Freedom of the Press, its Contents and Facets

Author(s): Soli J. Sorabjee

Source: India International Centre Quarterly , DECEMBER 1986, Vol. 13, No. 3/4, THE
RIGHT TO BE HUMAN (DECEMBER 1986), pp. 173-184
Published by: India International Centre

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Freedom of the Press, its Contents and
Facets
Soli J. Sorabjee

FREEDOM of expression has been humanity's yearning, in times

ancient and modern. "Where a man cannot call his tongue his own,
he can scarce call anything else his own" was the cri de coeur of
Cato, who greatly influenced American thinking prior to American
Independence in 1776. To Junius, the liberty of the Press was "the
palladium of all the civil, political and religious rights."

The enduring vitality of these beliefs is evident from the sacrifices

that people have made over the years for their preservation. The Press,
like the Church, has a long list of martyrs. They testify to mankind's
abiding belief that thought remains a soliloquy unless men can
communicate their ideas to one another. It is the free and frank
exchange of views between individuals and groups that ensures the
progress of civilization.

Our founding fathers attached great importance to the freedom of

speech and expression, and the freedom of the Press. Their experi
ence of waves of repressive measures during the colonial British rule,
when the Press was bludgeoned by sedition, trials and forfeiture of
security deposits, and their memory of the valiant struggle of the
Indian Press against measures designed to stifle criticism and silence
agitation, convinced them of the immense value of this right in a
sovereign democratic republic which India was to be under its
Constitution. They knew that when avenues of expression are closed,
government by consent of the governed would soon be foreclosed.

173

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174 SOLI J. SORABJEE

Freedom of the Press is not mentioned, or guaranteed specifically

as such, in the chapter on Fundamental Rights in our Constitution. At
first blush this appears to be incongruous. During the framing of the
Constitution, questions were raised about incorporating freedom of
the Press as a distinct fundamental right. According to the Constitu
tional Adviser, Dr. B.N. Rau, it was hardly necessary to provide for it
specifically, because freedom of expression would include freedom of
the Press. In the course of the Constituent Assembly debates, Dr.
Ambedkar expressed the same view, and thought that "no special
mention is necessary of the freedom of the Press at all."

In a series of decisions, the Supreme Court has ruled that free

dom of the Press is implicit in the guarantee of freedom of speech and
expression, because it is nothing but an aspect of freedom of speech
and expression and partakes of the same basic nature and character.
The legal consequence is that freedom of the Press is one of the
fundamental rights guaranteed in our Constitution. Yet one can
appreciate the sentiment that urges its specific incorporation as a
fundamental right in its own independent right, rather than by way of
implication or inference by way of judicial interpretation.

Members of the Constituent Assembly hailed the guarantee of

free speech and the freedom of the Press by Article 19(1 )(a) as the
'most important', 'the charter of liberties', 'the crux of fundamental
rights', etc.1 Vet they did not accept the theory of any fundamental
rights including the freedom of the Press. Whilst recognizing that
without a free Press there can be no free society, they realized that
freedom of the Press was not an end in itself—but a means to the end
of a free society. A Free Press, which is an inestimable privilege,
without a disciplined sense of responsibility, may well become "the
scourge of the Republic". Accordingly the founding fathers, whilst
guaranteeing freedom of the Press as a fundamental right, also
enacted at the same time the heads on which permissible legislative
restrictions may be imposed on its exercise.

Three distinct and independent prerequisites have to be satisfied

before freedom of speech and expression and freedom of the Press
can be constitutionally restricted:

(i) The restriction imposed must have the authority of law to support it.
Fundamental rights cannot be restricted by a mere executive order or an
administrative instruction which lacks statutory basis.

1Article 19 (1) (a) in the Constitution reads thus:

All citizens have the right
(a) to freedom of speech and expression.

