CASE ANALYSIS PROJECT

Subject – Law of Crimes

Topic – Hate speech

SUBMITTED BY:
Neel Kaith (22BWL015) & Tanishk Savera (22BWL034)

SUBMITTED TO:
Prof. (Dr.) Anjani Singh Tomar
Head, Academic Affairs & Professor of Law
Gujarat National Law University

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 Declaration
This is to certify that the research project titled “Case analysis – Hate speech’ is
an original work of Neel Kaith (22BWL015) and Tanishk Savera (22BWL034).
It is also certified that no part of the research paper has been plagiarized by any
other existing body of research work.

Name of the students: Neel Kaith (22BWL015) & Tanishk Savera

(22BWL034)

Date: 07/09/2023

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3
 GNLU Project* Details and Academic

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Semester: (22BWL015 ) & (22BWL034), SEM - III
Subject: LAW OF CRIMES
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Student Signature & Date Neel Kaith & Tanishk Savera

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 Acknowledgement

We would like to express our heartfelt gratitude and appreciation for the
generous help, unwavering support, and seamless cooperation extended to us
during the course of our research work by our esteemed professor and teacher,
Prof. (Dr.) Anjani Singh Tomar.
We are also indebted to the staff and administration of Gujarat National Law
University, whose unwavering cooperation has been indispensable in the
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 Table of Contents

 Cover page……………………………………………1
 Declaration……………………………………………2
 Academic Integrity form………………………………3-4
 Acknowledgement…………………………………….5
 Table of Contents……………………………………..6
 Introduction…………………………………………...7-8
 Provisions In Indian Penal Code………………………8-9
 Case Analysis………………………………………….9-20
 Conclusion…………………………………………….21
 Bibliography…………………………………………...22

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 1. Introduction
Hate speech is described in the Oxford Dictionary of Law as "Public speech that
expresses hate or encourages violence towards a person or group based on
something such as race, religion, sex, or sexual orientation".1

Laws regulating public conduct of individuals and their speech have seen their
genesis in the early 20th century during the era of civil rights movement,
Following World War II, When American civil rights organizations began to
push for limits on hate speech directed at racial and religious minorities in the
1950s. In 1952, Beauharnais v. Illinois case, the supreme court of The United
States of America upheld collective libel legislation, which was a significant
legal success for the introduction of hate speech laws.2

In India, Laws regulating hate speech have been enacted in several different
legislations and statutes, with the aim to protect the sentiments of various
religious, ethnic, caste and cultural groups as well to maintain the social
stability of the country. Conflicts between various accounts and interpretations
of what constitutes the public interest exist in a pluralistic democracy. As long
as differences stay within the bounds of polite conversation, democracy
survives. A dynamic society needs dissident and critical viewpoints. However,
caution must be exercised to avoid public conversation from being used to
advance speech that is disruptive to the peace.3

Hate speech is described as an incitement to hatred directed principally towards

a group of people based on their race, ethnicity, gender, sexual orientation, or
other characteristics. This definition is found in the 267th Report of the Law
Commission of India.

1
'Hate Speech’, Oxford Dictionary of Law (7th edn, OUP 2013).

2
Waldron, J. (2014) The harm in hate speech. Cambridge: Harvard University Press.
3
Kaur, R. (2009) Censorship in South Asia: Cultural regulation from sedition to Seduction. Bloomington:
Indiana University Press.

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This research project aims to conduct an analysis of various provisions provided
specifically in the Indian Penal Code,1860 that are used by law enforcement
agencies to prosecute hate speech. This will be done by conducting an In-depth
analysis of several influential cases that have contributed to development of the
jurisprudence of hate speech and have broadened or defined the elements of
hate speech.

