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Sedition Laws In India: A Critical Analysis

'Sedition is overt behaviour that aims toward revolt against the existing order through speech and organisation. Sedition frequently involves the violation of a constitution as well as the instigation of rebellion against established authorities. Any disturbance that isn't directly and overtly violent against the law is considered sedition. Seditious language is seditious libel. A seditionist is someone who participates in or advances sedition.'

No matter what you think about it, this definition of sedition that I discovered elsewhere seems rather dangerous. Everyone will agree, after knowing what sedition is, that it poses a severe danger to national security and creates resentment among the public toward their own elected government.

To put a stop to it, the government must intervene. It must take prompt action to put a stop to these thieves. So that our nation may grow without any interference from our administrations, the culprits should be captured as soon as feasible and prosecuted by the law.


There is an issue. Every story has two sides, and just like sedition in India, which is distinctly neither black nor white, 356 sedition-related incidents were registered between 2015 and 2020. However, just 12 of those held throughout the course of seven sedition trials over the course of these six years were convicted.

Law of Sedition
On July 15, Chief Justice N.V. Ramana expressed concern over the "colonial-era" sedition statute's continued existence. He said that sedition was like giving a carpenter a saw and telling him to cut a piece of wood, and then telling him to clear the forest. His comments and a series of recent judgements by the top court have sparked a contentious debate over how frequently state agencies (mis)apply sedition legislation.

The Indian Constitution states in Article 19(1)(a) that everyone has the freedom to express their opinions. However, the freedom of speech and expression is subject to some reasonable restrictions under Article 19, therefore this right is not unrestricted.

However, under section 124-A of the Indian Penal Code, 1860, actions that are considered disrespectful to the Indian government and that can be carried out by words, signs, or other means of communication are punishable. Speech that is considered to be antagonistic to or dangerous to the state is illegal under the crime of sedition. The protection afforded by Section 124A is fairly wide and does not include any criticism made of any particular administrative decisions or policies in good faith. It includes activities that defame the government.

History of Law Of Sedition
  • "Action or speech that leads to revolt against the authority of the state" is what is meant by sedition. The IPC's Section 124A, which addresses the Law of Sedition, is viewed as a reasonable restriction on the right to free expression. It was initially exhibited in 1870 and Thomas Macaulay invented it.
  • The section was first included to address the growth of Wahabi activity between 1863 and 1870. The colonial authorities faced a difficulty as a result of these actions.
  • Indian nationalist leaders were involved in some of the most well-known sedition cases of the late 19th and early 20th centuries.
  • The earliest of these was Jogendra Chandra Bose's trial in 1891. He served as the newspaper Bangobasi's editor. He published a piece denouncing the Age of Consent Bill for endangering the faith and its coercive treatment of Native Americans.
  • In 1897, Bal Gangadhar Tilak's articles in Kesari were the subject of legal action.
  • The other well-known case included Mahatma Gandhi's 1922 sedition trial. Sedition, according to Gandhi, is "the prince among the political sections of the IPC meant to destroy the freedom of the citizen."

Meaning of Sedition under Section 124-A IPC
Meaning of Sedition under Section 124A of IPC, 1860 "Whoever, by words, either spoken or written, or by signs, or by visible representation, or otherwise, brings or attempts to bring into hatred or contempt, or excites or attempts to excite disaffection towards the Government shall be punishable with Life Imprisonment".

Sedition in Other Laws
What constitutes "sedition" is hotly contested in India. The following elements must be present for an act to be classified as "seditious" under the Indian Penal Code:
  • Any words, whether spoken or written, or any signs, such as placards or posters (visible representation)
  • Must foster animosity, contempt, and disillusionment toward the Indian Government
  • Must lead to "imminent violence" or general unrest.
The following actions have been deemed to be "seditious" in accordance with the Court's interpretation of Section 124-A of the Indian Penal Code, 1860 like raising of anti-government chants by organisations, such as "Khalistan Zindabad." It was believed that raising slogans by one or two people casually wasn't seditious.

For a speech to be deemed seditious, it must encourage violence or other forms of public disorder. It has been further interpreted in subsequent decisions to encompass "incitement of imminent violence." any written material that encourages violence and disturbance in the public.