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 FREEDOM OF THE PRESS 175

(ii) The law must fall squarely within one or more heads provided in Article
19(2) .namely: the security of the State, sovereignty and integrity of India,
friendly relations with foreign States, public order, decency or morality,
contempt of court, defamation or incitement to an offence. The only rest
riction which may be imposed are on heads covered by clause (2) of
Article 19, and none other.
(iii) The restriction must be reasonable, not excessive or disproportionate.
Legislation which arbitrarily or excessively invades the right cannot be
said to be reasonable. The procedure and the manner of imposition of the
restriction must be fair and reasonable.

Does freedom of the Press occupy a preferred position in the con

stitutional scheme? In the view of some American jurists and judges
freedom of the press, freedom of speech and freedom of religion
are in a preferred position. This doctrine has not found favour with
our Supreme Court. Under our Constitution no fundamental right can
be said to be superior to another. Article 19 does not have a hierarchy
of rights having preference for one freedom over another.

Nonetheless, freedom of the Press has been accorded a high

place, and there are dicta of the Supreme Court describing this
freedom as "the most cherished and valued freedom in a democracy",
"one of the pillars of democracy", "the Ark of the Covenant of
Democracy", "the most precious of all the freedoms guaranteed by our
Constitution". Moreover, freedom of the Press has been treated with
special solicitude and has received generous support from the judiciary.
Indeed Justice Venkataramiah, speaking for the court in its recent
judgment in the newsprint duty case, has given a categorical assur
ance that as long as "this Court sits" newspapermen need not have
the fear of their freedom being curtailed by unconstitutional means.

What is the reason for the judicial soft spot for this particular
freedom? Does a media person belong to a special class or enjoy a
special privilege? Certainly not. As far back as 1914 in Arnold's case,
the Privy Council declared that the freedom of the journalist is an
ordinary part of the freedom of the subject, and no privilege
attaches to his position. Our Supreme Court endorsed this position
in 1959, and there has been no change since then. In the USA on
occasions intense loyalty to the First Amendment has transcended
obedience to some of the Ten Commandments. Yet the claim that
the Press Clause of the First Amendment gives journalists a distinct
and preferred status has not slowed general endorsement in the US
Supreme Court.

II

A close analysis would indicate that one of the reasons for the special

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176 SOLI J. SORABJEE

judicial treatment of the guarantee of Article 19(1 )(a), which embodies

the freedom of the Press, is that it embraces a variety of rights. The
right guaranteed is not merely the individual right of the proprietor of
the newspaper, or the editor or the journalist. It includes within its
compass the collective right of the community: the right of citizens
to read and to be informed, to impart and receive information. In
essence, it is the right of the public to know. The true rationale of the
freedom of the Press is not merely to enable the Press to make
profits, not to set newsmen apart as a favoured class, but to bring
fulfilment to the right of the people of India to know about the
functioning of government and the working of public institutions.

No democratic government can survive without accountability;

and the basic postulate of accountability is that the people should have
information about the functioning of the government. Consequently,
they must have access to information about every public act that is
done in a public way by their public functionaries. This is necessary
to form informed and intelligent decisions and for holding the
institutions of government accountable.

Thus the concept of freedom of the Press has a dimension and

range that is vastly different from the ambit and content of other
individual freedoms. It embodies the democratic principle of accoun
tability, and is an instrument of democratic control. That is the view
taken by our Supreme Court and also by the US Supreme Court.

Today a citizen is largely dependent on the Press for the quality and
the extent of news. He can seldom obtain for himself the information
needed for the intelligent discharge of his political responsibilities.
In seeking out the news, the Press therefore acts as the represen
tative or, more appropriately, as the custodian and trustee of the
public. The Press therefore ought to serve as a forum for the public,
through which it would know freely what is going on in government
and public institutions. If indeed government shall be based on the
consent of the governed, it is essential that it shall be grounded on
adequate information and discussion, aided by the widest possible
dissemination of information from diverse and antagonistic sources.
In that sense a press is free, and the mighty 'pillar of democracy'
subserves its purpose, to the extent that it promotes expression of
opinion in all its phases, and disseminates news from as many
different sources. Thereby, it serves public interest by throwing up a
broad spectrum of views. It also fulfils the individual interest of the
citizen by enabling virtually everyone—especially the inarticulate ones
who are generally ignored—to find some place for the expression of
their opinions.

