Parliamentary Privileges in India

By Subodh Asthana - August 4, 2019

Image Source: https://bit.ly/2yDAgkQ

This article is written by Akash R. Goswami, student of the faculty of

law, Aligarh Muslim University. In this article, he has discussed the
Parliament Privileges in India, its types, freedom of speech with respect
to Parliament and other aspects of Parliamentary privilege in Indian
Parliament.

Table of Contents
 1. Introduction
2. Who Enjoys Parliamentary Privileges
2.1. Article 105
3. Article 194
4. Types of Parliament Privileges
4.1. Collectively enjoyed by the member of Parliament
4.2. Individually enjoyed by the member of Parliament
5. Freedom of Speech
5.1. Some limitations are also there which should be followed in relation
to claim privileges
6. Right of Publication of Proceedings
7. Other privileges
8. Freedom from arrest
9. Freedom from appearing like a witness
10. Right to regulate internal affairs
11. Right to exclude strangers
12. Parliamentary privileges and fundamental right
13. Parliamentary privileges and law courts
14. Breach of privileges
15. Contempt of court
15.1. Giving misleading statement in the house
15.1.1. Disturbance by outsiders
15.1.2. Assault on members
15.1.3. Writings or speeches defining the personality of members
16. Punishment
17. Freedom of the press and the parliamentary privileges
18. Codification of the parliamentary privileges
19. Judicial review of the parliamentary privileges
20. Parliamentary immunities and the principle of natural justice
20.1. Facts regarding the case
20.1.1. Arguments raised by the members
20.1.1.1. Judgment by the court
21. Misuse of Parliamentary Privileges
22. Conclusion
23. References

Introduction
The privilege may be defined as an exceptional right and exemption.
The expression “Privilege and Immunity”, under the Constitution of
India and in the arena of Parliament, donates certain special and
exceptional rights of Lok Sabha and Rajya Sabha or its individual
members who are generally accepted as a necessity for the
implementation of constitutional functions.

In the case of Raja Ram Pal vs. The Hon’ble Speaker Lok
Sabha[1]. Supreme Court in their own view defines the word
“privilege” that it is immunity or a right provided to the specific person.
In another way around what a person can not do in general, now
he/she eligible to do a certain act.

For example, being an Attorney General you have the right to watch
any proceeding of any house, but not in the case of an ordinary person.
Privilege consists of the known laws, customs and usage of Parliament.
Thus, the term privilege is referred to as the special rights that are
available to a different extent and in various forms for the members of
Parliament throughout the world. However, the term applies to certain
immunities enjoyed by both the houses of the Parliament collectively,
and members of each house individually.

It is the privilege conferred on any member of parliament that he is

immune from whatever he will say on the floor of the house, and in
case of detention whether in civil or criminal, no member shall be made
liable and detained 40 days before and 40 days after the session of the
house. But there is a condition to comply with the availment of these
privileges. If a person ceased to be a member of Parliament, then the
privileges are called off. So in order to enjoy immunities, one should
have to be a member of any house of Parliament.
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Who Enjoys Parliamentary Privileges

Sir Thomas Erskine define the expression “Parliamentary Privilege” as
the total sum of the specific rights enjoyed by each House of
Parliament collectively is a constituent part of Parliament, and by the
members of every house of Parliament one by one, without which they
could not proceed with their functions, and which exceed those
possessed by different bodies and people.
The privileges only given to the members of the Parliament, and also
conferred on the person who actively participates in any of the
committee and in the function of the parliament, just like it
incorporates on Attorney General and union ministers but in case
of President, even though he is a part of Parliament, does not
entrust with parliamentary privileges.

Article 105
Privileges, power, right etc for the two houses of Parliament individually
and of the members and committees thereof-
1. Comes under the concern in the provisions of the constitution and
the rules, regulations and standing circulations which mandates
procedure and conduct of Parliament, and it shall be necessary that
freedom of speech in every house of parliament provided without any
checks and balances. As if there is restriction then the representative
will hesitate to express their feelings, which is not the aim of the
Democratic form of Government.

2. No member of the Parliament should be made liable for any

proceeding initiated against him in the court in respect of anything
said, vote which was given by him or any committee thereof, and no
person should be made liable in context to the publication by him or
under any authority empowered by either house of Parliament of any
report, vote, proceeding or paper.

3. In another sense, the privileges immunity and power of each of the

two houses of Parliament and of its members and committees
thereof, shall be such as may define time to time and provide by the
Parliament itself and through established procedure by law, and, until
so defined shall be a matter of concern for those of that house and of
members of that house and for its committees immediately before
the date of initiation of section 15 of the constitution by the (forty
four amendment) act, 1978.

4. The above mentioned constitutional provisions of clauses (1),(2) and

(3) shall apply in relation to the person who by virtue has the right to
freedom of speech, and otherwise to take part in proceedings of the
Parliament of any of its committee thereof, the clauses will apply in
relation to the Parliament.

Article 194
1. This subject comes under the provisions of the constitution and
rules, regulations and standing orders which regulates the procedure
of the State Legislature, and there shall be freedom of speech for the
member of the legislature in every state.

2. No member of the state legislature shall be compelled for any

proceeding initiated against him in any court of law in regards to
anything utter or any vote given by him or her in the state
legislature and any of its committee thereof, and no person shall be
made liable to prosecute in the context of the publication by him or
under any authority of a house of state legislature of any paper, vote,
report, or proceedings.