Disloyality in Action
Disloyalty in action has been referred to as "sedition." The goal of the sedition laws is to sow dissatisfaction and rebellion, to incite hostility to the government, and to defame the legal system. Sedition is a crime against society since it includes any actions that defy the authority of the state, incite civil war, or otherwise foster unrest in the community.

Punishment Under Section 124-A
Section 124-A of the IPC lists the following penalties: � It is a non-bailable offence.
  • A fine may be levied to any sentence of imprisonment ranging from three years to life.
  • The offender is ineligible for any government employment after being convicted of this crime.

Available Defences to a person charged with Sedition
To get the exemption from Criminal Liability, the following are the defences: That he did not make the sign or representation or not speak or write the words, or not do any act in question. He did not attempt into the contempt or attempt disaffection. Such disaffection should not be towards the Government.

Sedition and Article 19(1)(a) of Indian Constitution
Free expression is accepted by everybody as a fundamental human right and has grown in importance on a global scale.

Various rights are protected in India under Part-III and Article 19 of the Indian Constitution. The freedom of a person to communicate ideas and information both inside and outside of India means that the aforementioned right is not geographically limited. The courts have been given the power to protect and uphold a citizen's rights. Although "freedom of speech and expression" is protected by Article 19(1)(a), it is restricted by the provision in Article 19(2) that outlines the circumstances in which this right may be restricted by law.

In Niharendu Dutt's Case[2] prosecution for sedition, the Federal Court determined to interpret Section 124A of the IPC in conformity with British Law. It had determined that a need under Section 124A was the potential to disturb the peace. The Privy Council believes that section 124A does not need the incitement of violence or a tendency to disturb the peace.

In Tara Singh v. State[3], the legitimacy of Section 124A of the IPC was immediately contested. This provision was declared unlawful by the East Punjab High Court because it constrained the plaintiff's freedom of speech and expression. The Constitution (First Amendment) Act of 1951 altered the First Amendment's guarantees of free speech and expression in two ways. By introducing further justifications, it significantly increased the scope for free expression limits; the restriction imposed on Article 19(1)(a) must be fair.

This raises the issue of whether Section 124A of the IPC conflicts with Article 19(1)(a). The justifications listed below support this: In that it breaches Article 19(1)(a), which protects the right to free expression, and is not covered by the qualifier "for the sake of public order," Section 124A of the IPC is extra vires of the constitution.

Section 124A is not unconstitutional since the phrase "in the interests of public order" has a wider connotation and shouldn't be confined to just one aspect of public order. Section 124A IPC is both partially invalid and partially valid.

In Indramani Singh v. State of Manipur[4], In contrast to the restriction placed on the freedom of speech and expression protected by Article 19(2), it was determined that Section 124A, which aims to put limits on igniting just disaffection, is extra vires. Article 19(1)(a) of the Constitution was deemed to be extra vires by the Allahabad High Court in 1959.

Sedition and Indian Freedom Struggle
Mahatma Gandhi was accused of seditious activity. Because he had written three "politically sensitive" articles in his weekly journal Young India, which was published from 1919 till 1932, Gandhiji was put in prison on the grounds of sedition. He was sentenced to six years in jail. He was accused of trying to incite resistance to the British government, interfering with loyalties, and shaking manes. He authored the opening chapter of his autobiography.

The Story of my Experiments with Truth, while he was incarcerated and it was about the Satyagraha movement in South Africa. After two years, due to appendicitis, he was granted release. Bal Gangadhar Tilak was ultimately found guilty as a result. Bal Gangadhar Tilak was twice charged with sedition due to the following:

First, he was charged with sedition in 1897 for allegedly inciting violence that resulted in the deaths of two British policemen. In 1898, he was given bail while on trial.

Second, he supported the Indian revolutionaries and issued an editorial urging swift Swaraj, or self-rule, in his periodical "Kesari." He was sentenced to sedition for his conduct and held in Mandalay, Burma, from 1908 until 1914.

Constitutionality of Law of Sedition In India
The following are some laws which cover Sedition law:
  • The Unlawful Activities (Prevention) Act (Section 2(o) (iii)).
  • The Code of Criminal Procedure, 1973 (Section 95)
  • Indian Penal Code, 1860 (Section 124A)
  • The Seditious Meetings Act, (1911)

Disaffection and the State
Dissatisfaction and therefore the State In Srinagar, the Committee for the Discharge of a Prisoner hosted a lecture with the theme "Azadi, the single Way." The issue started when Arundhati Roy, Syed Ali Shah Geelani, Varavara Rao, and other speakers at the Seminar were accused of seditious activity. The Central Government reportedly opposed starting legal procedures in this issue, according to the media. However, there have been allegations of lawsuits being filed in Delhi, the capital of India. intimidation about the lawsuits being brought against Roy, Geelani, and other seminar speakers in various regions of the nation.