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 FREEDOM OF THE PRESS 177

III

The crux of the matter is that the constitutional guarantee of free

dom of the Press is not so much for the benefit of individual press
persons as it is for the benefit of the public. The true rationale and
the sustaining vitality of the freedom of the Press lies in its ability
and willingness to effectively perform its societal role of ensuring that
public discussion of governmental affairs is informed. Informed
public opinion is the most potent of all checks on maladministration.
It is also unfettered; because 'to allow it to be fettered is to fetter
ourselves'. The function of the vigilant critic of government is more
necessary now than ever—and more difficult to perform—when the
weapons of government propaganda are so strong and subtle.

If misgovernment and the abuse of power are to be checked and

controlled, what is required is more than oratorical exhortations. It
will need the combined efforts of the media and public-interest
groups and public-spirited organizations. They cannot succeed without
information because, in the felicitous language of Anthony Lewis,
'Information is power. Officials struggle to control it, and in that
struggle the citizen-critic needs constitutional support.' To that extent
the Press will be able to perform its role of foreclosing both public
authorities and private agencies from assuming guardianship of the
public mind.

If we have not grasped this fundamental principle, then the

freedom of the Press is a hollow slogan, a narrow self-serving concept,
and the judicial encomiums showered on it are undeserved rhetorical
flourishes.

Should the Press fail to play this role, it cannot legitimately or

morally invoke the benefit and protection of the constitutional gua
rantee of freedom of the Press. A newspaper that systematically and
intentionally suppresses information restricts the content of infor
mation and denies its accessibility to the public who are its readers,
forfeits its trust as the national trustee of a vital public resource. It is
no longer the educator of the public, and has ceased to be its watchdog
and sentinel. Such a newspaper may yet claim the fundamental right
to carry on trade and business in which case the scope for imposition
of restriction is wider; but it is not inarguable that it has placed itself
beyond the pale of the guarantee of Article 19(1)(a) and cannot lay
claim to its benefits.

The problem however is who will determine whether the newspaper

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178 SOLI J. SORABJEE

in question has so disentitled itself. On the balance we should console

ourselves with the conclusion of Madison, "that it is better to leave a
few of its noxious branches to their luxuriant growth, than, by pruning
them away, to injure the vigour of those yielding the proper fruits."

It might be well to recall what Walter Lippman once wrote in

another context:

For every right that you cherish you have a duty which you must fulfil. For
every hope that you entertain, you have a task you must perform. For every
good that you wish could haopen -you will have to sacrifice your comfort and
ease. There is nothing for nothing any longer.

IV

Restraints on Press freedom stem from a variety of sources: (a)

government or official agencies, (b) management, (c) the editorial
board, (d) labour union with political affiliations, and (e) unofficial
agencies and bodies advocating particular moral or political theories,
for example, the anti-abortion campaigners.

The most frequent occurrence is governmental interference and

pressure. But pressures also build up when the newspaper industry is
concentrated in a few powerful hands, and these few persons on
account of their position of dominance are able to discriminate and
restrict the flow and content of information. The Second Press Com
mission in its report has rightly bemoaned the indifference 'to the
reality and implication of non-governmental restraint on the exercise
of Press freedom.'

Restraints emanating from governmental quarters have taken

diverse forms, such as the enactment of laws providing for pre-censor
ship, seizures and demand for security deposits; restriction on the
price of newspapers, on the number of pages of newspapers and the
area that can be devoted for advertisements; withholding of govern
ment advertisements; increase in postal rates, imposition of taxes on
newsprint and canalization of import of newsprint with the object of
making its cost prohibitive.