3. In another sense, the privileges and immunities of the house of the

state legislature, and of its members and the committees of the
house os state legislature shall be such as may be defined by the
state legislature from time to time through established procedure of
law, and, until so define, shall be the subject matter to those of that
house and of its member and its committee thereof, immediately
before the section of 26 of the constitution by the (forty four
amendment) act,1978.

4. Above given constitutional provisions of clauses 1,2 and 3 shall apply

in relation to the person who by virtue of this constitution has the
right to freedom of speech, and the other way around to take part in
the proceedings of the house of the state legislature and any of its
committee thereof as they pertain in relation to members of the
state legislature.

It was observed from the above two articles of the Indian Constitution
that the position of the house of the Parliament is identical to the
position of the state legislature. Therefore, Article 105 apply, mutatis
mutandis, to the state legislate as well.

Types of Parliament Privileges

Collectively enjoyed by the member of
Parliament
No person whether a member or a stranger can be arrested and no
legal proceedings can be initiated against him either criminal or civil,
within the premises of the house of the Parliament and without the
approval of the proceedings officer of that particular house.

No court shall have the right to investigate the proceedings of any

house of the parliament and any of its committees.

Parliament shall have the power to exclude guests or visitors from

the meeting of the house or also have the power to conduct a secret
meeting if the matters of national importance or any matter of public
importance.

Parliament shall have the right to penalize its member or an outsider

for committing the breach of its privileges. And for contempt by
reprimand, admonition or imprisonment and also have the right to
expel and suspend in case of a member.

Individually enjoyed by the member of

Parliament
When a parliament is in session, a member of Parliament or a person
on whom this right and immunities conferred may refuse to appear
in the court of law or to present any evidence in court.

Members of the Parliament cannot be arrested when the sitting of

the Parliament in session and 40 days before the commencement
and 40days after the end of the session.

No member shall be made liable to any proceeding in any court for

whatever he or she said or any vote was given by him or her during
the session in the Parliament or its committees.

Freedom of Speech
The spirit of the parliamentary form of democracy is frank free and
valiant discussions in the house of the parliament. For the authority like
parliament freedom of speech plays a very indispensable role that
provides opportunities to the members of the houses to express their
feelings without any sort of fear, hesitation, being penalized for
offences such as defamation, innuendo, etc.. The recognition of the
right to freedom of speech in parliament came to known in the
seventeenth century in the case of SirJohn Elito.

The council of state i.e. Rajya Sabha in its XII report provides that a
Parliament can be asked a question in any court of law or any place
outside the parliament for making any disclosure or for any information
display since it will amount to inference with the right to freedom of
speech of that member. Subsequently, Lok Sabha has also propounded
that it will amount to contempt of house or breach of privilege if any
suit is initiated against any member in a court of law for what he/she
spoke on the floor of the house.

The Supreme court case of Tej Kiran Jain V. Sanjeeva Reddy held that
“once it is recognised that the parliament was in session and its
business being transacted, anything said during the clause of that
transaction was completely immune from any proceeding in any court
of law”.

Article 105, clause (1), expressly protects the right to freedom of

speech in Parliament. It provides that there shall be complete freedom
of speech in Parliament. Clause (2), further states that no member of
each house of the Parliament shall be made liable for any proceedings
in any court of law in regards to anything said or any vote given by him
or her in parliament or any committee of parliament.

No action is initiated against the member, for the offence of defamation

or in the context of words said in Parliament or its committees, neither
civil nor criminal. No imprisonment is there for the mere spoken words
by the immunity, it extends to votes, as clause (2) specifically provides
that any vote given by him/her in parliament or committee thereof.
Though it can be concluded that, the freedom of speech shall extend to
other conducts which are done and having a nexus with proceedings of
each house, such as, for notice of questions, motions, reports of
committee and the resolutions.

It is important to consider that clause (1) of article 105 comes under

the subject to the provisions of the constitution and to the standing
orders and rules for the regulation and procedures of the Parliament.
The word regulation for the procedure of Parliament comes in clause
(1) should be read in that manner so that it applies to provisions of
both i.e constitution and the rules and standing orders and circulations.

Freedom of speech in parliament becomes concern matter with

provisions of the constitution relating to the procedure and regulation
of the Parliament i.e subject to the article envisaged in part V contain
article 107 and 121. Thus, for instance, freedom of speech in
Parliament would not allow a member to talk about conduct and
manner of any judge of the high court or Supreme Court. Likewise, the
freedom of speech comes under the subject to the procedure or rules
of the house, such as the use of unparliamentary conduct and
unparliamentary language.

The freedom of speech described under article 105 (1) having a

peculiar interest and different from that right which a citizen enjoys as
a fundamental right provided under Article 19 (1) (a). The fundamental
right, freedom of speech, does have the power to protect an individual
completely for what he says. The right has come under clause (2)
which is subject to reasonable restrictions of article 19 of the
constitution. The term freedom of speech which used for article 105(1)
provides that no member of Parliament shall be made liable to any
proceedings initiated against him, whether civil or criminal, in any court
of law and for the statement made in house while debating in either
house of Parliament or any committee thereof.
The freedom of speech provided under article 105 cannot, therefore
subject to reasonable restriction likewise it is imposed in article 19 (2).
Clause (1) and (2) of Article 105 gives protection to the member of
Parliament for what is said within the boundaries of Parliament and not
what a member of Parliament may say outside. Similarly, if a member
publishes his speech outside the boundaries of Parliament, he will be
made liable if the speech found to be defamatory in regards to some
person.

