.
     
  3. Right to Broadcast:
    The concept of speech and expression has evolved with the progress of technology and includes all the available means of expression and communication. It would also include electronic and broadcast media.

    In Odyssey Communications (P) Ltd. v. Lokvidayan Sanghatana[9], the Supreme Court held that the right of a citizen to exhibit films on the State channel Doordarshan is a part of the fundamental right guaranteed under Article 19(1) (a). In this case, the petitioners challenged the exhibition on Doordarshan of a serial titled Honi Anhoni, on the ground that it encouraged superstitious and blind faith amongst viewers. The petition was dismissed as the petitioner failed to show evidence of prejudice to the public.
     
  4. Right to Information:
    The freedom of 'speech and expression' comprises not only the right to express, publish and propagate information, it circulation but also to receive information. This was held by the Supreme Court in a series of judgments that have discussed the right to information in varied contexts from advertisements enabling the citizens to get vital information about life-saving drugs, to the right of sports lovers to watch cricket or football and the right of voters to know the antecedents (social background) of the electoral candidates.

    The Supreme Court in Union of India v. Assn. (Association) for Democratic Reforms[10] observed that:
    One-sided information, disinformation, misinformation, and non-information, all equally create an uninformed citizenry which makes democracy a farce. Freedom of speech and expression includes the right to know, receive and impart information which also includes freedom to hold opinions.
     
  5. Right to Criticize:
    Everyone has a fundamental right to form his opinion on any issues of general concern. Open criticism of government policies and operations is not a ground for restricting expression. Intolerance is as much dangerous to democracy as to the person himself. In a democracy, everyone doesn't need to sing the same tune.

    In S. Rangarajan v. P. Jagjivan Ram[11], the Madras HC revoked the 'U' certificate issued to a film on the ground that the exhibition of the film was likely to cause public disorder and violence. On appeal by the producer and the Union of India, the Supreme Court reversed the order. The court not only reiterated the importance of the freedom of speech and expression and the role of films as a legitimate media for its exercise but also held that if the exhibition of the film cannot be validly restricted under Article 19(2), it also cannot be suppressed on account of threat of demonstration and processions or threat of violence. It added:[12]

    It is the duty of the State to protect the freedom of expression since it is a liberty guaranteed against the State. The State cannot plead its inability to handle the hostile audience problem. It is obligatory duty to prevent it and protect the freedom of expression.[13]
     
  6. Right to Expression beyond National boundaries:
    In Maneka Gandhi v. Union of India[14], the Supreme Court considered whether Article 19(1) (a) of the Indian Constitution was confined to Indian Territory and held that the freedom of speech and expression is not confined to national boundaries.
     
  7. Right not to speak or Right to silence (remain silent):
    In the case of Bijoe Emmanuel v. State of Kerala[15], it was held that a government circular having no legal sanction violates Article 19(1) (a), if it compels every pupil to join in the singing of the National Anthem despite his genuine, conscientious religious objection. Impliedly, the court has recognized the freedom of speech and expression, the right to remain silent or not to speak.
     
  8. Right to Listen or Decline to listen [16]:
    The Supreme Court has also recognized the right to listen or decline to listen. Nobody can be compelled to listen and nobody can claim that he has a right to make his voice trespass into the ears or minds of others.[17]

Law on Sedition in various other Countries:[18]
United States of America:
Under Section 2385 of the US Code, it is unlawful for anyone to knowingly teach/advocate the propriety of overthrowing the government, by force. However, with respect for freedom of speech, this law is rarely enforced.

Germany:
Volksverhetzung (incitement of the people) is a legal concept in Germany. The word loosely translates to 'sedition', although the law bans the incitement of hatred against any particular race or religion.

Canada:
Sedition laws are independent of the laws that pertain to hate crime, in Canada. Canadian citizens enjoy liberal freedom as the laws to restrict freedom of speech are rarely enforced upon them. As a matter of fact, there has been no new sedition brought to light after the 20th century.

Netherlands:
In the Netherlands, it is a crime to insult the King, the Heir Apparent, and their spouse, under Articles 111-113 of the Dutch Penal Code.

Malaysia:
The Malaysian Sedition Act 1948 is unique because it comprises not only laws on sedition against any ruler, ruling government, administration of justice and rights & privileges under the Federal Constitution, but also takes within its purview, prohibitions on racial hate speech.