2.Provisions In Indian Penal Code Prohibiting Hate Speech

While The Indian Penal Code doesn’t define provide a concrete definition of
what constitutes as “Hate Speech”, it has provided several sections which
prohibits acts that can come under the umbrella term of hate speech. Some of
the laws provided in the Indian Penal code are: -

Section 153A: This particular section penalises any Individual who attempts to
Promote animosity between different social communities on the basis of
religion, caste, ethnicity, Geographical location, cultural heritage or engaging in
any act which can be considered discriminatory and can potentially disrupting
public harmony between different social communities.4

Section 153B: According to Indian Penal Code Section 153B, those who make
or publish statements that incite animosity or discord among various racial,
religious, linguistic, or regional groups face up to three years in prison or a fine,
and if the offense is committed in a place of worship or during religious
ceremonies, up to five years in prison and a fine.5

Section 292: In accordance with Section 292 of the Indian Penal Code, it is
unlawful to sell, distribute, display, or possess any objects or materials that are
lascivious or likely to deprave or corrupt others. Offenders may be sentenced to

4
Indian Penal Code 1860, s153(A)
5
Indian Penal Code 1860, s153(B)

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up to two years in prison and a fine for their first offense, and up to five years in
prison and a higher fine for subsequent offenses.6

Section 293: According to Section 293 of the Indian Penal Code, anyone who
sells, distributes, exhibits, or circulates obscene objects to anyone under the age
of twenty can be sentenced to up to three years in prison and a fine, and in the
event of a second conviction, up to seven years in prison and a higher fine.7

Section 295A: The Indian Penal Code's (IPC) Section 295A tries to prevent
activities that inflame religious feeling. The Section discusses intentional and
malicious actions designed to offend someone's religious sentiments by
disparaging their religion or religious beliefs. The IPC classifies as an offense
all actions that offend or seek to insult a religion or religious beliefs, whether
they are spoken, written, on signs, or in any other way that is apparent. 8

Section 505: Anyone who makes or spreads statements or rumours with the
intent to incite crimes against the State or public harmony, cause mutiny among
military personnel, or promote hatred between various religious or social
communities can be punished with up to three years in prison, a fine, or both. If
the offense is committed in a house of worship, the sentence may be increased
to five years in prison and a fine.9

3.CASE ANALYSIS

3.1 Pravasi Bhalai Sangathan v, Union of India & Ors., AIR 2014 SC
1591.10

Bench: B.S. Chauhan (J), M.Y. Eqbal (J), A.K. Sikri (J)

6
Indian Penal Code 1860, s 292
7
Indian Penal Code 1860, s 293
8
Indian Penal Code 1860, s 295 (A)
9
Indian Penal Code 1860, s 505
10
Pravasi Bhalai Sangathan v, Union of India & Ors., AIR 2014 SC 1591

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Petitioner’s counsel: Shri Basava Prabhu S. Patil

Respondent’s counsel: Shri Sidharth Luthra ASG, Shri Rajiv Nanda, Shri
Gaurav Bhatia, AAG for the State of UP. Ms. Meenakshi Arora, counsel for
election commission of India.

Sections of laws involved:

1. Section 153A & 153B of IPC

2. Section 295A of IPC
3. Section 298 of IPC
4. Section 505(2) Of IPC

Background: This particular case is regarded as one of the landmark cases

when it comes to defining and expanding the jurisprudence of hate speech in
Indian Penal Code. Petitioner submitted an instant writ petition, in the nature of
public-interest seeking to remedy concerns arising out of “hate speeches”.
Petitioner sought prayers that: a) Issue a suitable writ, order, or decree in the
nature of a mandamus declaring that speeches that incite hatred or denigration
on the basis of religion, caste, region, or ethnicity are in violation of Articles 14
(Equality before the Law), 15 (Prohibition of discrimination on the basis of
religion, race, caste, or place of birth), 16 (Equality in matters of public
employment), 19 (Protection of certain rights regarding freedom of speech,
among other things.

b.) Issue appropriate writ, order, decree in the nature of mandamus declaring
that “Fraternity” forms part of “Basic Structure” of the Constitution.

The petitioner argued that the reliefs requested by the petitioner are consistent
with the design of the Indian Constitution because "hate speeches" made by
elected officials, political figures, and religious leaders that are primarily
motivated by religion, caste, region, or ethnicity work against the idea of
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fraternity embodied in Articles 14, 15, 19, 21, and 38 of the Constitution and
also violate the fundamental obligations under Article 51-A.

The petitioners demanded that the State implement stronger regulation and take
immediate action against those who promote hate speech because they believed
that the current rules pertaining to hate speech were insufficient.

