Sharing Citizens Health Data Without Their Informed Consent – ‘Aarogya Setu’

It is in the fitness of things that the Karnataka High Court has most recently on January 25, 2021 in its interim order in the latest, landmark, learned and laudable judgment titled Anavir A Aravind vs Ministry of Home Affairs and others has restrained the Government of India and National Informatics Centre (NIC) from sharing the response data of users of Aarogya Setu app, observed that sharing of health data of citizens without their informed consent will violate right to privacy under Article 21 of the Constitution. A Division Bench of Chief Justice Abhay Oka and Justice S Vishwaith Shetty very rightly noted that, “The information contains data about the health of the user which all the more requires the protection of right to privacy.” It was also very rightly observed that, “The sharing of health data of a citizen without his/her consent will necessarily infringe his/her right of privacy under Article 21 of the Constitution of India.” This observation is the real crux of this entire commendable judgment.

While specifying the purpose of the writ petition, it is stated right at the outset that, “This Writ Petition is filed under Article 226 of the Constitution of India praying to direct the respondent Authorities to make the use of Aarogya Setu application by citizens voluntary and etc.” It is also pointed out that this Writ Petition having being heard and reserved for passing order on prayer for interim relief, coming on for pronouncement of order.

To start with, the Division Bench first and foremost sets the ball rolling by first and foremost observing in para 1 that, “On 19th August, 2020 rule nisi has been issued in this petition. Thereafter, submissions were heard from time to time on the prayer for interim relief. The submissions were lastly heard on 17th December, 2020 and order was reserved.”

To put things in perspective, the Bench then observes in para 2 that, “The issue in this writ petition concerns Aarogya Setu application (for short, ‘the Aarogya Setu app’) introduced by the Government of India after the nationwide lockdown was announced by the Hon’ble Prime Minister on 24th March, 2020. The National Informatics Centre (‘NIC’ for short)-seventh respondent launched the Aarogya Setu app on 2nd April, 2020 which is stated to have been downloaded by more than one hundred million users. One of the issues involved is whether the Government of India has a right to use the personal data of Aarogya Setu app users on the app and whether it can transfer/ share the data without obtaining the informed consent of the users. On 1st May, 2020, an order was made by the Union Home Secretary, the Ministry of Home Affairs, in his capacity as the Chairperson of the National Executive Committee of the National Disaster Management Authority (for short, ‘the NDMA’) under the Disaster Management Act, 2005 (for short, ‘the said Act of 2005’). The said order was passed in exercise of powers under Section 10 (2) (l) of the said Act, 2005, by which, new guidelines were issued on lockdown which were annexed to the said order. The guidelines appended to the said order provided for ensuring 100% coverage of the Aarogya Setu app amongst the residents of Containment Zones. On 11th May, 2020, an order was issued by the Chairperson, Empowered Group on Technology and Data Management which was constituted by the National Executive Committee of the NDMA. By the said order of 11th May, 2020, directions were issued in the name and style of “the Aarogya Setu Data Access and Knowledge Sharing Protocol, 2020” (for short, ‘the said protocol’).”

Be it noted, the Bench then enunciates in para 4 that, “Prayer III-C refers to clause 3 (vii) of Annexure-N which is a Standard Operating Procedure (for short, ‘SOP’) issued by the Government of India, Ministry of Health and Family Welfare on 4 th June, 2020 relating to the preventive measures to contain spread of COVID-19 in the offices. Clause 3 (vii) of the said SOP seeks to make the installation and use of the Aarogya Setu app by the employees mandatory.”

For the sake of clarity, the Bench then clarifies in para 5 that, “We must note here that by the Order dated 19th October, 2020, this Court directed that till the petition is heard on the prayer for interim relief and in the absence of any legislation, neither the State Government nor the Central Government, its agencies or instrumentalities can deny any benefit of any services to a citizen only on the ground that he has not installed the Aarogya Setu app on his cell phone. As far as the prayer made in clause (2) for interim relief is concerned, we must note here that the Government of India (8th respondent), Airports Authority of India (4th respondent) and Bengaluru Metro Rail Corporation Limited (9th respondent) have taken a clear stand that installation and use of the Aarogya Setu app is not mandatory for those who want to avail facilities provided by them. The order dated 12th June, 2020 clearly records that the passengers who wish to travel by Air or Railway are not mandatorily required to download and install the Aarogya Setu app as a condition precedent for travelling. The Order dated 3rd August, 2020 records the statement made by the Government of India in the memo dated 2nd August, 2020 wherein it is stated that installation of the Aarogya Setu app is voluntary in nature which is intended to help the users to have reduced risk of infection of COVID-19. The Order dated 19th August, 2020 records the submission made by the learned counsel appearing for the Airports Authority of India to the effect that downloading and installation of the Aarogya Setu app for Air travelers is not mandatory and it is optional. Thus, the second prayer for interim relief is virtually worked out. The same is the case as regards the first prayer for interim relief. Thus, what remains for consideration is the third prayer for interim relief.”