Norway:
Chapter 9 of the Norwegian General Civil Penal Code makes defaming the King/Regent of Norway, a crime. Section 5 of the constitution states: The King's person is sacred, he cannot be censured or accused. The responsibility rests with his Council.

New Zealand:
Sedition ceased to be a crime following the introduction of The Crimes (Repeal of Seditious Offences) Amendment Bill in 2007, which was enforced w.e.f. 1st January 2008.

United Kingdom:
Section 73 of the Coroners and Justice Act 2009 abolishes sedition and seditious libel. This came into effect from 12th January 2010. Sedition by an alien (resident but not a national of the country) is an offence.

ABOLITION OF SEDITION IN USA AND UK: A CASE STUDY[19]
Tool created to prevent the Criticism of the King (UK):
Sedition was devised as a tool in 13th century Britain to suppress the freedom of the printing press and its ability to criticize the King. The Sedition Act, 1661 imposed punishment on anyone who wrote, printed, or preached any words against the King. It evolved to mean slander and libel against the reputation or actions of government officials and judges. The goal was to protect the faith that the common person had in the government and to avoid a 'breach of peace' in society.

By The 18th century, the law had received much criticism in the U.K. However, its efficacy in controlling speech and expression in the country was noted and applied to India. Queen-Empress v. Jogendra Chunder Bose[20] was the first recorded case in India on sedition. To encourage the masses to resist the government or disobey its authority was considered seditious.

In 1977, a working paper was published by the Law Commission suggesting the abolishment of the Act. This suggested that several legislations existed that covered the issues under sedition and that a law based on 'politics' rather than the policy was unnecessary. Thirty-two years later, Section 73 of the Coroners and Justice Act, 2009 abolished the offence of sedition.

The US introduced Sedition to Protect Federal Government:
In 1798, the Sedition Act was passed under the presidency of John Adams, to criminalize the act of making false statements against the federal government. It was designed to expire in 1801 as the purpose of the law was the protection of the government during the Quasi-War.

The mention and criminalization of sedition were next seen during World War I. Section 3 of The Sedition Act, 1918 was drafted to punish anyone making false statements that interfered with the U.S. war efforts. This included insulting the U.S. government, flag, Constitution, or military.

The most prominent case in this regard is In Re Debs[21], where a socialist worker Eugene Debs was sentenced to 10 years in prison for an anti-war speech. Justice Oliver Wendell Holmes stated that the freedom of speech and expression could be curtailed under certain circumstances.

In 1921 the Act was repealed. The case of Sullivan v. New York Times[22] upheld the freedom of speech under the First Amendment, which affected the treatment of libel. The U.S. Supreme Court held that unless a statement was made with malice or reckless disregard for the truth, the First Amendment protected the criticism of public officials.

Criticism of Sedition Law (124-A) in India:
Validity Test of Sedition Law: [23]
The validity of sedition law was tested for the first time in independent India by the then Punjab high court in 1951 in Tara Singh Gopi Chand v. The State. [24] The High Court held that Section 124A was indisputably a restriction on the freedom of speech and expression, and invalidated the provision on the basis that it was in contravention of the fundamental right of freedom of speech and expression under Article 19 of the Constitution of India. It was this judgment that prompted the Jawaharlal Nehru government to introduce new grounds on which the right to freedom of speech and expression could be reasonably restricted.

But in 1954, the Patna high court, in Debi Soren & Ors v. The State[25], upheld the validity of Section 124A, holding that the law does not violate Article 19. Four years on, the Allahabad high court declared Section 124A void in the case of Ram Nandan v. State[26], and held that the government must be ready to face a strong opposition apart from popular approval or disapproval.

124-A only Penalizes Disturbance caused to Law and Order or Incitement of Violence:
The conundrum arising from various views of the high courts was finally settled by the Supreme Court by its judgment in Kedar Nath case[27] in 1962, which is considered the most authoritative judgment of the Supreme Court on the interpretation of the sedition law. The five-judge bench defined the scope of Section 124A. It held that Section 124A only penalized words that reveal an intent or tendency to disturb law and order or that seem to incite violence.

The Supreme Court underlined that the presence of a pernicious tendency to incite violence is a pre-condition to invoke the sedition clause and that the penal provision cannot be used to stifle free speech. This definition has been taken as a precedent for all matters of Section 124A ever since.

