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18. In India, there are several sting operations that have been conducted. A few instances are the operation West Wing which was an undercover operation carried by Tehalka; operation Duryodhana, by Cobra Post, where certain members of the Indian Parliament were caught on camera; Narada case, highhanded operation of financial bribes were unearthed by the said sting operation. These are a few instances where sting operations have been conducted which are in public domain. Judicial interpretations of sting operations have also been done through several judgments by the Apex Court or by the High Courts.

"16. We have also come across an article titled "A tale in the sting", relating to the Uma Khurana incident, written by Ms. Barkha Dutt, Managing Editor of NDTV wherein she has referred to media reports/sting operations in the United States. Ms. Dutt in her article referred to reports of the American newspaper 'Chicago Sun Times' wherein Police officers were bribed by journalists to get a bar licence. Police officers taking bribe were caught on hidden camera and later the sting operation was shown on TV. The said programme won many awards but not the Pulitzer prize because they could not agree on whether the methods used were honourable enough. After having referred to the said incident, Ms. Dutt observed:
"This is, perhaps, what is at the heart of the matter. There is something unseemly and mildly sleazy about reporters playing Pied Pipers who lay out the cheese to seduce conmen into their rat traps. It is much easier to justify the use of a hidden camera when it is for capturing the event that would 2007 SCC OnLine Del. 1662 (DB) take place whether or not the camera was there. Entrapment somehow can't manage to shake off the suggestion of fabrication."

18. Giving inducement to a person to commit an offence, which he is otherwise not likely and inclined to commit, so as to make the same part of the sting operation is deplorable and must be deprecated by all concerned including the media. Sting operations showing acts and facts as they are truly and actually happening may be necessary in public interest and as a tool for justice, but a hidden camera cannot be allowed to depict something which is not true, correct and is not happening but has happened because of inducement by entrapping a person.