Landmark Judgements

Queen Empress v Jogendra Chunder Bose (1891) [5]
  • Jugendra Bose criticised the Age of Consent Act of 1891 in a piece of writing.
  • His critique was seen as disrespect for the government.
  • However, once he was granted bail, the matter was subsequently withdrawn.

Sedition Trial of Lokmanya Tilak (1897) [6]
  • The celebration reports, together with an 1894 study by Professor R. P. Karkaria on the Maratha monarch Shivaji, were published by Bal Gangadhar Tilak. In 1894, Karkaria delivered his paper to the Royal Asiatic Society of Bombay. The yearly Shivaji Coronation ceremony was made possible by this publication. Tilak afterwards made the reports of the festivities public.
  • These festivities were described as "Shivaji's Utterances" by Tilak in his newspapers, Kesari and Mahratta.
  • Justice Arthur Strachey presided over the proceedings.
  • This sedition trial is infamous in history because it involved an attempt to incite animosity against the government and was classified as seditious under Section 124A. The interpretation of Section 124A was thus expanded.
  • Tilak received a harsh 18-month jail term as punishment.

Sedition Trial of Lokmanya Tilak (1908)[7]
  • On May 12 and June 9, 1908, respectively, Tilak wrote two pieces in Kesari, headlined "The Country's Misfortune" and "These Remedies aren't Lasting."
  • In accordance with the recently created Section 124A, he received a 6 year jail term in Burma (Now, Myanmar).

Mohandas Karamchand Gandhi's Sedition Trial (1922)[8]
  • Due to his articles in his daily, "Young India," Mahatma Gandhi was sentenced to six years in prison.
  • "Bringing or trying to stir disaffection towards His Majesty's Government constituted by law in British India" was the allegation levied against him.
  • Section 124A was described by Mahatma Gandhi as "Prince among the political parts of the Indian law code meant to restrict the citizen's freedom."

Post-Independence �Supreme Court Decisions
Brij Bhushan and Another v. The State of Delhi (1950)[9] and Romesh Thappar v. The State of Madras (1950)[10]
  • The Supreme Court ruled that it was unconstitutional for a statute to limit speech if it may disrupt public order.
  • The "First Constitution Amendment," which replaced "undermining the protection of the State" with "in the interest of public order," was inspired by the court's ruling.
The Punjab High Court had declared Section 124A invalid in 1951. The Allahabad High Court made a similar decision in 1959 and came to the same conclusion that it violated the fundamental right to free expression.

Kedar Nath Singh vs State of Bihar (1962) [11]
  • In this case, the constitutionality of Section 124A was put to the test.
  • A Forward Bloc member was accused of sedition after making a speech.
  • The Supreme Court held:
    1. It is seditious to say or write anything that implies "subverting the govt. by violent means," including the idea of "revolution."
    2. Sedition is considered to be a failed attempt with incitement.
    3. Creating chaos in public was seditious.
  • There was no "unreasonable difference" made between criticising the government's actions and criticising the government as a whole.
P. Alavi vs State of Kerala (1982) [12]
  • The Supreme Court ruled that using slogans or denigrating the government or judicial system does not constitute sedition.
Balwant Singh vs State of Punjab (1995) [13]
  • Balwant Singh who was the Director of Public Instructions (DPI) in Punjab, Chandigarh among other two, was speculated to have shouted pro-Khalistan slogans on the day of former PM Indira Gandhi's assassination.
  • The apex court held that unless there's public disorder merely sloganeering can't attract punishment under Section 124A.

Sanskar Marathe v. State of Maharashtra (2015)[14]
  • In this instance, the Bombay High Court established instructions that police officers must abide by before bringing a sedition prosecution against someone.
  • These recommendations involve a critical analysis of the seditious content. The police must assess if the statements and acts led to dissatisfaction and treason against the government before coming to a conclusion.
Rajat Sharma v. Union of India Case (2021)[15]
  • According to the court's decision in this instance, rejecting the government's policies and ideologies does not constitute sedition. Therefore, it is not possible to use the Sedition clause to calm the unrest (criminalizing the critics).
Improvement or change through legal means in opposition to governmental measures is not viewed as seditious behaviour.