By two judgments in 2011, the Supreme Court unambiguously stated yet again that only speech that amounts to incitement to imminent lawless action can be criminalized. In Indra Das v. State of Assam[28] and Arup Bhuyan v. State of Assam[29], the apex court also held that mere membership of a banned organization cannot incriminate a person unless he is proved to have resorted to acts of violence or incited people to imminent violence. However, the Union government has sought a review of these judgments on the aspect of membership of banned organizations.

The Law Commission of India, in its consultation paper on sedition, published in August 2018, also observed that while retaining the offence of sedition was essential to protect national integrity, should not be used as a tool to curb free speech.

Rise in Sedition Cases but Low Conviction Rate:
According to the data from the National Crime Records Bureau (NCRB), uploaded on its website, cases of sedition and under the stringent Unlawful Activities (Prevention) Act showed a rise in 2019, but only 3% of the sedition cases resulted in convictions.

The year 2019 saw a 25% rise in the number of sedition cases and a 41% increase in arrests over the previous year. A total of 93 cases of sedition were reported in 2019, with 96 arrests and charge sheets filed in 76 cases, as against 70 cases, 56 arrests, and 27 charge sheets the previous year.

As per the ministry of home affairs, out of the 96 people arrested for sedition in 2019, only two were convicted for the crime, while 29 were acquitted.

Sedition cases spiked by 160 percent from 2016 to 2019 and the conviction rate in such matters stood at just 3.3 percent in 2019, according to an analysis of official data by a rights lawyer.

The National Crime Records Bureau (NCRB) data, referred to and quoted by rights lawyer Vrinda Grover, assumes significance because of the observations of an apex court bench headed by Chief Justice NV Ramana that there have been enormous misuse of the colonial era penal law on sedition and very low rate of conviction in such cases.[30]

Karnataka had recorded the maximum number of sedition cases in 2019 at 22, followed by Assam (17), Jammu & Kashmir (11), and Uttar Pradesh (10). While J&K was under President's rule then, the other three states were being ruled by BJP. NCRB said the West Bengal government did not provide the data for 2019.[31]

During the anti-CAA protests last year, Delhi Police had invoked sedition charges against several persons including three young Muslim women. Similarly, Karnataka Police had booked 19-year-old Amulya Leona after she raised Pakistan zindabad slogans at a rally during an anti-CAA protest last year.

As per the NCRB report, for cases under trial, 21 were closed due to insufficient evidence or no clue while two were categorized as false and six cases were found to be a dispute of civil nature, based on the final report submitted by the police before the courts.

Private Member Bills Suggesting Amendment to IPC:[32]
In the year 2011, a private member bill titled the Indian Penal Code (Amendment) Bill, was introduced in the Rajya Sabha by Mr. D. Raja. The Bill proposed that section 124A IPC should be omitted. It was reasoned that the British Government used this law to oppress the view, speech, and criticism against British rule. But the law is still being used in independent India, despite having specialized laws to deal with the internal and external threats to destabilize the nation. Thus, to check the misuse of the section and promote freedom of speech and expression, the section should be omitted.

Another Private member Bill titled The Indian Penal Code (Amendment) Bill, 2015[33] was introduced in Lok Sabha by Mr. Shashi Tharoor to amend section 124A IPC. The Bill suggested that only those actions/words that directly result in the use of violence or incitement to violence should be termed seditious. This proposed amendment revived the debate on the interpretation of sedition. The courts through various judgments have settled that the language of this section does not imply that only words, either spoken or written, or signs, or visible representation that are likely to incite violence should be considered seditious.

Recent Developments on Sedition Law in India:
Chief Justice of India N.V. Ramana's remarks in open court on Thursday sends a strong message to the government that the Supreme Court is prima facie convinced that sedition is being misused by the authorities to trample upon citizens' fundamental rights of free speech and liberty.[34]

In a way, the court has questioned the need for the continuance of Section 124A — a colonial provision which was used to jail the Mahatma in the law books of modern democracy. This is a step away from the court's own Kedar Nath judgment of 1962 which had upheld Section 124A but read it down to mean any subversion of an elected government by violent means. The court will have to re-examine whether this 59-year-old judgment holds in the modern context when the State is itself using a punitive law to impose serious burdens on free speech.