The freedom of speech given under article 105 (1) and (2) refers, shall
be only available to the member of the Parliament when the session of
the Parliament is going on. Therefore, if an order of detention, which
refrains a member from attending a session of the Parliament (no
occasion shall be raised to said that the right has been invalidly
annexed.

Article 105 (2) confers privileges, in respect of anything said on the

floor of the Parliament. The word “anything” is considered as the widest
concept and it is parallel to as a whole. The only restriction arises from
the word in the Parliament, which means during the session of
Parliament and in the course in the transaction of the Parliament. Once
it was proved that Parliament was in session and its business was
carried out, anything uttered during the course of that business was
completely immune from proceedings initiated against the member in
any court. This immunity is not absolute but works with respect to the
Parliament.

It is one of the alluring features of the parliamentary form of

government that the people’s chosen representative should be free to
express themselves and their views without any fear of intimidation or
any legal consequences. What they said comes only under the purview
of the discipline and regulation of the Parliament, the good conduct of
the members and the control of the proceedings by the presiding
officer. The court has no right to say and interfere in the matter of the
Parliament and should really have none.

In a controversial case involving former Prime Minister, several union

ministers, members of parliament and others, the court held in the
case P.V. Narsimha Rao V. state JMM Bribery[] that the privilege of
immunity to exempt the member from the court proceedings in article
105 (2) should be extended to cover the scope of bribes considered by
the member of parliament for the purpose of voting in the parliament
in a particular form.

The three judges of supreme court did not consider the decision to be
right which was given by two judges and explained the expression “in
the context of” regarding article 105(2) shall be provided a wide
meaning so as to understand an act having a series of chain or
connection with the speech or a vote submitted by a member in the
parliament or any committee thereof. If interpreted, it would cover
within its core, acceptance of a bribe by the member of parliament,
further extending to make a speech or to cast his/her vote in
parliament or any committee in a particular way.

In this manner, the fix taker MPs, who had cast their vote in parliament
against no-confidence motion were held qualified for the security of
Article 105(2) and were not answerable in court for supposed
conspiracy and agreement. The Court additionally held that the bribe-
taker MP, who did not decide on the no-confidence motion was not
qualified for protection under Article 105(2).

To the pay off supplier MPs, it was held, the protection under Article
105(2) was not accessible. The court additionally decided that the Lok
Sabha could make a move for breach of benefits or disdain against the
alleged bribe providers and against the bribe-takers, regardless of
whether they were a member of parliament.

The court was anonymously said that the member of parliament who
takes a bribe, or who gives bribe but he/she does not have to
participate in the voting could not claim the privileges conferred upon
them from court proceedings under Article 105 (2). The decision of the
Apex court has imploded so much attention of the general public and
dissatisfaction among that the review petition is pending in the court.

Some limitations are also there which should

be followed in relation to claim privileges
Freedom of speech should be according to the constitutional
provisions and subject to the procedures and rules of the parliament,
provided under article 118 of the Indian constitution.

Article 121 of the Indian constitution confers that, the member of the
Parliament is not allowed to discuss the manner and the judgement
given by the judges of the supreme court and the high court. But,
even if this occurs, it is an internal matter of the parliament and the
court has no right to interfere in it.

No immunity and right could be claimed and held back by the

members for anything which is said outside the proceedings and
premises of the parliament.

Right of Publication of Proceedings

Clause (2) of Article 105 (and article 194) expressly provides that “no
person shall be compelled to made liable in regards to the publication
by him or by under the authority of either house of the parliament for
any report, paper, journal, vote or proceedings”.

Therefore, the protection did not address the scope of publication made
by the person without the authority of any house of the parliament,
however, Common law renders the defence of qualified privilege for
fare and exact official reports of proceedings of the parliament,
published in a newspaper or as here.

In Wason v. Walter C.J. Cockburn, observed that it was of public

sovereignty and comes under the subject to national importance that
parliamentary proceedings should be communicated and displayed to
the general public, which has an immense interest in knowing was
happening in parliament. But to provide an incomplete report or a
detach report which contain disconnected part and partial information
of proceedings published with the intention to injure individual
character will be disentitled to protection. A similar law is also
applicable in India.

The Parliamentary Proceedings (protection of publication) Act, 1956

provides that “not a single person shall be compelled for any
proceedings initiated against him, either civil or criminal, regarding the
publication of the proceedings, in any court of law, for a substantially
true journal and report of the proceedings of either house of the
parliament until or unless it has been proven that the publication was
made with malice intention”. Later the act was deleted during the time
of emergency in 1975.

Article 361-A provides that “protection of publication of proceedings of

parliament and state legislature” under clause (1) of this article
empowers that no person shall be made liable to any proceedings
initiated against him, either civil or criminal in any court in regards to
the publication made by him in any newspaper of a substantially true
report of any proceedings of any house of parliament or the state
legislature assembly, or as the case may be, unless the publication
made by the member is proven to have been made with the malafide
intention.

Moreover, it is also provided that notwithstanding under this clause

shall be complied with the publication of any report, paper, vote or
proceedings and securely held session of the parliament or as same as
the case in the state legislature. Clause (2) provides that clause (1) will
apply in relation to the right of publication of reports and protects it
broadcast, not detached part of any proceeding of parliament through
wireless technology, and part or any service which will broadcast by the
member in any platform or station. And insense of agency, it should be
viewed as the agency who have reported material to be published. It is
further stated in this article, the newspaper includes a news agency
which contains report material to be published in a newspaper.

