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K. A. Abbas vs The Union Of India & Anr on 24 September, 1970

A similar question came up before this Court in K.A. Abbas v. The Union of India, [1971] 2 SCR 446 wherein Chief Justice Hidayatullah exhaustively dealt with the question of prior restraint in the context of the provisions of the Constitution and the Act. The learned Chief Justice after setting out the various provisions to which we have already adverted posed the questions; `How far can these restrictions go and how are these to be imposed'? The documentary film ` A tale of four cities' made by K.A. Abbas portrayed the contrast between the luxuious life of the rich and the squalor and poverty of the poor in the four principal cities of the country and included therein shots from the red light district of Bombay showing scantily dressed women soliciting customers by standing near the doors and windows. The Board of Film Censors granted `A' certificate to the film and refused the `U' certificate sought by Abbas. This was on the ground that the film dealt with relations between sexes in such a manner as to depict immoral traffic in women and because the film contained incidents unsuitable for young persons. Abbas challenged the Board's decision on the ground (i) that pre-censorship cannot be tolerated as it was in violation of the freedom of speech and expression and (ii) even if it is considered legitimate it must be exercised on well-defined principles leaving no room for arbitrary decisions. This Court held that censorship in Indian had full justification in the field of exhibition of films since it was in the interest of society and if the legitimate power in abused it can be struck down. While dealing with the grounds on which the `U' certificate was refused, the learned Chief Justice observed: "The task of the censor is extremely delicate and his duties cannot be the subject of an exhaustive set of commands established by prior ratiocination. But direction is necessary of him so that he does not sweep within the terms of the directions vast areas of thought, speech and expression of artistic quality and social purpose and interest. Our standards must be so framed that we are not reduced to a level where the protection of the least capable and the most depraved amongst us determines what the morally healthy cannot view or read. The standards that we set for our censors must make a substantial allowance in favour of freedom thus leaving a vast area for creative art to interpret life and society with some of its foibles along with what is good. We CS(OS) No. 3010/2012 Page 36 of 66 must not look upon such human relationships as banned in toto and for ever from human thought and must give scope for talent to put them before society. The requirements of art and literature include within themselves a comprehensive view of social life and not only in its ideal from and the line is to be drawn where the average man moral man begins to feel embarrassed or disgusted at a naked portrayal of life without the redeeming touch of art or genius or social value. If the depraved begins to see in these things more than what an average person would, in much the same way, as it is wrongly said, a Frenchman sees a woman's legs in everything, it cannot be helped. In our scheme of things ideas having redeeming social or artistic value must also have importance and protection for their growth."
Supreme Court of India Cites 15 - Cited by 112 - M Hidayatullah - Full Document

Ram Jethmalani vs Subramaniam Swamy on 3 January, 2006

Hence, it cannot be gainsaid that the modern mediums of communication are undoubtedly vital for keeping the public debate alive on various issues of national importance, but at the same time the restrictions imposed under Article 19(2) cannot be encroached. This court in the celebrated judgment of in Ram Jethmalani vs Subramaniam Swamy 126 (2006) DLT 535 defined defamation as a public communication which tends to injure the reputation of another. It dwelled upon the balance between the right to reputation and held that law of defamation, by making actionable certain utterances, runs counter to another widely accepted legal tenet-the right to freedom of expression, but the two have been harmonised by judicial process so that an individuals right of privacy and right to protect his honour and reputation is CS(OS) No. 3010/2012 Page 28 of 66 preserved and at the same time his fundamental right to free speech is also protected. The court also explained the defenses of truth, fair comment and privilege available in a suit for defamation as under:

K.V. Ramaniah vs Special Public Prosecutor on 18 April, 1960

In the case of K.V. Ramaniah vs Special Public Prosecutor AIR 1961 Andhra Pradesh 190, cited in the above judgment of Madhya Pradesh High Court, the court CS(OS) No. 3010/2012 Page 46 of 66 took a view that it is impossible to accept the argument that freedom of speech in Article 19(1) must be taken to mean absolute freedom to say or write whatever a person chooses recklessly and without regard to any person‟s honour and reputation. It would be relevant to reproduce the relevant paragraphs of the said judgment as under:-
Andhra HC (Pre-Telangana) Cites 33 - Cited by 10 - Full Document

Binod Rao vs Minocher Rustom Masani on 10 February, 1976

29. At this stage, we wish to clarify that the reliance on the above judgments is only to show that "prior restraint" per se has not been rejected as constitutionally impermissible. At this stage, we may point out that in the present IAs we are dealing with the concept of "prior restraint" per se and not with cases of misuse of powers of pre- censorship which were corrected by the Courts [see Binod Rao v. Minocher Rustom Masani reported in 78 Bom LR 125 and C. Vaidya v. D'Penha decided by Gujarat High Court in Sp. CA 141 of 1976 on 22.03.1976 (unreported)]
Bombay High Court Cites 89 - Cited by 8 - Full Document
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