International Journal of Research Publication and Reviews, Vol 5, no 8, pp 109-115 August 2024

International Journal of Research Publication and Reviews

Press Freedom in India: A Complete Analysis

ABSTRACT

Government of India on 12th of July,2024 in the Official Gazette of India notified that 25th of June will be observed as ‘Samvidhan Hatya Diwas’ taking into
consideration the Emergency imposed by the then Prime Minister Indira Gandhi which lead to numerous Human Rights Violations caused by the misuse of
Constitutional Powers. Among those human rights violation Freedom of Press was also curtailed which got a huge criticism throughout the World. So, this research
paper majorly focuses on the Freedom of Press in India and how throughout the years changes have occurred in the Freedom of Press.

Keywords: Press, Freedom, Article 19, Democracy, Constitution

Introduction:

Whenever the question regarding best form of Government is asked the usual answer which comes to everyone’s mind is democracy and indeed it is true
that democracy is the one of the best human produce where each and every individual irrespective of their caste, creed and religion gets a chance to
participate in the formulation of the Government. Even in the Preamble of our Indian Constitution it has been mentioned that the people of India are the
source of Authority. From this one can very well assume the importance which a democratic state gives to its Citizens.

But to ensure a healthy and effective functioning of a democracy it is vital to have a free press within the country. Press plays a very important role in
ensuring vigilance among the citizens enabling them to understand the policies and laws , making an informed decisions and hold those in power
accountable in case of failure of any policy. It also acts a watchdog by exposing the corruption and transgression, and promoting transparency and
accountability.

A free press has been usually labelled as the oxygen of a democratic state; it is difficult for one to survive without another. Press in our country has been
regarded as the fourth pillar of democracy. Thus, this paper will be highlighting the importance of press freedom in India and how freedom of press has
been affected throughout the history.

Meaning of Press Freedom:

The word ‘Freedom’ signifies “The state or fact of being free from servitude, constraint, inhibition, etc.” 1Press freedom means the right which allows
citizens and various associations to express their ideas, opinions and share any credible information without any of intrusion or fear of bowdlerization
from the authorities. Generally, it doesn’t include defamation, hate speech or those acts which spur violence within the society.2

In those nations where freedom of press is not ensured journalists, media person, bloggers, political critics are generally threatened.3 According to the
report of Committee to Protect Journalists 1900 journalist and media person were killed all around the Globe between 2000-2024 while in India this
number amounts to 72 deaths.4

The World’s first governmental law towards the Freedom of press was passed on 2 December, 1766 in Sweden, which at that time also included present
day Finland. For the first time the importance of freedom of speech and expression was acknowledged in a legal constitutional document.5

1
https://www.oed.com/dictionary/freedom_n (last visited on July 20,2024)
2
https://www.humanrightscareers.com/issues/freedom-of-the-press-101-definition-examples-significance/ (last visited on July 20, 2024)
3
Ibid
4
https://gijn.org/stories/doc-of-the-day-global-impunity-index/ (last visited on July 20,2024)
5
https://unric.org/en/swedish-freedom-of-press-ordinance-among-new-inscriptions-on-unescos-memory-of-the-world-register/ (last visited on July
20,2024)
 International Journal of Research Publication and Reviews, Vol 5, no 8, pp 109-115 August 2024 110

Importance of press freedom in a democracy:

A democratic society cannot function properly without press freedom because it denies citizens access to a wide range of reliable information, which is
critical for decision-making and for holding those in positions of authority responsible. The media serves as a watchdog in a democratic society, bringing
to light wrongdoing such as corruption and power abuse that may go unreported or ignored by other organizations. In order to ensure that public access
to information regarding government policies, decisions, and activities, as well as that officials are held accountable for their acts, it is imperative that
there exist free and independent media outlets. Apart from these vital roles, freedom of the press is essential for safeguarding human rights. Documenting
violations of human rights, drawing attention to problems that could otherwise go unnoticed, and promoting justice and responsibility are all important
tasks that journalists frequently carry out. In general, a democratic society needs free speech in the press to function. It supports the rule of law and human
rights, gives citizens access to a variety of reliable information, and pushes for accountability and openness in the government.6

In the present day time press plays such a significant role that the freedom of press is even mentioned by United Nations General Assembly in its Universal
Declaration of Human Rights(UDHR) which was formulated in Paris on 10 December 1948. In this 30 Articles are there mentioning the common human
rights goals which are to be achieved by all people and all nations.7