Other privileges
Clause (3) of article 105, after some constitutional amendment
declares that the immunity and right of every house of the parliament,
its members and committees shall be such as furnished by parliament
from time to time and until it is done by the parliament, which it has
not yet been done, shall be dated back on 20th June 1979 i.e from
date of initiation of section 15 of the (44th constitutional amendment)
act, 1978.

Before this amendment, clause (3) provided that the parliament gives
the immunity of each house and its members shall be similar as the
house of commons in England at the time of commencement of the
constitution. This position till 20th June 1979 was in use and apply in
relation to the earlier provision, it is still relevant to depend on the laws
as it has been denoted to the English laws. A form that views it may be
concluded that there are some privileges that may not be claimed by
the parliament of India.

For example, the immunities for access to the sovereign, which is

carried by the House of Commons trough it presiding officer to have all
the time access for that particular right to the sovereign through their
chosen representative can have no value in India. Similarly, a general
warrant of arrest given by the parliament of India can not subject to be
regarded as a court of record at all in any sense.

Also, the right of the two houses of the parliament, unlike the
immunities of the house of commons and house of lords in England are
completely identical. To every house of parliament, accordingly,
entrusted the right, which is empowered by the House of Commons in
the United Kingdom.

Freedom from arrest

It given under this right, no member of parliament or state legislative
assembly shall be arrested or detained for civil proceedings initiated
against him during a period of 40 days before and 40day after the
session of the house. If a member is imprisoned during this period, he
should be set free so that he may be able to attend the session of the
house.

This immunity does not cover the circumference of arrest or

imprisonment on a criminal charge or contempt of court or in
preventive detention act. However, in case if a member is arrested, rule
261 of Lok sabha set forth the duties of the detaining body to provide
information to the house to which the member belongs to, also provide
the reason for his/her arrest or detention, also specified the time of
his/her arrest, the place where he will be confined or imprisoned and
the period how long that particular member will be detained or
arrested.

It has been observed in case of K. Anandan Nambiar V. chief secretary

governor of madras that the matter of the parliament does not enjoy
any special or specific status as compared to an ordinary citizen of this
country in regards to legally fair orders issued for detention purposes.

Freedom from appearing like a witness

The member of the parliament has the special right conferred on them
which enables them to not attending court as a witness. They are
provided complete right to attend the meetings of the house and
perform their duties without any interference while exercising their
duties from the court.
Right to regulate internal affairs
The house has the special right to manage and control its own
proceedings. The governor has entrusted with the power to call the
session of the legislature of the state. But the governor does not have
any constitutional right to give orders to the presiding officer about the
manner and conduct in which the proceedings of the house should be
carried out.

The transaction of the business carried out in the house should be

followed according to the rules of the parliament, which are provided
by the house itself. In order to strengthen this right, Article 122 (in
case of state legislative assembly) expressly provides that the
constitutional value or any proceedings shall not be called in question
on the ground of any alleged irregularity of procedure or no officer or
member of parliament in whom these powers are conferred by virtue of
the constitution for mandating the procedure or the conduct for the
business transacted out in the parliament or for maintaining orders in
parliament shall become under the subject to the jurisdiction of any
court in respect of the power empowered by him.

Right to exclude strangers

The right to exclude visitors or strangers or non-members and held a
secret session was a tradition of the house. The objective behind this to
avoid the act of threatening the member as the visitor may attempt
from galleries to interfere in the debate going on.

Rule 248 of the Lok sabha grant the power to the presiding officer,
whenever he deems fit, of order to exclude strangers from any part of
the house and when the house conducts the secret meeting no guest or
non-member is allowed to present the house, lobby or galleries of the
house. The only exception and the member of the council of states and
the person authorized by the presiding officer should be present.
Parliamentary privileges and
fundamental right
In the case Gunupati Keshavram Reddy V. Nafisul Hasan, the home
minister was detained at his Bombay residence under the warrant
directed by the presiding officer of the U.P legislative assembly for the
contempt of the house of the state legislature and was fled to Lucknow
and was house arrest in a hotel under the supervision of the presiding
officer. While filling for a writ of habeas corpus on that very that his
detention was infringed and violates the article 22(2), the Apex court
quashed the detention and gave orders for his release as he had not
been produced before a magistrate within 24 hours of his arrest as
given under Article 22.

This decision, therefore, provides that article 194 (or 105) came under
the subject to the fundamental right guaranteed under Article 22(2) in
part III in the constitution of India.

However, in case M.S.M. Sharma V. S.K. Sinah[], it was struggled by

the appellant that the immunities conferred on the house under article
194 are subject to the provision of a fundamental right which is
envisaged in part III of the constitution. In favour of his allegation, the
petitioner relied on the supreme court’s decision given in the case
Ganapati Keshavram reddy V. Nafisul Hassan.

But, in M.S.M. Sharam’s case, the Supreme Court held that in case of
dispute between Fundamental right under Article 19(1)(a) and the
immunities conferred under article 194(3), in that situation
fundamental right always occupy the place of superiority and will
prevail over the privileges conferred on the parliament and its
members, committee thereof. As in the context of article 21, on the
facts, the court did not find any infringement of fundamental rights.