ANALYSIS: In this case, the three- judge bench of the supreme court analysed
the issue of hate speech and based on the consultation of law commission and
foreign judgements propounded by the Supreme Court of Canada in
Saskatchewan (Human Rights Commission) v. Whatcott 2013 SCC 11 came to
defined Hate speech as “an effort to marginalise individuals based on their
membership in a group. Using expression that exposes the group to hatred, hate
speech seeks to delegitimise group members in the eyes of the majority,
reducing their social standing and acceptance within society.”

It observed that Hate speech lays the groundwork for later, broad attacks on
vulnerable that can range from discrimination, to ostracism, segregation,
deportation, violence and, in the most extreme cases, to genocide.

Judgement/Ratio Propounded: The Court held that in order to prosecute the

Individual who engage in such acts, the Legislature has already given an
adequate and appropriate remedy. As a result, the party who has been wronged
must use the legal recourse. Not the lack of laws but rather their ineffective
application is the main issue. Therefore, in order to enforce the current legal
system, both the government and civil society must play their respective roles.
Since the writers of such remarks may be charged under current penal law,
effective control of "hate speeches" at all levels is necessary. All law
enforcement authorities must make sure that the current legal framework is not
reduced to a mere formality. The maxim "salus reipublicae suprema lex" (safety
of the state is the highest law) requires enforcement of the aforementioned rules.

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It dismissed the petition, further adding that it called for issuing directions
which can’t be executed, adding that bodies such as The National Human Rights
Commission would be well within its power if it decides to initiate suo-motu
proceedings against the alleged authors of hate speech.

Finally, it urged the Law commission to carefully examine the concerns

mentioned above, defining the term "hate speech" before making suggestions to
the Parliament about how to improve the Election Commission and reduce the
threat of "hate speeches" no matter when they are delivered.

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3.2) Ramji Lal Modi vs The State Of U.P 1957 AIR 62011

Bench: Das Sudhi Ranjan (CJI), Imam Syed Jaffer (J), Das S.K. (J), Menon P.
Govinda (J), Sarkar A.K (J)

Petitioner’s counsel: S. K. Kapur

Respondent’s counsel: G. C. Mathur

Section of laws involved:

1. Section 153A of IPC
2. Section 295A of IPC

Background: Petitioner, Ram Lal Modiji was an editor, publisher and printer of
a monthly magazine called “Gaurashak”, committed to protecting cows. The
petitioner was prosecuted as a result of a contentious piece that was published in
the magazine's November 1952 edition. He was prosecuted in accordance with
Indian Penal Code Section 295A, which makes maliciously insulting a religion
illegal. The lower courts sentenced him to prison after finding him guilty of
purposefully upsetting Muslims' religious sentiments. He filed an appeal of this
ruling and contested the legality of section 295A.

Lower court’s Judgements: District Magistrate of Kanpur charged the

Petitioner under section 153A and 295A of the Indian Penal Code. After this, the
session’s court sentenced convicted him and sentenced him to rigorous
imprisonment of 18 months with a fine of 2000 rupees.

Decision by High Court: Allahabad high court held that the article published
by petitioner, Ram Lal, can be considered as a strategic attempt at outraging the
religious sentiments of the Muslim community.

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Ramji Lal Modi vs The State Of U.P 1957 AIR 620

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Decision of Supreme Court: Final Judgement by the apex court held that
section 295A of the Indian Penal Code can be considered within the protection
of article 19(2) of the Indian Constitution.

3.3) Sri Baragur Ramachandrappa & Ors vs State of Karnataka & Ors.12

Bench: B.P. Singh (J), Harjit Singh Bedi(J)

Petitioner’s counsel: Mr. Raju Ramachandran

Respondent’s counsel: Shri Uday Holla

Section of laws involved:

1. Section 95 of Code of Criminal Procedure
2. Section 96 of Code of Criminal Procedure
3. Section 124-A of Indian Penal Code
4. Section 153-A of Indian Penal Code
5. Section 292 of Indian Penal Code
6. Section 293 of Indian Penal Code
7. Section 295-A of Indian Penal Code

Background: In 1995, Dr. P.V. Narayanna wrote a book called

"Dharmakaarana" that told the tale of Basaveshwara, Akkanagamma, and
Channabasaveshwara in the first person, with Basaveshwara serving as the
narrator. The book was chosen by the Karnataka Sahitya Academy as the best
novel of 1995 for its annual award. It is believed that some notable individuals,
including Shri B.D. Jatti, the former vice-president of India, wrote to the state
government suggesting that the novel be forfeited because some of the
statements made therein were objectionable, inflammatory, hurtful, and
insulting to the sentiments and feelings of the Veerashaivas and the followers of
Basaveshwara.