Article 19 of UDHR deals with freedom of speech it says that everyone has the right to freedom of speech, which includes the ability to hold beliefs
without hindrance and the ability to look for, accept and share ideas and information across all boundaries and media.8

In various regions of the globe, media organizations are facing censorship, penalties, and shutdowns, with journalists being arrested, intimidated, and
even killed just for carrying out their duties. The significance of freedom of the press remains as crucial today as it has always been, necessary for both
journalists and anyone seeking to stay informed. It involves showing respect for the information, ideas and opinions that are shared globally.9

History of press freedom in India:

The initial newspaper printed in India was the Bengal Gazette, also called Hickey's Gazette or journal, after its creator. The initial release occurred in
January of 1780. Samachar Darpan was the initial newspaper in an Indian language, published in Bengali. The initial number was assigned on May 23,
1818.Theidistributioniofgthese0papershwasbinevitably7quite9limited.10

From the start, British authorities viewed the press unfavourably. Editors were demoralized and oppressed, with limitations placed on their work. Those
in authority could not tolerate any form of criticism. Editors were occasionally even penalized for releasing harmless news articles. From 1791 to 1799,
numerous editors were sent to Europe without trial, while others were reprimanded and forced to apologize humbly. Therefore, the government enacted
several laws to restrict the freedom of the press.11

Colonial Era

In 1779, James Augustus Hickey launched Bengal Gazette, exposing corrupt acts by company officials. It was seized in 1782 due to personal attacks on
Governor-General and chief justice, leading to Hickey's imprisonment and hefty fine for libel. During the early years of the Indian press, J Natarajan
stated that the first instance of censorship occurred on the Madras Gazette in 1795.12

• Censorship of press act, 1799

Lord Wellesley imposed stringent press restrictions, such as "pre-censorship," in advance of "The French Invasion" of India. The purpose of this measure
was to prevent the French from publishing anything that would harm the British colonists' reputation in India. All newspapers now have to submit to a
stringent government review process, per the statute.

It said that the names of the printer, editor, and proprietor should immediately appear on all newspapers, and that anyone found in violation would face
severe consequences, including expulsion in the worst of circumstances. Books, magazines, pamphlets, and journals were also included in the act's 1807
extension. But when "Lord Hastings" took over in the year 1818, these limitations were loosened due to his progressive and modern viewpoint.13

• Press Registration of Book Act, 1867

6
https://timesofindia.indiatimes.com/india/world-press-freedom-day-why-is-it-important-in-democracy/articleshow/99941140.cms (last visited on July
20,2024)
7
https://www.un.org/en/about-us/universal-declaration-of-human-rights#:~:text=Article%2019,media%20and%20regardless%20of%20frontiers. (last
visited on July 2024)
8
Article 19, Universal Declaration of Human Rights
9
https://www.lexisnexis.com/blogs/gb/b/research/posts/the-importance-of-freedom-of-the-press (last visited on July 20,2024)
10
Ramananda Chatterjee, ”Origin and Growth of Journalism among Indians”145 Sage Publications, Inc. in association with the American Academy of
Political and Social Science 161(1929)
11
Ibid
12
Sangita De, Priyam Basu Thakur, ”Press Freedom in India: Virtuous or Vulnerable” ResearchGate, Jan., 2022.
13
https://www.legalserviceindia.com/legal/article-11420-a-critical-analysis-of-the-indian-press-acts-and-sedition-law-in-india.html (last visited on July
21,2024)
 International Journal of Research Publication and Reviews, Vol 5, no 8, pp 109-115 August 2024 111

It is one of the oldest existing laws specifically targeting the press. It was indicated that each press owner must enrol. Each newspaper is required to
disclose the owner, editor, and publication date. The British Government lacked trust in their subjects, so thorough verification of information is essential.
Cancellation of registration can occur if another paper has a title that is alike, if there is a change in printer or publisher, or in cases of breaking certain
laws, hiding information, or misrepresenting important facts.14

• Vernacular Press Act, 1878

Vernacular Press Act, 1878 was a law passed in British India in 1878 to restrict the freedom of the non-English Indian language press. Suggested by Lord
Lytton, who was the viceroy of India at the time (1876-80), the law aimed to restrict the local press from criticizing British policies, particularly the
backlash that arose during the second Anglo-Afghan War (1878-80). English language publications were not included in the act. The law sparked intense
and continuous backlash from a broad range of the Indian people. Lord Ripon, who governed from 1880 to 1884, repealed the law in 1881 after taking
over from Lytton. Nevertheless, the anger it stirred among Indians played a role in spurring on India’s increasing independence movement. One of the
most outspoken opponents of the act was the Indian Association, established in 1876, often seen as a forerunner of the Indian National Congress, founded
in1885.15