Under article 143, the supreme court enlarged the proposition laid
down in the M.S.M. Sharma case held that:

We are not in the opinion that it would be correct to read the majority
judgment as laying down the general idea that whenever there
condition of imbalance between the provision of part V of article 194(3)
and any provision of the fundamental right conferred by the part III,
the fundamental right will also remain supreme over the other. The
unanimous decision, therefore, has to be taken to settle only that
article 19(1)(a) would not apply and article 21 would prevail.

There is a rule that every house provides for a committee of privileges.

In case of breach of privilege or contempt of the house is in the
question, is referred to the committee of privileges. The committee
shall have the power to summon or gives direction to call the members
or stranger before it. Refusal to present in front of the house or to
answer or knowingly gives the misleading statements is itself
considered as the contempt of the house. The committee’s
recommendations are given to the house which discusses them and
their conduct and regarding to this give their decision.

Parliamentary privileges and law courts

There is one more cornerstone to be achieved by the judiciary. The

dispute between the legislative privileges of the houses and the court
of the law came to be resolved by the supreme court of India in the
reference case, which is popularly known as the Keshav Singh’s case[]
or U.P. Assembly case.

In this case, one person named Keshav Singh who was not a member
of U.P. Assembly, published, circulate and printed a pamphlet. The
presiding officer of the U.P. Legislative Assembly admonish him for the
contempt of the house and committing the breach of the privilege of
the member Mr Narsingh Narain Panday. On the same day, Mr Keshav
Singh, who was present in the house, by his delinquent act, committed
another contempt in the house. The speaker after that, given an order
that Mr Keshav Singh should be detained and put behind the bars. A
warrant was issued in this regard for his detention in jail for a period of
7 days and he was confined.

Mr. Soloman, his council, filed a writ petition under section 491 of
Cr.P.C. along with article 226, a Habeas Corpus petition coupled and
alleged that his detention in jail was illegal, unjust and lack of legal
merit because he was not given an opportunity to defend himself and
there was an infringement of natural justice in other word is was an ex-
parte decision. The petition was taken under consideration by two
judges of Allahabad high court which gave the order to grant the
interim bail to Keshav Singh and after that he was released. But the
decision of the case was pending and would be decided on the merits
and evidence provided in the case.

On the judgement given by Allahabad high court, the state assembly,

by a resolution took the decision that the two judges, Mr Keshav Singh,
and Mr Soloman have committed contempt of the house and order that
the Keshav Singh must be immediately taken back into the jail and the
two judges and the council of Mr Keshav also brought into custody
before the house.

At this, the two judges and the advocate, by means of separate

petitions lodged and move to the high court, under article 226 (which
empowers the High Court to issue writ) contended that the resolution
appeared to be the content of court at the very first sight and it should
be set aside and its implementation would be stayed by temporary
order.

The petition was considered by the full bench of all the 28 judges of the
Allahabad high court. Later court gives the order to grant the stay for
the implementation of that resolution. The Assembly after that brings
some modification in its order and the warrant against the two judges
 which was initiated by the house was withdrawn, but the house asked
the judges to summon before it and explain their conduct. The judges
on that write an application and moved before the court against the
modify order of house and the court again granted the stay for the
implementation of the order.

At this point, the President refer this matter to the supreme court,
invoking the provisions of Article 143(1), for using its advisory power,
which provides that in the matter of law if any question is unanswered
and he needs to seek advice then in that case he can rely on the
judges of article supreme court and the high court. The main questions
arose to be were-

1. Whether the state legislature is the sole and exclusive judge of its
privileges and whether the legislature is competent enough to punish
a person for its contempt even outside of the legislature?

2. Another question was whether the high court who consider the
petition of habeas corpus challenging the validity of the detention of
a person given by the legislative assembly under a general or
unspeaking warrant has committed contempt of the house?

The supreme court given the judgment and express their support with
a great sense of majority as in ration of 6:1 and held said that two
judges did not commit contempt of house, as under article 226, which
empower every high court of India to issue the and adjudicating the
writ petitions. And the court has the power to investigate and have a
preview of judicial review to check whether the detention of that
particular person is legal or not.

The Judges further said that in India The Court shall have the power to
check the detention and in that context, they have an option for judicial
review to determine the question of the detention valid or order of
detention by state legislative assembly, under the general or
unspeaking warrant.
When we refer to Courts in England, in their case Court are not allowed
to reconsider the judgement moreover, they don’t have judicial review
power to check the validity and legality about the general warrant
issued by the House of Commons. On this condition Court further said “
in that manner such a right will not be entrusted with legislature of
India, as house of commons is an internal part of High Court, and
parliament being superior there and also due to its influential nature,
the general warrant issued by the house will not become under the
subject of judicial review, By the other courts.

But in India the condition was different, the history and background of
the legislature of India had no significance of judicial function and does
not claim to be regarded as a Court of record at all”. There it can be
concluded that the privilege enjoyed by the House of Commons is not
applicable in the context of Indian legislature.

Article 226 entrusted every High Court of India, in the matter of issuing
the writ petition of habeas corpus against any State authority or
institution which under Article 12 included the Legislature.

Article 121 of the Indian constitution provides that, the member of the
state legislative assembly is not allowed to talk about the manner and
conduct of any judge of the Supreme Court and the High Court, but if
they do then, in that case, the Court has no right in there matter to
interfere.