Significantly, the Bench then puts forth in para 26 that, “We have perused the contents of Annexure-R19 which is an Order/Notification dated 11th May, 2020 regarding the issue of the said protocol. The said protocol is issued by the Chairperson, Empowered Group on Technology and Data Management appointed under Order dated 29th March, 2020 issued by the Ministry of Home Affairs, a copy of which produced as Annexure-R2. Clause-2 of Annexure-R2 is relevant which reads thus:

“2. The measures taken hitherto have been effective in containing the pandemic so far. However, considering the gravity and magnitude of the challenges, which are emerging with every passing day, there is a pressing need to augment and synchronies efforts cutting across various Ministries/Departments. Keeping in view the need for such comprehensive action and integrated response, in exercise of the powers conferred under the section 10 (2) (h) and (i) of the Disaster Management Act, 2005, the undersigned in the capacity as Chairperson, National Executive Committee, hereby constitute eleven Empowered Groups of Officers (as per Appendix). These Groups are empowered to identify problem areas and provide effective solutions therefor; delineate policy, formulate plans, strategize operations and take all necessary steps for effective and timebound implementation of these plans/policies/ strategies/decisions in their respective areas.””

More significantly, the Bench then elucidates quite remarkably in para 27 that, “On plain reading of clause-2 referred above, the role of the Empowered Group is of identification of problems/difficulties, finding out solutions, formulating contingency plan etc. There is nothing placed on record to show that the Chairperson, Empowered Group on Technology and Data Management is empowered to pass any order which will have a binding effect. Prima facie, it is not shown that this Empowered Group has any statutory power either under the said Act of 2005 or any other Act to pass such an order. There is nothing on record to show that the powers of the authorities under the said Act of 2005 have been delegated to the said Empowered Group. We have perused the said protocol. Clause 5(a) clearly stipulates that any response data and the purpose for which it is collected by NIC shall be clearly specified in the Privacy Policy of Aarogya Setu App. Perusal of Privacy Policy available on the App. shows that there is no reference incorporated therein to collection of response data by NIC and purpose of collection. Clause 6 of the protocol permits sharing of data by NIC with the entities mentioned therein. The said entities are State Government, Public Health Institutions etc., But, the Privacy Policy says that the data will be shared only with the Government of India. Clause 8 permits NIC to share the response data for research purposes with third parties. It is pertinent to note that there is no reference to the said Clauses 5, 6 and 8 in the privacy policy or terms of service available on app itself. Thus, the collection of the data as per clause 5 and sharing of response data as per Clauses 6 and 8 is being done without the consent of the user, much less, an informed consent. Though Clause 8 provides for the anonymisation, there is nothing on record to show that the claim of anonymisation is tested by any agency. The sharing of health data of a citizen without his/her consent will necessarily infringe his/her right of privacy under Article 21 of the Constitution of India. Therefore, prima facie, the said protocol regarding sharing of ‘response data’ cannot be permitted to be implemented for two reasons. Firstly, the user of Aarogya Setu app is not informed about the said protocol at all and the same is not at all a part of the terms of use or privacy policy which are available on Aarogya Setu app itself. The users are not even informed about the said protocol and the provisions therein about sharing of the response data before he uploads his personal information. Secondly, it is not the case made out by the Government of India that the informed consent of the user is obtained to sharing of the response data, as provided in the said protocol. The information contains data about the health of the user which all the more requires the protection of right to privacy. Prima facie, we find that the sharing and use of the response data as per the said protocol will infringe the right of privacy of the users, thereby amounting to violation of the rights guaranteed under Article 21 of the Constitution. We may note here that by order dated 10th November, 2020 which has been produced along with the memo dated 11th November, 2020, it has been directed that the said Protocol will remain in force for a further period of six months i.e., till 10th May, 2021.

Finally and far most significantly, the Bench then holds in para 28 that, “Therefore, we pass the following interim order:

i) We accept the assurance given by the Government of India that no individual will be denied the benefits of any services that are being provided by the Governments, its agencies and instrumentalities on the ground that he has not downloaded and installed Aarogya Setu app;

ii) Prima facie, we hold that informed consent of the users of Aarogya Setu app is taken to what is provided in the privacy policy which is available on Aarogya Setu app itself and, therefore, there is an informed consent of the users of Aarogya Setu app which is limited only to collection and manner of collection of information, use of information and retention, as provided in the privacy policy which is available on the Aarogya Setu app. However, it is made clear that the use and retention of information and data shall remain confined to what is provided in the privacy policy which is available on the Aarogya Setu app;

iii) Prima facie, we hold that there is no informed consent of users of Aarogya Setu app taken for sharing of response data as provided in the Aarogya Setu Data Access and Knowledge Sharing Protocol, 2020, as there is no reference to the said protocol in the terms of use and Privacy Policy available on the app.