• Indian Press Act, 1910

The British officials believed that the rise of nationalist newspapers and pamphlets fostered a political atmosphere that could lead to revolution. Lord
Risley, the Home Member, presented a bill on the 4th of February in the year 1910 in order to stop the spreading of anti-Government materials. The press
legislation had three primary goals:

i) to enhance the Government's authority over the media in India

ii) to expand bureaucratic oversight of the import and distribution of local political writings; and

iii) to empower the local Government to confiscate any newspaper or other printed materials that contain seditious content

Lord Minto agreed with Lord Risley's perspective and approved his suggestion, leading to the enactment of the Indian Press Act on February 8th, 1910.
The regulations in the Press Act of 1910 were somewhat similar to those in the Vernacular Press Act of 1878. The primary provisions of the Indian Press
Act, which was enforced on February 9, 1910, were as listed below:

i) to manage the printing machines and how they are distributed for publication;

ii) to exert dominance over the publishers;

iii) prohibition of seditious or objectionable newspapers, books or other materials in any location they may be located.

iv) exercise authority over the importation of seditious content into British India and its transmission through the postal system.

The Press Act applied to all of British India, including British Baluchistan, the Santhal Parganas, and the Pargana of Spiti.16

Post Independence Era

India achieved independence in 1947 under the leadership of Pt. Its first Prime Minister was Jawaharlal Nehru. Nehru had a close connection with the
newspaper ‘National Herald’ starting in 1938. The British Raj prohibited this paper during the 'Quit India Movement'. After gaining independence, he
conveyed his desire to collaborate with the media in shaping India into a democratic, socialist country. According to him, the press's importance has
multiplied significantly since Independence. Addressing the Parliament, he stated,"The media is not a foreign influence. It is a strong force, yet it originates
from within. Before, it needed to impact a foreign administration that had the ability to silence or harm it, but now it is significantly stronger due to
several different factors. While it is not under governmental control, it is considered a segment of the Parliament, if I may put it that way". Based on the
statement mentioned, it can be inferred that Nehru saw a significant role for the press in parliamentary democracy.17

Following independence, the newspaper industry began to evolve as a profitable business. A significant amount of investment was necessary to develop
the infrastructure needed to set up a newspaper. Nehru did not support the idea of newspaper conglomerates. He criticized the monopolistic inclinations
of the press, meaning the press controlled by wealthy elites.18

The Press Enquiry Committee was established in 1947 to analyse press laws in accordance with the fundamental rights outlined by the Constituent
Assembly.

In 1951, the government passed the Press(Objectionable Matters) Act, which included a change to Article 19(2) allowing them to request security for
publishing “objectionable matter.” It was effective until 1956.

14
Rajeev Dhavan, “On the Law of the press in India”26 Indian Law Institute 288-332(1984)
15
https://www.britannica.com/topic/Vernacular-Press-Act (last visited on July 21, 2024)
16
V. Venkat Raman, “The Indian Press Act of 1910: The Press and Public Opinion at crossroads in the Madras Presidency 1910-1922” 60 Indian
History Congress 863-871(1999)
17
Rajendra Kumar Sharma, “Jawaharlal Nehru and the Press” 34 Journal of National Development 194-208(2021)
18
Ibid
 International Journal of Research Publication and Reviews, Vol 5, no 8, pp 109-115 August 2024 112

In 1954, Justice Rajadhyaksha established a Press Commission. One of the main suggestions put forward by the committee was the creation of the All
India Press Council. On 4 July, 1966, it was officially founded as an independent, legal, quasi-judicial entity, led by Justice J.R. Mudholkar, who was a
Supreme Court judge at the time.

Additional legislation passed includes the Public Libraries Act of 1954 concerning the delivery of books and newspapers, the Working Journalists Act of
1955 regarding conditions of service, the Newspaper Act of 1956 regulating prices and page numbers, and the Parliamentary Proceedings Act of 1960
protecting publications. 19