The court also provides that there is hardly any doubt about, that
Parliament is the sole and exclusive judge in the matter of privilege and
this fact will not be distorted and not be in dispute, also it could found
in Article 194(3). But the main question is in the concern and had
implored great attention that whether the privilege claimed by the
house of Parliament was provided by Article 194(3) or not, this
question was still to be determined by the Court.

The question whether the immunities enjoyed by the Legislature

provided under the part of Article 194(3) was subject some restriction
in respect of Part III relating to fundamental rights, was left
unanswered, however, the tussle is going to resolve. And the Court
observed that such privileges were necessarily subject to Article 21 and
22 regarded as fundamental right provided in the Indian Constitution.

Breach of privileges
When any individual or authority does not recognize and attacks on any
of the privileges, rights, and immunities, either of the Members
individually or of the House in its collective capacity the offence is
called the breach of privileges and is punishable by as per the House
rules and regulations. Besides breaches of particular privileges, actions
must be taken in regards to the nature of offences against the
authority or dignity of the House or in other words contempt of the
house, such as disrespect to its legitimate orders upon itself, its
members or officers, are also subject to punishment as it regarded as
contempt of the House.

Contempt of the House shall be defined generally as “any conduct or

negligence which obstructs or bring inconvenience either House of
Parliament in the performance of its functions, or which obstructs or
impedes any member or officer of such House in the exercise of his
duty, or which has a capacity, directly or indirectly, to produce such
results.” It may be stated that it is not possible to describe exhaustively
every act which might be considered by the House as contempt of the
House. The House may punish a person who is found to be indulged in
breach of privilege or contempt of the House either by reprimand or
admonition or by imprisonment for a specified period of time.

In the case of its own members, two types of punishment can be given
by the House, namely, suspension from the duties of the House and
expulsion. The penal jurisdiction of the House is neither confined to its
own members nor to its officers, but enlarged to all contempts of the
House, whether committed by members or by persons who are not
members, irrespective of the fact that the offence is committed within
the House or beyond its premises. The power of the House to punish
any person who commits a contempt of the House or a breach of any of
its members privileges is the “keystone” of Parliamentary privilege.

It is the power that gives effect to the privileges of Parliament and

pertain its supreme character so far as the protection of its rights and
the maintenance of its dignity and authority are concerned. The power
exercised by each House of Parliament and the House of the State
Legislature to punish the person for contempt or breach of privilege is a
general power of committing for contempt analogous to that likewise
by the Superior Courts and is in its discretionary nature. It flows from
the provisions given under Article 105(3) of the Constitution as
affirmed by the Supreme Court in the case of Rajaram Pal & Ors. Vs.
UOI & Ors[10].

Norms of punishment for breach of privilege or contempt of the House

may impose the following punishments on a person found to be guilty
of breach of privilege or contempt of the House.

(1) Imprisonment: The period for which the House can direct an
offender to prison for contempt or breach of its privileges is limited by
the duration of the session of the House. As soon as the House
discontinues its session the prisoner is set free. There are a number of
cases where the audience shouted slogans and threw leaflets from the
visitor’s gallery on the floor of the House, the offenders were sent to
prison for committing contempt of the House by creating disorder in
the public Galleries.

(2) Admonition or reprimand: In cases where the offence of breach

of privilege or contempt is not so serious like petty the warrant for the
imprisonment of the offender by way of punishment the person
concerned may be summoned to the Bar of the House and admonished
or reprimanded by the presiding officer by order of the House. The
admonition is the mildest form of punishment, whereas reprimand is
the more serious remark of the displeasure of the House.

(3) In the case of its own members, two other punishments are also
available to the House by which it can express its displeasure more
strongly rather by admonition or reprimand, namely:

(i) Suspension from the service.

(ii) Expulsion from the House

The penalization powers of the House for committing a breach of

privilege or contempt of the House are, however, exercised only in
extreme cases where a deliberate attempt is made to disturb the house
of Parliament to show disrespect and further in order to depict the
institution has lost the public confidence. It is also a tradition of the
House that unqualified and unconditional regrets sincerely expressed
by the persons guilty of breach of privilege and contempt of the House
can be accepted by the House. And the House normally decides in such
cases to best consult its own dignity by providing no further notice of
the matter.

Contempt of court
There are no codified rules which clearly state what action constitutes a
breach and what punishment is granted. Although, there are several
acts which are considered by the house as the contempt. It is generally
viewed as the actions which intended to obstruct the proceedings of
the house and produce a disturbance for the members.

Some of them are briefly discussed.

Giving misleading statement in the house

The acts which are done only with the purpose to mislead and intended
to deceive are considered as a contempt of the house. If the statement
is uttered by a person who believes the information to be true then
there is no breach violated. It has to be proven that the statement
recorded by him/her deliberately with the intention to mislead the
house.

Disturbance by outsiders
Any conduct of disturbance created by chanting slogans or throwing
leaflets etc. with the purpose of disturbing the procedure and
functioning of the house are regarded as the major contempt of the
house. The person who commits shall be confined by the house for a
specific period of time or an alert is given depending on the sincerity of
the case.

Assault on members
The privilege is provided when the member is performing his duties. An
assault was done by any person on the member of parliament when he
discharged his responsibilities is dealt as contempt of the house.

Writings or speeches deNning the personality of

members
Any speech published, advertised or libel made against the character of
any member also regarded as the contempt of the house. These are
ascertained to be necessary because it affects the confidence of people
for their representative and role of the member by diminishing the
respect for him.