The CJI's reference to low conviction rates under the sedition law resonates with a petition filed by senior journalist Sashi Kumar highlighting the dramatic jump in charging a person with the offence of sedition since 2016

In May, Justice D.Y. Chandrachud said it is time to define the limits of sedition. The judge had flagged the indiscriminate use of the sedition law against people who aired their grievances about the government's COVID management, or even for seeking help to gain medical access, equipment, drugs, and oxygen cylinders, especially during the second wave of the pandemic.

This is muzzling the media, Justice L. Nageswara Rao, another Supreme Court judge, had noted while considering a plea made by two TV channels, TV5 and ABN, against the Andhra Pradesh government for using the sedition law to silence them. The CJI Bench issued notice on Thursday to the government on a petition filed by the Editors Guild of India to quash the sedition law. Senior journalist Arun Shourie has also challenged the constitutionality of Section 124A.

Justice U.U. Lalit, in his recent judgment quashing a sedition case against Mr. Dua for his alleged remarks about the Prime Minister and the Union Government in a YouTube telecast, upheld the right of every journalist to criticize, even brutally, the measures of the government to improve or alter them through legal means.

Pleas Challenging Section 124-A of IPC [35]:
Concerned over enormous misuse of the colonial era penal law on sedition, the Supreme Court asked the Centre as to why it was not repealing the provision used by the British to silence people like Mahatma Gandhi to suppress freedom movement.

Agreeing to examine the pleas filed by the Editors Guild of India and a former major general, challenging the constitutionality of section 124A (sedition) IPC, a bench headed by Chief Justice N V Ramana said its main concern was the misuse of law and issued the notice to the Centre.

Mr. Attorney (General). We want to ask some questions. This is the colonial-era law and the same law was used by the British to suppress the freedom movement. It was used by the British to silence Mahatma Gandhi, Gokhale, and others. Is it still necessary to keep this in statute even after 75 years of independence? asked the bench which also comprised of justices A S Bopanna and Hrishikesh Roy.

Observing that the provision on sedition has been put to enormous misuse, it also referred to alarming misuse of section 66 A of the Information Technology Act even after the top court set it aside long back and observed:
It can be compared to a carpenter, asked to cut wood, cut the entire forest.

A factionist can invoke these types of (penal) provisions to implicate the other group of people, the CJI said, adding that if a particular party or people do not want to hear a voice, they will use this law to implicate others.

The bench wondered at the continuance of the sedition law in the statute book for the last 75 years and said: We do not know why the government is not making a decision. Your government has been getting rid of stale laws.

The bench said that it was not blaming any state or government, but unfortunately, the executing agency misuses these laws and There is no accountability.

In a hearing, conducted through video-conferencing, the bench said that if a police officer in a remote village wanted to fix a person then he can easily do so by using such provisions. Moreover, said the bench, there was a very low percentage of convictions in sedition cases and these are the issues which are needed to be decided.

The CJI, on being told that another bench headed Justice U U Lalit has been hearing a similar plea which has been fixed for further consideration on July 27, said he would take a call on posting of the matters and notify the date of hearing.

Attorney General KK Venugopal, who was asked to assist the bench in dealing with the case defended the provision and said it be allowed to remain in the statute book and the court may be laid down guidelines to curb the misuse.

Senior advocate Shyam Divan, appearing for the Editors Guild of India said that a separate plea has been filed by the journalists' body challenging the validity of section 124A (sedition) of the IPC and that plea can also be tagged along with the present one. He said that besides challenging the validity, the Guild has also sought framing of guidelines to curb misuse.

The bench was hearing the fresh plea by former army officer, Major-General S G Vombatkere (Retd), challenging the Constitutional validity of section 124 A (sedition) of the IPC on grounds that it causes a chilling effect on speech and is an unreasonable restriction on free expression, a fundamental right. The bench, referring to the credentials of Vombatkere said that he gave his entire life to the country and his motive in filing of the case cannot be questioned.

The former Army officer challenged the constitutional validity of the sedition law on the ground that it causes chilling effect on speech and is an unreasonable restriction on free expression, a fundamental right. His plea said section 124-A is wholly unconstitutional and should be unequivocally and unambiguously struck down.

The petitioner contends that a statute criminalizing expression based on unconstitutionally vague definitions of disaffection towards Government etc. is an unreasonable restriction on the fundamental right to free expression guaranteed under Article 19(1)(a) and causes constitutionally impermissible Chilling Effect on speech, the plea said.