Emergency Era

On June 26, 1975, in the early hours, President Fakhruddin Ali Ahmed announced a state of Emergency in India due to concerns about “internal
disturbances” posing a threat to national security. Indira Gandhi, who was the prime minister at the time, restricted civil liberties such as free press and
made changes to the Constitution. In the midst of the crisis, reporters, members of the Opposition and campaigners were incarcerated under the Strict
governance of Indira Gandhi’s administration. The President declared a state of Emergency. Indira Gandhi reassured on All India Radio that there is no
need to worry. As India faced a Constitutional crisis during Emergency, Press Freedom drastically deteriorated, with changes happening overnight. When
freedom of speech was revoked as a basic right, the printing presses were searched and the newspaper ceased publication for two days. The information
that was given to the media. The Indira Gandhi administration established certain regulations for journalists nationwide, informing them of specific
guidelines to adhere to. Three years ago, Kalpana Sharma, ex-Editor of Himmat, mentioned that when they finally understood the situation in the country,
numerous leaders and activist had already been imprisoned. Sharma menti0oned that one of the rules was that newspapers will help the Chief Press
adviser by withholding news that Is clearly harmful. When uncertainties arise, it is recommended to consult the closest press adviser. During the 21-
month emergency period, when the media was being targeted in the country, the foreign media was eager to report on the suspension of Constitutional
rights in the country. The Indian media was advised to ignore the rumours. The Chief Press Advisor mandated that all newspaper in the country must
seek approval before printing any articles, as the role was established to oversee and control the news.

Arrests, intimidation

The majority of the mainstream media publications were facing the wrath of the Emergency. The Censors’ Scissors slice through major publishers such
as Himmat, Janata, Frontier, Sadhana, Swarajya, and many more. Some people were in danger of being expelled from publications, while others faced
imprisonment. The Indian Express and The Statesmen decided not to publish any content on their editorial pages. Soon after, other publications also
followed suit. IE stated that journalists from The Times of London, The Washington Post, and The Los Angeles Times were removed. The journalists
from The Guardian and The Economists returned to the United Kingdom following threats. The Channel also removed Mark Tully, the BBC’s voice. In
May of 1976, the Home Ministry reported that nearly 7,000 journalists and media personnel had been detained.

Rebellion and Liberation

Journalist Kuldip Nayar was taken into custody by the authorities for participating in a demonstration against the emergency along with the other reporters
in Delhi. The leaders of the opposition were also advocating for the same issue nationwide. During the Emergency, LK Advani, a former leader of the
Janata Party and a veteran of the Bharatiya Janata Party, was imprisoned for several months. Advani’s words resonate in the minds of every Indian
following the lifting of Emergency. He spoke to the press and commented: “You were simply requested to bend, yet you choose to crawl.”20

Current Scenario:

India has been placed at 159 in the 2024 World Press Freedom index, two spots higher than the previous year, as reported by Reporters Without Borders
(RSF). In 2023, it was ranked 161. Reporters Without Borders (RSF) highlighted the crisis in press freedom in India, the world’s largest democracy led
by Prime Minister Narendra Modi since 2014. The country was also featured in RSF’s report on press freedom in the Asia-Pacific region under
authoritarian regimes. RSF commented that India’s two-rank increase was not accurate because while its scores decreased, the higher ranking was a result
of bigger drops in scores from countries that were previously ranked higher. India rose two spots in the rankings, even after implementing stricter laws.
According to the report, the current placement is inadequate for a democracy. RSF’s report on India highlights a decline in press freedom under the
Narendra Modi administration since 2014. Mukesh Ambani, a close associate of the prime minister, possesses over 70 media organizations under the
Reliance Industries group, with a reach of at least 800 million people in India. Gautam Adani, a mogul with close ties to Modi, acquiring NDTV channel
towards the end of 2022 spelled the demise of diversity in mainstream media. In the past few years, there has been an increase in the so-called “Godi
Media” (a play on words referring to Modi’s supporters)- media organizations that blend populism with the pro-BJP messaging. The traditional Indian
model of a diverse press is being challenged by pressure and influence. The prime minister strongly criticizes journalists, viewing them as intermediaries
who disrupts his direct connection with his supporters. It is mentioned that Indian journalists, who are highly critical of the government, face harassment
campaigns from trolls supported by the BJP. RSF observes that many governments and political authorities worldwide are failing to ensure the ideal
conditions for journalism and the public’s access to trustworthy, impartial, and varied news and information. Pakistan is ranked at 152, Sri Lanka at 15,
Nepal at 74, and Maldives at 106, slightly higher than India. Afghanistan ranks 178th, Bangladesh ranks 165th, and Myanmar ranks 171st in the standings.21

Article 19 and Freedom of Press :