Thanks to an independent judiciary exercising the power of

judicial review, many of these restrictions have been struck down.
The Supreme Court has ruled that it is not for government to deter
mine which newspapers should grow in page and circulation, and
which newspapers should grow only in circulation and not in
pages. In the celebrated case of Bennett Coleman, the Supreme
Court ruled that a newsprint policy under the Import and Export

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 FREEDOM OF THE PRESS 179

Control Act cannot, under the garb of distribution of newsprint,

control the growth and circulation of newspapers. In that case the
Court also recognized that advertisements are not only a main source
of revenue, but also one of the factors for circulation; and the loss of
advertisements inevitably affects the circulation of a newspaper. Thus
a restraint on advertisements infringes on the freedom of the Press.

An interesting case arose in Andhra Pradesh. The proprietor of

a leading Telugu daily Eenadu complained that government had with
drawn advertisements from its paper on account of extraneous
reasons, and this had adversely affected the revenue and circulation
of the paper. This action of the government was challenged as
unconstitutional. The High Court did not accept the contention that
any newspaper had a constitutional right to obtain advertisements
from the government. It however ruled that the government cannot
exercise this power or privilege

to favour one set of newspapers or to show its displeasure against another

section of the Press. It should not use the power over such large funds in its
hands to muzzle the Press, or as a weapon to punish newspapers which
criticize its policies and actions. It has to use the funds in a reasonable manner
consistently with the object of the advertisement, viz. to educate and inform
the public about the activities of the government.

In a recent judgment the Supreme Court held that whilst newspapers

did not enjoy any immunity from payment of taxes and other fiscal
burdens, the imposition of a tax such as customs duty on newsprint is
an imposition on knowledge. The Court was called upon to reconcile
the social interest involved in the freedom of speech and expres
sion with the public interest involved in the fiscal levies imposed by
the government "specially because newsprint constitutes the body, if
expression happens to be the soul". In the absence of any material
on record to establish whether the customs duty on newsprint had
imposed a distinct and noticeable burden on the newspapers which
was directly attributable to that levy, the Court remanded the matter
for the reconsideration of the Central Government.

The most serious and virulent attack on Press freedom was launched
by the government during the Proclamation of Emergency, which was
issued on 26 June 1975 and remained in force till its revocation in
March 1977.

Along with the Proclamation of Emergency, a host of repressive

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 180 SOLI J. sorabjee

measures was introduced. For the first time in free India, pre-censor
ship was imposed by promulgating a Censorship Order dated 26 June
1975 Simultaneously with the promulgation of the Censorship Order,
certain guidelines and instructions were issued to the Press. They
were purely executive in character and had no statutory force; cen
sorship authorities followed them blindly.

One of the instructions issued was as follows: "Nothing is to be

published that is likely to convey the impression of a protest or
disapproval of a government measure". Consequently anything that
smacked of criticism of governmental measures or actions was almost
invariably banned, even if the criticism was sober and moderate.

Without the censor's prior scrutiny and permission no news or

report could be published nor any comment made on the Emergency;
the presidential order suspending habeas corpus; the place or
conditions of detention of persons arrested under MISA; the family
planning programme; or the imposition of Presidential rule in the
states of Tamil Nadu and Gujarat.

The censer's scissors were applied arbitrarily, and in a few cases

its decisions 'bordered on the farcical.' Quotations from Gandhi,
Tagore end Nehru were banned. A statement by the Chairman of the
Monopolies and Restrictive Trade Practices Commission criticizing
the working of public sector undertakings was blacked out.

The reaction of the Indian Press was depressing. For the first two
days there was some semblance of opposition from certain sections
of the Press. Blank editorials appeared as a gesture of protest, but
official threats, conveyed unofficially, caused even these to vanish.
Thereafter there was, by and large, meek submission. The first and
most crucial round of the battle for freedom of the Press and civil
liberties was lost without a struggle, in the first week after the
Emergency.