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Sri Baragur Ramachandrappa & Ors vs State of Karnataka & Ors

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Trial Court’s Judgement: The Court then proceeded to analyses the facts of
the case against the backdrop of the legal argument and noted that the cruel
narrative portrayed by the author in Chapter 12 about Channabasaveshwara
being Akkanagamma's unwed child was Offensive and hurtful.

The Court finally found that the explanation tendered by the author for the
change of residence was the subject matter of a raging debate amongst
historians and religious functionaries and he had merely adopted this story for
the Novel, was unacceptable and without any foundation.

Final Judgement: On the grounds that his right to freedom of expression is

unaffected, the Supreme Court of India ruled that no one has the right to hurt
another person's sentiments. India is a diverse country with a lot of different
religions, languages, cultures, etc. Unwanted criticism of other people's
religious beliefs is not acceptable.

3.4) Sujato Bhadra vs State of West Bengal (2005) 3 CALLT 436 HC13

Bench: D K Seth (J), A K Basu(J), S Pal (J)

Petitioner’s counsel: Souvik Mitra

Respondent’s counsel: Manas Kumar Das

Section of laws involved:

1. Section 95 of Code of Criminal Procedure

2. Section 295A of Indian Penal Code
3. Section 96 of Code of Criminal Procedure

Background: In 2003, the Poet Taslima Nasrin Published an autobiography

book titled, known as “Dwikhandito”. Immediately upon its release, the book
became a subject of intense controversy, in India and Bangladesh, with many

13
Sujato Bhadra vs State of West Bengal (2005) 3 CALLT 436 HC

16
stating that the book was a Deliberate Scheme to hurt the feelings of Muslim
community in the State of West Bengal and Bangladesh. Few months after the
release of the book, the government of West Bengal decided to prohibit the sale
of the book, citing the provision of section 95 of the Criminal Procedure Code
and framing it as an attempt to destroy public harmony under the section 295A
of the Indian Penal Code. The Petitioner challenged this move in the high court
of West Bengal.

Court’s Judgement: This case is significant in properly defining the elements

of “what constitutes as hate speech”. The court held that A State Government
opinion must be formed before a book may be banned. Such an opinion must be
expressed as reasons in any notification or declaration that the State
Government may issue. The judgment that must be made relates to a book to the
degree that it includes material prohibited under Section 295A IPC, adding that
a publication cannot be banned unless the issue qualifies as Section 295A IPC
mischief.

The court defined the ingredients of section 295A as: A Person with Deliberate
and Malicious intent to outrage the religious feelings of any class of citizens
of India, insults or attempts to insult the religion or the religious beliefs of
that class

Court’s judgment placed an emphasis on the presence of deliberate and

Malicious intent in the individual’s action. Without the malicious of intent, the
provision of 295A cannot be applied to a particular case – if the remarks were
anything that was done accidentally, haphazardly or with an inadequate attempt,
it wouldn't be covered by Section 295A of the IPC.