19
https://editorsguild.in/history-of-journalism/ (last visited on July 22, 2024)
20
https://www.timesnownews.com/india/article/emergency-in-india-how-the-press-was-affected-in-1975/246017 (last visited on July 22, 2024)
21
https://thewire.in/media/unworthy-of-a-democracy-india-ranks-159-of-176-countries-on-press-freedom-index (last visited on July 22, 2024)
 International Journal of Research Publication and Reviews, Vol 5, no 8, pp 109-115 August 2024 113

In order to protect democracy, it is vital for individuals to be able to freely voice their opinions and share their perspectives with the public. The media,
an influential tool for widespread communication, should have the freedom to contribute to the development of a robust and sustainable society.
Restricting citizens’ access to press freedoms would weaken their ability to sway public opinion and go against democratic principles. Article 19(1)(a) of
the Constitution does not explicitly reference freedom of the press, but instead focuses on freedom of speech and expression. During the Constituent
Assembly Debates, Dr. Ambedkar, Chairman of the Drafting Committee, emphasized that there was no need to specifically mention that freedom of the
press, as both the press and an individual or citizen had the same right to express themselves. The creator of the Indian Constitution viewed freedom of
the press as a crucial element of the right to freedom of speech and expression enshrined in Article 19(1)(a) of the Constitution. In the cases of Romesh
Thapar vs State of Madras22 and Brij Bhushan vs State of Delhi23, it was assumed by the Supreme Court that freedom of the press is a crucial component
of the right to freedom of speech and expression. In Romesh Thapar, Patanjali Sastri J. noted that the freedom of speech and expression encompassed the
spread of ideas, and that freedom was safeguarded by the freedom of circulation. It is evident that the freedom to express oneself includes the freedom to
share one’s ideas, opinions, and perspectives through various means of publication without any restrictions.24

The freedom of the press involves the freedom to disseminate ideas and opinions as well as the ability to publish and distribute them. Still, like with the
freedom of expression, journalistic freedom is not unrestricted. Article 19(1)(a) protects the public interest by establishing appropriate restrictions on the
right to free speech in areas that impact: The state’s sovereignty and integrity; security; amicable relations with other nations; public order; decency and
morality; contempt of court; defamation; and incitement to commit an offence.25

The first revision of Article 19(2) in 1951 expanded the scope of appropriate restrictions in response to these incidents. Following the Supreme Court’s
rulings in the cases of Brij Bhushan and Thapar, the categories of “public order,” “friendly relations with foreign states,” and “incitement to offence”
were added.26

The Supreme Court dismissed the sedition case against journalist Vinod Dua over a YouTube video in June 2021. And more recently, the Chief Justice
said, “How can we tell a journalist not to write?”, while granted bail to the Alt News co-founder Mohammad Zubair, who was detained because of tweets
from 2021. These directives demonstrate that there is still battle left in the ideals.27

Recommendations :

The new administration in India needs to take immediate action to regain media freedom in a country ranked 159th out of 180 countries in RSF’s 2024
World Press Freedom Index. So, here are some of the recommendations which have been made by various organizations that can lead to the improvement
of press freedom index in India :-

o Revision of anti-terrorism laws :-

Revise anti-terrorism laws so that journalists are not targeted. The Unlawful Activities Prevention Act (UAPA) of 2019 and the Public Safety Act of 1978
and cannot be utilized to oppress media people. Furthermore, the state must stop utilizing criminal laws against journalists.28

o Protect plurality by limiting media concentration :-

Many of India’s media channels are currently owned by a small number of private sector corporations and conglomerates. To protect media variety,
legislation must be implemented to abolish monopolies and prohibit cross-ownership.29

o Unnecessary legal proceedings against journalists who criticizes government must be stopped :-

In order for democratic governments to thrive, they must be capable of enduring public examination and disapproval, this is what defines a robust checks
and balance system that enhances the strength of democracies. The government needs to stop its ongoing legal harassment of journalists, who are unfairly
charged for their critical opinions on the government.30

o Revoke any domestic Laws or legal provisions that go against media freedom and the right to information, both nationally and
internationally.31

o Government must restrain from using technology in curtailment of press freedom :-

22
AIR 1950 SC 124
23
AIR 1950 SC 129
24
https://www.legalservicesindia.com/article/1847/Freedom-of-Press--Article-19(1)(a).html (last visited on July 22,2024)
25
Ibid
26
https://www.scobserver.in/journal/article-19-prescription-procedure-and-the-press/ (last visited on July 22,2024)
27
Ibid
28
https://rsf.org/en/india-rsf-and-national-civil-society-organisations-give-new-government-10-recommendations-guarantee (last visited on July
23,2024)
29
Ibid
30
https://ipi.media/india-ipi-urges-government-to-respect-press-freedom/ (last visited on July 23, 2024)
31
Ibid
 International Journal of Research Publication and Reviews, Vol 5, no 8, pp 109-115 August 2024 114