Leading newspapers and their editors fully realized both the

absurdity and the illegality of the censor's action but they were
unwilling to challenge it in a court of law. They invented their own
reasons. The truth was that fear had also struck the Press. Editors
were keen to retain their jobs, and printers did not want to risk forfei
ture of their presses. Detention under MISA of Kuldip Nayar, a
journalist with an international reputation, heightened the atmosphere
of terror.

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 FREEDOM OF THE PRESS 181

Fortunately there were a few in the Press world who believed

that freedoms are not for the craven and the cringing, and they were
willing to stick their necks out. There were also a few fearless lawyers
who were never unwilling to take up unpopular cases to uphold civil
liberties. Most fortunately, the judges of the State High Courts
valiantly rose to the occasion and fully justified their role as protectors
of the people's basic rights, despite threats of transfer from one state
to another and their possible supersession.

Minoo Masani was the first to challenge in a court of law the

censor's action in respect of his monthly journal, Freedom First. He
was followed by another veteran journalist, Y.D. Lokurkar.

The High Court of Bombay displayed traditional courage and in

dependence in striking down the censor's orders and upheld the
right of dissent even during the Emergency. The High Court laid down
certain important principles in the matter of censorship.

...True democracy can only thrive in a free clearing house of competing

ideologies and philosophies—political, economic and social—and in this the
Press has an important role to play. The day this clearing house closes down
would toll the death-knell of democracy. It is not the function of the censor
acting under the Censorship Order to make all newspapers and periodicals
trim their sails to one wind or to tow along in a single file or to speak in chorus
with one voice. It is not for him to exercise his statutory powers to force
public opinion into a single mould or to turn the Press into an instrument for
brainwashing the public.

The saddest part is that the managements and editors of big

national dailies, with the honourable exceptions of the Indian Express
and The Statesman, were unable to break the fetters of fear. They were
afraid to avail of the limited Press freedom which was secured during
the Emergency through the courts, thanks to the valiant effort of
owners and correspondents of small newspapers and journals.

It is fortunate that these cases involving issues of Press freedom

and censorship did not come up before the Supreme Court for determi
nation. The record of the Supreme Court, headed by Chief Justice Ray
in the matter of the fundamental rights of citizens during the Emergency,
was disastrous. Its judgment in the habeas corpus case, to the effect
that even a proven malafide order of detention cannot be challenged,
is an indication of the low watermark that the court had reached in
its role as protector of the fundamental rights of the people.

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182 SOLI J. SORABJEE

VI

One of the significant ways in which media can discharge its societal
function is by optimum utilization of its freedom for the protection and
promotion of human rights. The final Report of the International
Commission for the Study of Communication Problems, presided over
by Sean MacBride, emphasizes that the defence of human rights is
one of media's most vital tasks. The contribution of media should be
to expose by constant publicity all infringements, wherever they occur,
and to support those whose rights have been neglected or violated.
One of the recommendations of the Report is that communication
needs in a democratic society should be met by the extension of specific
rights such as the right to be informed, the right to inform, the right to
privacy, the right to participate in public communication—all elements
of a new concept: the right to communicate.

Much criticism can be levelled at the working of the Supreme

Court. But it must be conceded that its greatest achievement has
been in revolutionizing the concept of locus standi, that is, the
standing of the person to approach the court. The normal rule is that
the person whose rights are injured must himself invoke the court's
jurisdiction; it cannot be done by proxy. For instance, B cannot come
to court complaining that A's rights have been infringed. The Supreme
Court has carved out an exception to this rule in cases of social
action litigation. The Court in such cases has repeatedly ruled that
where judicial redress is sought of a legal injury or a legal wrong
suffered by persons, who by reason of their poverty, disability or
socially or economically disadvantaged position are unable to approach
the Court, any member of the public acting bonafide can maintain an
action for judicial redress. This has been done even by addressing a
letter drawing the Court's attention to such legal injury, and the Court
has swung into action.