3.5) Mahendra Singh Dhoni vs Yerraguntla Shyamsundar (2017) 7 SCC

76014
14
Mahendra Singh Dhoni vs Yerraguntla Shyamsundar (2017) 7 SCC 760

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Bench: Dipak Misra, (CJI)

Petitioner’s counsel: Ms. Liz Mathew, Mr. M.S. Philip

Respondent’s counsel: Mr. Jaideep Singh, Mr. Himanshu Shekhar, Mr. Sajad
Sultan, Ms. Aishwarya Bhati, AOR Mr. T. Gopal, Ms. Tanuja Patra, Ms. Heena
Khan

Section of laws involved:

1. Section 295A of Indian Penal Code

2. Section 34 of Indian Penal Code

Background: In one instance, a magazine disseminated a photograph of the

cricketer Mahendra Singh Dhoni dressed as Lord Vishnu with the caption
“Divine power of Big Deals”. The prosecution claimed that the image offended
the religious beliefs of Lord Vishnu's followers. An F.I.R was registered against
Mahendra Singh Dhoni under section 295A read along with section 34 of Indian
Penal Code citing this image as attempt to outrage the religious feelings of
followers of Lord Vishnu. Petition was transferred to supreme court filed
challenging the validity of the F.I.R.

Court’s Judgement/ratio propounded: The court held that Although Section

295A does not list all offenses that are punishable, any act that insults or
attempts to disrespect the faith or religious beliefs of a group of persons is
punishable. It only punishes acts of insult or attempts to offend the religion or
religious belief of a class of people that are committed with the purposeful and
malicious goal of upsetting that class of citizens' religious sensibilities. Insults to
religion made unintentionally, negligently, or without any purpose to
intentionally or maliciously offend that class's religious sensibilities are not
covered by this Section. The Constitution Bench further highlighted that the
aforementioned rule only sanctions the more severe kind of insult to religion

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when it is committed with the express purpose of upsetting the religious
sentiments of that particular class. Emphasis has been placed on how likely it is
for the aforementioned heightened type of insult to disrupt public order and so
merit punishment.

The court quashed the criminal proceedings initiated against the petitioner citing
that, the allegations remotely do not satisfy the essential ingredients of the
offence, further adding that if criminal proceedings against the co-accused -the
editor and publishers of the magazine had also been quashed. It passed the order
of quashment keeping in view the criminal miscellaneous petition filed in this
case for quashing and also not to allow more space for abuse of the process of
the Court.

Lastly it Issued a message of caution to The Magistrates who have been given
the authority to take cognizance and issue summonses must carefully examine
whether the accusations made in the complaint proceeding satisfy the essential
elements of the offense, whether the concept of territorial jurisdiction is
satisfied, and whether the accused is actually required to be summoned.

3.6) Munawar S/o Iqbal Faruqui Vs. State of Madhya Pradesh (2021)15

Bench: Rohit Arya, (J).

Petitioner’s counsel: S/Shri Anshuman Shrivastava and Soumil Ekadi

Respondent’s counsel: Shri Amit Sisodia

Section of laws involved:

1. Section 295A of Indian Penal Code

2. Section 298 of Indian Penal Code
3. Section 269 of Indian Penal Code

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Munawar S/o Iqbal Faruqui Vs. State of Madhya Pradesh (2021)

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 4. Section 188 read with section 34 of Indian Penal Code

Background: comedian named Munawar Faruqui along, with other

comedians Sadakat Khan, Edwin Anthony, Prakhar Vyas, Priyam Vyas, Nalin
Yadav (organizer of the show), were booked under booked under Section
295A,298,269,188/34 of the Indian Penal Code due to alleged insults to
Hindu Deities. On 01/01/20201, a standup comedy show was organized at
Munro Cafe, (56 Shops) Indore where the aforementioned comedians were a
intentionally making crude and obscene comments about Hindu deities and
BJP National President Amit Shah. As a result, the comedians offended and
injured the religious beliefs of the complainant who originally filed an F.I.R
against the Munawar and others.

The accused were detained and brought before the Judicial Magistrate, First
Class, Indore, following the filing of the FIR.

Decision of the Judicial Magistrate: On 02/01/2021, the Magistrate denied

their application under section 437 of the Penal Code, and the Court below
denied their plea for bail under section 439 of the same law in the challenged
judgement.

Analysis: The accused argued that the case had been falsely filed against
them and that they are innocent. They put on a comedy performance, but
they didn't do anything that would have offended someone's religious
sensibilities. The components of section 295A IPC are not applied in this
case.

Given that Article 19(1)(a) of the Indian Constitution upholds freedom of

speech and expression, making jokes about political officials won't cause any
offense. The applicants are comedians who aim to amuse and make others

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 laugh, and they have no desire to offend anyone's religious sensibilities in
society.