Strong language that conveys resistance to governmental regulations and deters behaviour that may otherwise result in violent acts that disrupt public order. To make sure that these actions are corrected legally without inciting animosity or disloyalty that can lead to disturbance in the public square or the use of force, or to better the situation of the people.

National Crime Records Bureau (NCRB) [16]
The National Crime Records Bureau (NCRB) reports that between 2015 and 2020, 356 instances of sedition under Section 124A of the IPC were reported, and 548 persons were detained.

Between 2015 and 2020, 356 sedition-related cases were reported. However, just 12 of those detained in seven sedition trials throughout this six-year period were found guilty.

There were 73 sedition-related cases across the nation in 2020, 93 in 2019, 70 in 2018, 51 in 2017, 35 in 2016, and 30 in 2015.

In 2020, 3.3% in 2019, 15.4% in 2018, 16.7% in 2017, 33.3% in 2016, and 3.3% in 2019 were the conviction rates for sedition cases.

In 2020, 44 people in total were detained for violating the legislation on dissent, as opposed to 99 in 2019, 56 in 2018, 228 in 2017, 48 in 2016, and 73 in 2015.

Out of 548 people, 290 between 2015 and 2020 belonged to the 18 to 30 year age group, while the remainder are in the 30-35 age range.

Over the past three years that the NCRB has provided crime statistics (2018-2020), Assam had the most sedition arrests, with 23 in 2018 and 2019, and 10 in 2020. The states with the most arrests made under Section 124A of the IPC in 2018 were Andhra Pradesh (15), Madhya Pradesh (4), and Chhattisgarh (3); in 2019, Karnataka (18), Nagaland (11) and Uttar Pradesh (9) had the most; and in 2020, Uttar Pradesh (8), Nagaland (7), and Karnataka (6) had the most. In 2020, Manipur had 15 sedition cases, more than Assam (12), Karnataka (8), or Uttar Pradesh (7). (1).

Sedition Around The World[17]
United Kingdom
In the UK, the 1960s saw the end of the sedition statute, which was ultimately repealed in 2009. Sedition committed by an alien (a resident who is not a national of the country) is nonetheless illegal.

Some sedition laws in the USA have been revoked or declared to be unenforceable. The courts provide free expression broad protection. The US Code's Sections 2381 through 2385 address treason, sedition, and subversive actions that call for the overthrow of the government. To protect the right to free expression, however, the legislation is rarely used.

In 2017, Singapore, which, like India, inherited colonial English law, abolished its sedition statute, which had been put in place 83 years earlier to quell local resistance to British colonial control. Key provisions of the Sedition Act, according to the Home Ministry, have been out of date for a while in contemporary Singapore, and prosecutions under the statute are extremely rare. It claimed that a number of additional legislation can adequately solve the problems covered by the sedition law. Over the years, Singapore has passed additional legislation to address the problems addressed by the Act in a more focused and calculated way.

New Zealand
The act of 'sedition' ceased to be a crime following the introduction of The Crimes (Repeal of Seditious Offences) Amendment Bill in 2007 that came into effect from January 1, 2008.

The Crime Act of 1920 was Australia's first comprehensive piece of law to include a sedition offence. In 1984 and 1991, reviews were conducted on it. The Anti-Terrorism Act (No 2) 2005's Schedule 7 underwent changes in 2005. The usage of the term "sedition" to describe the offences stated in the 2005 amendment was examined by the Australian Law Reform Commission (ALRC). The National Security Amendment Act of 2010 adopted an ALRC proposal in 2010, changing the term "sedition" to "urging violence offences." Scotland On March 28, 2011, the common law offence of sedition was eliminated by Section 51 of the Criminal Justice and Licensing Act, 2010.

Sedition was deemed "unconstitutional" in Indonesia in 2007, following the directives of the Dutch colonisers.

South Korea
Sedition laws were repealed in the Republic of Korea in 1988 as part of political and legal changes.