The Supreme Court, by a farsighted and generous interpretation

of the guarantee of freedom of speech and freedom of the Press, has
elevated the right to know and the right to access to information
to the status of fundamental rights —on the principle that certain
unarticulated rights are immanent and implicit in the enumerated
guarantees.

What tremendous scope the judiciary has offered the Press for
effectively exposing deception in the working of government and
official agencies, and also for making basic human rights in the Cons
titution living realities for the large numbers of the needy and the

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 FREEDOM OF THE PRESS 183

oppressed—the majority of Indians. It is heartening that this oppor

tunity has not been neglected by the Press. Press persons have
moved the court directly, and public-spirited persons and organiza
tions have approached the courts on the basis of Press reports in
cases of human rights violations. The results have been gratifying.
The twin blessings of a free Press and an independent judiciary,
taking human rights seriously and sensitive to suffering, have
provided much-needed succour to large segments of the oppressed
and the downtrodden: undertrials languishing in jail for years; bonded
labourers living in sub-human conditions of servitude; victims of blind
ings in Bhagalpur whose existence and fate would have been
otherwise unknown; prisoners suffering cruel and degrading treat
ment in jails; numerous workers in mines and quarries denied the
bare minimum conditions for living with dignity; inmates of asylums
and women's homes suffering in silence their inhuman treatment;
and numerous victims of exploitation for whom the freedoms
enshrined in the Constitution were heretofore a cruel joke.

The role of the Press in exposing duplicity and corruption in

government has been appreciable. Exposure of the sordid machinations
of Watergate and the official lies in relation to the conduct of the
Vietnam war provide classic instances of the inestimable value of a
free Press.

The well-researched and probing articles of Arun Shourie on the

functioning of Mr. Antulay led to public interest litigation in the
Bombay High Court. In the course of the proceedings many lapses
and instances of abuse of power came to light. As a consequence of
the judgment of the Bombay High Court, Mr. Antulay, one of the most
powerful of Chief Ministers, had to resign.

VII

Yet much remains to be done in the 'vast undone' area of human

rights. Publicity is one of the most effective ways of implementation
of human rights. Here the Press has a definite role to play. Violations
of human rights should be given prominent and persistent publicity
in a daily column devoted to the issues on human rights. Specific cases
of individual violations should be followed up to the hilt as also cases
of persons whose human rights have been grandiloquently upheld
by courts but have not yet secured any real and lasting benefits. What
are the reasons for this strange phenomenon? Above all, close
coordination between media persons and public-spirited lawyers
some still exist—is necessary for proper planning and strategy in

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 184 SOLI J. SORABJEE

cases of social action litigation which has come to stay in our

country.

What about the future? Will the Press grow and become strong
enough to withstand the kind of onslaughts it faced during the Emer
gency? Or, will it again crawl when all it was asked to do was to bend?
Will it honour its trust to the people of India by fulfilling their right to
know and also respect the rights of those who have no Press but
want and need to express themselves? Will it act as their sentinel,
ever ready and unafraid to speak out against deception and
oppression?

The answers will depend not on the state of the laws or the provi
sions of the Constitution but on the integrity of the Press, the extent of
development of the culture of an independent Press. Lippman rightly
warned that the real danger to the Press springs not so much from the
pressures and intimidation to which it may be subject but from the
sad fact that journalists can be captured and captivated by the
company they keep, their constant exposure to the subtleties of power.
Judicial protection is certainly helpful but that is not all that is
needed. Freedoms cannot be preserved for an inert people by the
Constitution or the Courts. That lesson was bitterly brought home
during the last Emergency. It is trite that civil liberties do not defend
themselves. That is true of Press Freedom also.

In the ultimate analysis, the reality of Press Freedom will be

realized by the will and determination of its champions and defenders
to assert their rights and defend this precious freedom, remembering
at all times the spirit of Benjamin Franklin who told his compatriots:

They who would give up essential liberty to purchase a little temporary safety
deserve neither liberty nor safety.

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