The petition said there is a need to take into account the march of the times and the development of the law before dealing with Section 124-A.

Earlier, a separate bench had sought a response from the Center on the plea challenging validity of sedition law, filed by two journalists –Kishorechandra Wangkhemcha and Kanhaiya Lal Shukla--working in Manipur and Chhattisgarh respectively.

Conclusion:
The sole claim that since Section 124-A of IPC (Sedition Law) is a colonial law that cannot be considered a valid ground for its repeal, but if followed the data relating to low conviction rate despite the increase in the sedition cases, which is acting as evidence to the issue of the misuse and abuse of the sedition law for curbing the freedom of speech and expression of the citizens- this can be a strong and rational argument that might compel to consider the repeal of Section 124-A or at least limiting the extent of 124-A through an amendment in accordance with modern times and the changing scenario.

References:
Books:
  • V.N. Shukla, Constitution of India, Eastern Book Company, 13th edn, Reprinted 2021 with Supplement 2020.
End-Notes:
  1. V.N. Shukla, Constitution of India, Eastern Book Company, 13th edn, Reprinted 2021 with Supplement 2020, Pg no. 136.
  2. http://www.legalserviceindia.com/legal/article-572-constitution-of-india-freedom-of-speech-and-expression.html
  3. AIR 1950 SC 124: 1950 SCR 594.
  4. (1985) 1 SCC 641: AIR 1986 SC 515.
  5. AIR 1962 SC 305: (1962) 3 SCR 842.
  6. (1972) 2 SCC 788: AIR 1973 SC 106.
  7. AIR 1950 SC 129.
  8. (1995) 5 SCC 139: AIR 1995 SC 2438.
  9. (1988) 3 SCC 410: AIR 1988 SC 1642.
  10. (2002) 5 SCC 294: AIR 2002 SC 2112.
  11. (1989) 2 SCC 574.
  12. Ibid, 599.
  13. V.N. Shukla, Constitution of India, Eastern Book Company, 13th edn, Reprinted 2021 with Supplement 2020, Pg no. 141.
  14. (1978) 1 SCC 248.
  15. (1986) 3 SCC 615: AIR 1987 SC 748.
  16. V.N. Shukla, Constitution of India, Eastern Book Company, 13th edn, Reprinted 2021 with Supplement 2020, Pg no. 144.
  17. Noise Pollution (5), re, (2005) 5 SCC 733: AIR 2005 SC 3136.
  18. https://www.scoopwhoop.com/Sedition-Laws-In-Different-Countries/
  19. https://www.scobserver.in/beyond-the-court/sedition-in-the-common-law-jurisdictions-uk-usa-and-india
  20. (1892) ILR 19 Cal 35
  21. 158 U.S. 564 (1895)
  22. 376 U.S. 254 (1964)
  23. https://www.hindustantimes.com/india-news/the-sedition-story-complicated-history-of-sec-124a-101626370928612.html
  24. 1951 CriLJ 449
  25. 1954 CriLJ 758
  26. AIR 1959 All 101: 1959 CriLJ 1
  27. 1962 AIR 955: 1962 SCR Supl. (2) 769
  28. (2011) 3 SCC 380
  29. (2011) 3 SCC 377
  30. https://www.tribuneindia.com/news/nation/sedition-cases-jump-160-per-cent-between-2016-19-rights-lawyer-283709
  31. https://economictimes.indiatimes.com/news/politics-and-nation/arrests-under-sedition-charges-rise-but-conviction-falls-to-3/articleshow/81028501.cms?from=mdr
  32. Law Commission of India, Consultation Paper on Sedition (2018): https://lawcommissionofindia.nic.in/reports/CP-on-Sedition.pdf
  33. The Indian Penal Code (Amendment) Bill, 2015, available at: http://164.100.47.4/BillsTexts/LSBillTexts/Asintroduced/2535LS.pdf
  34. https://www.thehindu.com/news/national/sedition-law-supreme-court-sends-strong-message-to-government/article35348364.ece
  35. https://www.business-standard.com/article/current-affairs/sc-concerned-over-misuse-of-law-on-sedition-seeks-centre-s-reply-121071500410_1.html
Written By Chintan Jain, a 2nd-year law student at Unitedworld School, Karnavati University

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