A handful of journalists have previously been imprisoned under Ghana's Criminal Libel and Seditious Laws, which were overwhelmingly abolished on July 27, 2001. Following a unanimous majority in the House, the Criminal Code (Repeal of the Criminal and Seditious Laws Amendment Bill) Act 2001 was repealed.

Sedition legislation controversies are not brand-new. Even Mahatma Gandhi described Section 124A as a tactic used to restrict citizens' freedoms. The application of the legislation by successive administrations against, among others, political leaders, activists, and the media has been criticised as an effort to stifle dissent. State and federal administrations have both exploited the statute.

Jibon Singha, the leader of the Kamtapur Liberation Organization, was recently charged with sedition for referring to Mamata Banerjee as a "outsider" by the West Bengal government. In another instance, the Lakshadweep government accused filmmaker Aisha Sultana of violating the sedition act for her remark in which she referred to Praful Patel, the UT's administrator, as a "bioweapon."

Government data shows that between 2014 and 2019, 326 sedition instances were reported nationwide, however only six people were found guilty in these proceedings. Journalist Kishorechandra Wangkhem of Manipur was similarly detained on suspicion of sedition and later charged with the NSA, but the Manipur High Court also granted him bail.

Reasons behind its Support
  • The IPC's Section 124A is helpful in the struggle against terrorist, separatist, and anti-national organisations.
  • It also protects the elected government from attempts to overthrow it via force or illegal means.
  • If disrespecting the court results in criminal prosecution, then disrespecting the government ought to do the same, as maintaining the existence of the legal government is a requirement for the stability of the State.
  • Maoist rebel groups successfully run a parallel government in a number of states' various districts. These groups openly support a revolution to overthrow the state legislature.
Therefore, repealing Section 124A just because it has been improperly used in some well publicised cases would be a bad idea.

Reasons behind its Criticism
Poor implementation of court guidelines: The judiciary provided guidance to the law enforcement agencies about its applicability each time a sedition case was dismissed. However, the law enforcement organisations do not adhere to the recommendations in text and spirit.
  • Growing abuse of Sedition:
    According to recent data, sedition charges under Section 124A have surged by 160%. While the conviction rate decreased from 33.3% in 2016 to 3.3% in 2019.
  • Sedition has been outlawed in the UK:
    Sedition was outlawed in the UK in 2010. India, meanwhile, is still adhering to the British Empire's legal system. Similar to this, the term "sedition" was deleted from references to "urging violent crimes" in Australia after the Australian Law Reform Commission's (ALRC) recommendations.
  • Law Commission Recommendation:
    The Law Commission of India questioned whether Section 124A should be kept in place in 2018. Even the removal or revision of Section 124A of the Indian Penal Code was urged.
  • India signed the International Covenant on Civil and Political Rights (ICCPR) in 1979, going against its international commitment.
  • It lays out widely regarded norms for the defence of free speech. However, abuse of the term "sedition" and arbitrary charging are in odds with India's international obligations.
  • There are sections in both the IPC and the Unlawful Activities Prevention Act that make "disturbing the public order" or "overthrowing the government by violence and criminal means" illegal. These are adequate to safeguard national integrity. Section 124A is not specifically required.

Supreme Court Intervention on validating its constitutionality
The Indian Penal Code's Section 124-A has been suspended by the Supreme Court, which also requested that neither the Central nor state governments file any FIRs under this provision.

Governments should refrain from using the sedition clause until the Center's review of the provision is complete, according to a bench led by Chief Justice N.V. Ramana and composed of Justices Surya Kant and Hima Kohli. The apex court has given the Central government permission to review and reevaluate the provisions of Section 124A of the IPC, which makes sedition a crime.

"It will be prudent to wait to apply this legal provision until additional review is complete. When the matter is being reviewed by the Center, we hope and anticipate that the Central Government and States would refrain from filing any FIRs, conducting further inquiries, or using coercive measures according to Section 124A IPC "Ordered by the Supreme Court. According to the SC, if sedition complaints are filed, the parties are free to appear in court and the judge is required to quickly resolve the matter.

Expected Assumptions for its future
Many nations throughout the world, including Ireland, Australia, Canada, Ghana, Nigeria, and Uganda, have recently modified or eliminated their laws on sedition. Sedition has been outlawed even in the United Kingdom, where Indian law was based, according to the Coroners and Justice Act of 2009.