It is, clearly inferred that any attack on the immunity of the members
by any intend is considered as a violation of the rights and the
parliament can take action concerning the same

Punishment
1. Imprisonment – If the breach of immunities committed is of a
heinous nature, punishment can be given in the form of detention or
imprisonment to any of the member or the person liable to it.

2. Enforcing fine – If in the perspective of the house, the violation or

contempt committed is of economic misdeed and any pecuniary
profit has been made from that breach then, the parliament can
impose fines on the person.

3. Prosecuting the offenders – The parliament has the power to

prosecute the member or an outsider if anyone committing the
breach.

4. The punishments are given to its own members – If any

contempt is committed by the members of the parliament then he
has to face penal consequences initiated by the house itself which
could also affect in the interruption of the privileges of the member
from the house.

Freedom of the press and the

parliamentary privileges
The parliamentary privileges restrict the freedom of the press, which is
a fundamental right. Degree of higher care and Caution has to be taken
by the press while publishing any report, paper of the proceedings of
the parliament or the conduct of any member. There are some
instances where the press can be held liable for the contempt of the
house-

1. Publishing any sort of news vandalizing the character of any member

of the parliament.

2. Any premature or incomplete information published.

3. Misrepresenting or Misreporting the proceedings of the house.

4. Publishing the obliterate section of the proceedings.

 Indeed of the truth that the freedom of the media comes under the
protection of parliamentary privileges, certain amendments have been
made in respect to the indemnity of the freedom of the press. If the
elementary rights are being violated, there is no sign of democracy.
The freedom of the press has to be defended because in India there is
an indispensable need to inform everyone about the acts of our
representatives Parliamentary Proceedings (Protection of the
publication) Act, 1977 [10] protects the rights of the press under given
circumstances-

1. The report is made for the Publicam Bonum i.e for the public good

2. The report should not reveal any secret meeting of the house.

3. The reports of the proceedings somehow to be true and real.

4. The report is made without malice intention.

CodiNcation of the parliamentary

privileges
Parliament member enjoys supreme powers by virtue of being a
member of the parliament. But there is always a doubt of misuse of the
privileges conferred on them because they do not have any sort of
restrictions and checks and balances on their privileges. They have the
right to be the judge in their own case, regulate their proceedings, and
also to decide what was considered the breach and what punishment
should be given for the committed of that breach, are solely decided by
them.

The power vested in their hands are too wide in scope as compared to
the fundamental rights vested in the hands of citizens. Having a no
codification of the privileges, they have gained omnipotent power
because there is no expressed provision to put a bar on their
immunities. The privilege from any civil arrest for 40 days before and
after the session and during the session of the house results that they
are free from arrest for even more than 365 days. No law has been till
date enacted by the parliament for the codification of the parliamentary
privileges.

It is mostly resisted by the members because the enactment of the law

will be made privileges subject to the fundamental rights and would be
entitled to judicial analysis. Justice M.N. Venkatachaliah is the head
of the Constitution Review Commission suggest to define and confine
the privileges for the free and independently functioning of the
legislature. This raised the presumption that codification will involve
interference of the court as if the matters would be presented in a
court of law. Non-codification of privileges has provided the immense
opportunity of greater powers vested and being enjoyed by the
members of the house. But, now the time has come to confine and
define the privileges and actions must be taken in case of misuse, for
smooth and accordingly functioning of the parliament without any
conflict.

Judicial review of the parliamentary

privileges
The Indian judiciary has been entrusted to take care of and vested with
the responsibility for the protection of the fundamental rights conferred
by the Constitution. Parliament members claim absolute sovereignty
over their privileges and also have the privilege that if in any case they
do not want the judiciary to interfere in that. But, the judiciary is
considered as the guardian and exclusive protector of our Constitution
and it cannot stood firmly if any of the fundamental right of the citizen
is violated due to privileges conferred or when there is an escape from
any criminal liability.

The judiciary has to take a step on the wrongs committed by the

members of the house who are taking the benefit of the privileges. The
Supreme Court in Keshav Singh’s case held that the privileges
conferred on the members are subject to the fundamental rights and in
case of conflict fundamental right will prevail.

The Supreme Court has also observed that any conflict arising between
the privileges and the fundamental rights would be resolved by
adopting the harmonious methodology. The judiciary is aware enough
about the fact that it does not have jurisdiction over parliamentary
matters but Judicial body should have the power to decide, for the
betterment of the community that any offence should be resolved by
the court as it considered fit.

Parliamentary immunities and the

principle of natural justice
In a judgment which was by the Apex Court judges in the case of
Algaapural R. Mohanraj v Tamil Nadu[11]. it was held that the principle
of natural justice cannot be taken for granted by the members of the
Parliament and its immunity committee.

Facts regarding the case

On the date 19-02-2015, some of the members of the Tamil Nadu
State Legislative Assembly was suspended on the grounds of
misbehaving charge. In furtherance of this, a privilege committee came
into existence to investigate the conduct and acts of the members of
the Assembly, and further proceedings related to breach of immunity. It
was found and proposed that the necessary action must be taken
against six members, who are alleged for the breach of immunity.

By a decision dated 31-03-2015, the members were dispersed for a

period of ten days. Further, it was extended and cover the scope to
reduce their salaries and giving any other benefit or perk till the
dispersion period. A writ petition was filed by the members of the
Assembly in the Apex Court under Article 32 of the Indian Constitution.
Arguments raised by the members
The argument was raised by the appellant that their elementary rights
(fundamental rights) under Article 19(1)(a), 19(1)(g), 14 and 21 of the
Indian Constitution have been infringed by the resolution passed by the
Parliament of India.