Government is more and more utilizing technology to restrict human rights and hinder freedom of expression on the internet. In February 2021, the Indian
government released the Information Technology Rules that threaten freedom of speech and privacy rights. These regulations give the government the
authority to immediately force the deletion of online material with no court supervision. They also put encryption at risk, essential for maintaining privacy
and security on the internet, commonly utilized by journalists to safeguard their sources and themselves from any potential threats. The regulations were
criticized by the Editors Guild of India for restricting media freedom. Three experts in human rights from the UN have shown worry that the regulations
are not in line with global human rights standards.32

Conclusion :

After analysing the conditions of press within the country throughout the ages we can conclude that although in India press is regarded as the fourth pillar
of democracy but still there is a very little regard for this agency in the country. Government in power always tries to supress it by imposing various bans
and laws upon it. The condition of journalists is even worse, they are harassed and threatened for criticizing the government and the number of crimes
against journalists are constantly increasing every year. There are many cases which even go unreported. So, there is definitely a need to reform media.

REFERENCES:

Statues

1. Constitution of India, 1950

2. Universal Declaration of Human Rights, 1948

Cases

1. Brij Bhushan v State of Delhi AIR 1950 SC 129

2. Romesh Thapar v State of Madras AIR 1950 SC 124

Journals and Articles

1. Ramananda Chatterjee, ”Origin and Growth of Journalism among Indians”145 Sage Publications, Inc. in association with the American
Academy of Political and Social Science 161(1929)

2. Rajeev Dhavan, “On the Law of the press in India”26 Indian Law Institute 288-332(1984)

3. Rajendra Kumar Sharma, “Jawaharlal Nehru and the Press” 34 Journal of National Development 194-208(2021)

4. Sangita De, Priyam Basu Thakur, ”Press Freedom in India: Virtuous or Vulnerable” ResearchGate, Jan., 2022

5. V. Venkat Raman, “The Indian Press Act of 1910: The Press and Public Opinion at crossroads in the Madras Presidency 1910-1922” 60
Indian History Congress 863-871(1999)

Websites

1. Britannica https://www.britannica.com/topic/Vernacular-Press-Act

2. Editors Guild of India https://editorsguild.in/history-of-journalism/

3. Global Investigative Journalism Network https://gijn.org/stories/doc-of-the-day-global-impunity-index/

4. Human Rights Watch https://www.hrw.org/news/2022/05/03/india-media-freedom-under-threat

5. Human Rights Careers https://www.humanrightscareers.com/issues/freedom-of-the-press-101-definition-examples-significance/

6. International Press Institute https://ipi.media/india-ipi-urges-government-to-respect-press-freedom/

7. Legal Services India https://www.legalservicesindia.com/article/1847/Freedom-of-Press--Article-19(1)(a).html

8. Legal Services India https://www.legalserviceindia.com/legal/article-11420-a-critical-analysis-of-the-indian-press-acts-and-sedition-law-in-

9. LexisNexis The Importance of Freedom of the Press (lexisnexis.com)

10.Oxford English Dictionary https://www.oed.com/dictionary/freedom_n?tl=true

11.Reporters Without Borders https://rsf.org/en/india-rsf-and-national-civil-society-organisations-give-new-government-10-recommendations-

32
https://www.hrw.org/news/2022/05/03/india-media-freedom-under-threat (last visited on July 23, 2024)
 International Journal of Research Publication and Reviews, Vol 5, no 8, pp 109-115 August 2024 115

12.Supreme Court Observer https://www.scobserver.in/journal/article-19-prescription-procedure-and-the-press/

13.The Times of India https://timesofindia.indiatimes.com/india/world-press-freedom-day-why-is-it-important-in-democracy/article

14.The Wire https://thewire.in/media/unworthy-of-a-democracy-india-ranks-159-of-176-countries-on-press-freedom-index

15.Times Now News https://www.timesnownews.com/india/article/emergency-in-india-how-the-press-was-affected-in-1975/246017

16.United Nations https://www.un.org/en/about-us/universal-declaration-of-human-rights#:~:text=Article%2019,media%20and%20

17.United Nations https://unric.org/en/swedish-freedom-of-press-ordinance-among-new-inscriptions-on-unescos-memory-of-the-world-