It is crucial to educate the public, law enforcement, the executive branch, and the lower judiciary about the modified section in order to combat these.

Several private member bills on sedition have been submitted in India, and the bulk of them call for reform rather than repeal. While Section 124A of the IPC was called out as being draconian and colonial in the private member bills put forth by Shri D. Raja, Shri P. Karunakaran, and Shri Elamaram Kareem, other bills, including those from Shri Shashi Tharoor, Shri Bhartruhari Mahtab, Shri Saugata Roy, and Shri Baijayant Panda, propose reformation of the provision.

While some people may be excited by the potential elimination of sedition in the nation, several private member bills have suggested modifying the restrictions of Section 124A of the IPC. Even the Law Commission believes that sedition is crucial for preserving national integrity in its comment document.

A few of the changes may be:
  • Adding explanation providing that acts expressing disapprobation of the measures of the government or the administrative action of the government would not amount to sedition
  • Adding a clarification that sedition would apply only if it directly results in incitement of violence and commission of an offence of certain punishment.
  • Adding a clarification regarding the scope of "disaffection" under this provision.
  • Adding a clarification regarding legitimate protests.
  • Adding procedural safeguards in Section 124A of the Code of Criminal Procedure or through policy guidelines.
It might be claimed that despite Kedarnath v. State of Bihar providing clear instructions, Section 124A of the IPC is still being misused by the police and state agencies, making any reforms unlikely to be effective in practise. It may also be argued that, in the absence of any institutional improvements, changing the language of Section 124A alone would not significantly alter the current situation. It is crucial to educate the public, law enforcement, the executive branch, and the lower judiciary about the modified section in order to combat these. Advocacy efforts are necessary to inform the many facets of society about the significance of this provision in addition to the change.

The future of dissent and free expression in the nation may benefit from repealing or amending the sedition statute. The legal reforms will have a significant impact on whether a person feels comfortable voicing beliefs that are opposed to those of the government. One can only hope that the alterations safeguard the people's right to free expression and dissent while taking into account the interests of the nation and security.

  • To address the issue of misuse, the government must train law enforcement officials. The enforcement agencies may get training on the implementation of sedition laws and other criminal defamation laws, as well as on when they do not apply.
  • Parent-Child Relationship: The government must treat all of its citizens as though they were its children. Parents don't readily abandon their children despite the insults (sedition) they receive from youngsters (citizens).
  • The state should also acknowledge that prominent people will inevitably draw criticism.
  • The government may pass the Protection of Speech and Reputation Bill, 2016, in amended form. The Private Member's Bill has certain crucial features, including
  • Determining the maximum claim amounts and prohibiting governmental entities, municipal authorities, and other organisations from bringing libel and sedition lawsuits (statutory functions).
  • Imposing sanctions for less serious transgressions, such as apologies, corrections, and retractions.

India is the largest democracy in the world and the right to free speech and expression is an essential ingredient of democracy. Dissent is the lifeblood of democracy. If the criticisms reach at the right time to the government, then it can save a lot of resources, government machinery, etc. On the other hand, to secure national integrity, divisive forces have to be kept in check. Preventing wrongful enforcement and misuse alone can remove the majority of the criticism against the Sedition. So the government must prioritize that.

  1. Ipleaders,'Law of Sedition In India'(Ipleaders, 14 February 2018)<> accessed 05 October 2022
  2. AIR 1939 Cal 703
  3. 1951 AIR 441, 1951 SCR 729
  4. 1955 CriLJ 184
  5. (1892) ILR 19 Cal 35
  6. (1898) ILR 20 All 55
  7. (1908) 10 BOMLR 848
  8. (1920) 22 BOMLR 368, 58 Ind Cas 915
  9. 1950 AIR 129, 1950 SCR 605
  10. 1950 AIR 124, 1950 SCR 594
  11. 1962 AIR 955, 1962 SCR Supl. (2) 769
  12. 1982 CriLJ 94
  13. 1976 AIR 230
  14. (2015) SCC BOM 587
  15. (2021) 5 SCC 585
  16. Marziya Sharif,'548 sedition related arrests since last six years: NCRB data'(Siasat Daily, 10 May 2022 ) <> accessed 05 October 2022
  17. Praveen Shekhar, 'How various countries have junked sedition law' (India Today, 11 May 2022) accessed 05 October 2022

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