Judgment by the court

The Court does not entertain the argument of the petitioners that the
decision offended Article 19(1)(a) and 19(1)(g). It further accepted the
argument that the rights were violated under Article 14 of the
Constitution in the context of the right to equality. The court noticed
that the video recording which showed the act of the members of the
legislature, amounting to the breach was not adjacent before the
appellants.

If it would have been available then they may have had the chance to
explain their actions or why they behave like this. It was further
decided and ordered by the Court to Backed the salary and other
benefits of the petitioners.

Misuse of Parliamentary Privileges

There is hardly any doubt, that a member of Parliament accepts the
bribe to influence the conduct done by him/her as a member is a
contempt of house, there is uncertainty whether the Parliamentary
Privileges is a bar to the prosecution of the members for law offences
of bribery and corruption. Salmon report commission on the standard
of code and conduct of parliament stated that the statutory offence of
corruption and bribery do not apply to the members of either house of
the parliament. The question of whether the legislation is needed in the
area of corruption in public life is not solved yet, how Parliamentary
privileges affect the criminal liability deemed to be a big issue before
the various committees.
In 1972 the question raised whether the court has jurisdiction over MPs
in respect of the misuse of parliament privileges as indulging in taking
bribes and increasing corruption. A Conservative MP, Mr. Harry
Greenway, had been accused of taking bribe jointly with an executive
engineering company, which had its contacts with British rail and was
an employer in his constituency.

In order to curb the problems, the parliamentary privilege committee

decided to codified its privileges so that the member will have some
checks and balances over them. As we generally see that the level of
debate proceeds in parliament is nothing more than mud-slinging over
each other, and after that member take the protection that they
exercise their privilege in order to show the general public the truth
about their representative.

This act not meant to show the truth but to defame the other member
and influence their performance while exercising his/her duties through
character assassination.

Privileges give numerous perks and facilities to the members of the

house and the member will start misusing it. They use the privileges
for their personal means and for monetary profit

These all are the issue can be put in the heading of misuse of
parliamentary privileges. And these issues are not new they have they
root since so long, but there is a hope which we can rely upon and that
is judicial system, which is exclusively deemed as the sole guardian of
our constitution, as the constitution is the supreme law, and all laws
contradicting the provisions of our constitution shall be declared as null
and void.

However, Buckley J ruled that Parliamentary privileges were no bar for

prosecution initiated on members of parliament found to be alleged in
common law offences. Unfortunately, the case never proceeds to full
trial.
Conclusion
It has been shown that there is an unmistakable division about what all
rights and benefits are supreme and what isn’t. In India Legislative
Assemblies and Parliament never release any legal capacity and their
verifiable and protected foundation does not bolster their case to be
viewed as courts of record in any sense. No insusceptibility from an
investigation by courts of general warrants issued by House in India
can, in this way, be asserted.

Both the Parliament and State Legislatures have an obligation to look

cautiously under the steady gaze of making any law so it doesn’t hurt
different rights. It is likewise an obligation of the individuals to
appropriately utilize these benefits and not abuse them for substitute
purposes that are not in the support of general enthusiasm of the
country and open on the loose.

The Court has developed the correct convention to decide the benefits
of the parliament that the Indian Parliament can receive. The Doctrine
of Pen, Ink and Indian elastic hypothesis.

As to obtaining models and instances of benefits from the Constitution

of different nations, the Supreme Court in case M.P.V. Sundaramier and
Co. v. Territory of Andhra Pradesh[12]. advised: “The strings of our
Constitution were no uncertainty taken from other Federal Constitution
yet when they were woven into the texture of our Constitution their
compass and their composition experienced changes. In this manner,
significant as the American choices are as indicating how the inquiry is
managed in the Federal Constitution extraordinary consideration ought
to be taken in applying them in the understanding of our Indian
Constitution.”

The National Commission to Review the Working of the Constitution

(NCRWC) has additionally prescribed in the report, that “The benefits of
 lawmaking bodies ought to be characterized and delimited for the free
and autonomous working of Parliament and State Legislatures.”

It might in this way be expressed that the codification of benefits would

reinforce the standard of law. Along these lines, it may be effectively
reasoned so as to decide the benefits, the house can’t aimlessly
embrace a similar that exists in Britain however needs to choose and
examine whether it suits the Indian Democracy and does not outrage
the Republic for the country.

To know more about parliamentary privileges and immunities, please

Click Here.

References
1. https://indiankanoon.org/doc/1757390/

2. https://www.5rb.com/case/john-v-associated-newspapers-ltd/

3. 1970 AIR 1573, 1971 SCR (1) 612

4. https://www.indiatoday.in/magazine/cover-story/story/20051226-
jharkhand-mukti-morcha-bribery-scandal-in-1993-corruption-got-
institutionalised-in-india-786386-2005-12-26

5. https://trove.nla.gov.au/newspaper/article/13189722

6. 1966 AIR 657, 1966 SCR (2) 406

7. https://indiankanoon.org/doc/528695/

8. 1959 AIR 395, 1959 SCR Supl. (1) 806

9. AIR 1965 All 349, 1965 CriLJ 170

10. https://indiankanoon.org/doc/544981/

11. https://indiankanoon.org/doc/38086329/

12. 1958 AIR 468, 1958 SCR 1422

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