After the application of bail was moved to High court of Madhya Pradesh
(Indore Bench), the counsel for the petitioner (Munawar & ors) further
submitted that the petitioners were innocent and that they had been falsely
accused in the crime. Counsel relied on Judgement of Apex Court in the case
of “Mahendra Singh Dhoni Vs. Yerraguntla Shyamsundar and another,
2017 (7) SCC 60” that held that that any act of insult to religion committed
with the purpose to offend the religious sentiments of that class but done
unintentionally, negligently, without any deliberate or malicious motive shall
not be covered under section 295A IPC. The candidate has no prior criminal
history.16

He Further argued that due to COVID-19, the trial was not likely to conclude
in the near future. Under such circumstances, the applicant needed to be
enlarged on bail on such terms and conditions.

Final Judgement: The Court after examining all evidences presented by the
applicant and respondent, rejected the petitioner’s request for grant of bail
and further stated that Mutual trust, faith, and respect amongst all Indian
people are fundamental elements of cohabitation in a welfare society based
on the rule of law. It further added that, According to Article 15A(e) and (f)
of the Indian Constitution, every citizen of the nation as well as the States
have a responsibility to foster harmony and a sense of shared brotherhood
among all Indians, regardless of their differences in religion, language,
region, or social class. They also have a responsibility to value and preserve
the rich cultural heritage of our composite society.

16
1Mahendra Singh Dhoni vs Yerraguntla Shyamsundar (2017) 7 SCC 760

21
 4). CONCLUSION/WAY FORWARD

“Actus Non Facit Reum Nisi Mens Sit Rea”, which states that an act may only
be classified as a crime if it was done with the intention to commit a crime, is
the foundation of criminal law. Due to the lack of evidence proving purpose,
hate speech differs from all other criminal offenses in that it is hard to tell
whether a statement was made intentionally or not.

It may be concluded that hate speech provisions of the IPC solely attempt to
penalize such intentional and malicious acts that are done with the goal to
offend religious emotions after comprehending and analysing all landmark
judgements in this case analysis project. The clause of 295A was passed and
added to the criminal code in 1927, the year that Hindu-Muslim riots broke out
as a result of inflammatory remarks made by British officials while they were
still in control of India.

The goal of hate speech laws of the Indian Penal Code is to suppress activities
that offend the religious emotions of any faith or class of persons who are
protected by the law of the state. This section of the IPC unquestionably fits
within the scope of Article 19(2) of the Indian Constitution. While there are
arguments that Section 295A is being abused, it can also be seen that this
Section safeguards the interests of all the religions that are thriving in India,
which is renowned for its multiethnic culture.

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 5.) BIBLOGRAPHY

1. 'Hate Speech’, Oxford Dictionary of Law (7th edn, OUP 2013).

2. Waldron, J. (2014) The harm in hate speech. Cambridge: Harvard
University Press.
3. Kaur, R. (2009) Censorship in South Asia: Cultural regulation from
sedition to Seduction. Bloomington: Indiana University Press
4. Indian Penal Code 1860, s153(A)
5. Indian Penal Code 1860, s 153(B)
6. Indian Penal Code 1860, s 292
7. Indian Penal Code 1860, s 293
8. Indian Penal Code 1860, s 295 (A)
9. Indian Penal Code 1860, s 505
10. Pravasi Bhalai Sangathan v, Union of India & Ors., AIR 2014 SC 1591
11. Saskatchewan (Human Rights Commission) v. Whatcott 2013 SCC 11
12. Ramji Lal Modi vs The State Of U.P 1957 AIR 620
13. Sri Baragur Ramachandrappa & Ors vs State of Karnataka & Ors. (2014)
14. Sujato Bhadra vs State of West Bengal (2005) 3 CALLT 436 HC
15. Mahendra Singh Dhoni vs Yerraguntla Shyamsundar (2017) 7 SCC 760
16. Mahendra Singh Dhoni vs Yerraguntla Shyamsundar (2017) 7 SCC 760
17. Munawar S/o Iqbal Faruqui Vs. State of Madhya Pradesh (2021)

23
24