iv) Till further orders, we hereby restrain the Government of India and National Informatics Centre, the eighth and seventh respondents respectively from sharing the response data by applying the provisions of the Aarogya Setu Data Access and Knowledge Sharing Protocol, 2020 issued vide order dated 11th May, 2020 (Annexure-R19) unless the informed consent of the users of Aarogya Setu app is taken;

v) However, it will be open for the Union of India and National Informatics Centre, the eighth and seventh respondents respectively to file an affidavit for satisfying the Court that the Chairperson, Empowered Group on Technology and Data Management or the said Empowered Group is legally empowered to issue the said protocol and that the informed consent of the users of Aarogya Setu app is taken for implementation of clauses regarding sharing of the data as provided in the said protocol. After filing of an affidavit and the documents as aforesaid, it will be open for the said respondents to apply for vacating the limited interim relief granted as above, in terms of clause (iii).”

Of course, it goes without saying that the Karnataka High Court Division Bench has very rightly upheld the prayer made in the petition filed by cyber security activist Anivar A Aravind who had specifically sought an order restraining the respondents during the pendency of the petition from proceeding with the Aarogya Setu app and with the data collected, in any manner, whether the collection of data from members of the public is stated to be voluntary or involuntary. Senior Apex Court advocate Colin Gonsalves while appearing for the petitioner had heavily and very rightly relied on the landmark judgment of the Supreme Court in the case of Justice KS Puttaswamy (retired) vs Union of India. It is certainly a well-written, well-reasoned, well-substantiated, well-articulated and well-comprehended 50-page judgment by a Division Bench of the Karnataka High Court which must be read certainly in its entirety! All the governments must always respect the right of privacy of citizens which is an inalienable fundamental right and should desist from sharing any data without the prior informed consent of concerned citizens as held very commendably in this leading case also! There can certainly be no denying or disputing it!

Sanjeev Sirohi, Advocate,

s/o Col BPS Sirohi,

A 82, Defence Enclave,

Sardhana Road, Kankerkhera,

Meerut – 250001, Uttar Pradesh

National Voters Day in India 25th January

Ramani Wiped 50 Years Of My Hard Work With One Stroke: MJ Akbar

Let me begin with a disclaimer: I have no affiliation with eminent and senior journalist MJ Akbar of any kind and I have never met him in person nor am I affiliated in any way with his political party BJP of which he is a member and earlier was Union Minister of State also for External Affairs. But ever since I gained senses I have been a regular reader of his scholarly articles in most prestigious magazines like “India Today” among others and so also in many eminent newspapers. I used to enjoy reading his learned articles most when I was in school and in college even though later also I made it a point to always read his articles! I was most shocked to learn when his name figured in a controversy and when his name was dragged in it. To be brutally honest, it was the worst shock that I could ever have imagined in my life!

Needless to say, MJ Akbar has always enjoyed an impeccable reputation and even his worst critic could never have questioned his unimpeachable conduct, his impeccable reputation until Priya Ramani raised serious questions marks on his conduct. MJ Akbar through his counsel argued that it was journalist Priya Ramani who “targeted him” for which he was prompted to file the defamation complaint.

It may be recalled that MJ Akbar was left with no option but to resign as Union Minister of State for External Affairs even before the charges have been proved against him in any court and he too became a victim of “MeToo Media Trial”! Hang him if he is guilty but condemning him even before charges have been framed against him in any court and tarnishing his “impeccable reputation” which he has earned in his entire life in just few seconds cannot be justified under any circumstances! MJ Akbar could have easily continued as a Minister but he preferred to resign and first challenge those who tarnished his impeccable reputation in court.

Bluntly put: Is MJ Akbar not entitled to the benefit of the due process of law and legal defence? Should he not be given a chance to prove his innocence? There are many senior eminent women journalists like Tavleen Singh who have always appreciated him and have said that they have never experienced any such “alleged misconduct” from him but this is never highlighted in the media! Tavleen Singh is most famous for calling a spade a spade and she never fears anyone! How can all this be ignored?

Most recently, a woman journalist deposed in court in his favour and admired his upright approach in always dealing with her. Only the numbers are highlighted that 16 or 17 women have levelled most serious charges against him but I want to ask: Why they never dared to lodge FIR against him in any police station of India till now? Why they kept quiet for so many years? Why inspite of being professional they chose to keep quiet? Were they not aware of their legal rights?

Going forward: Why did they not immediately complaint? Why they didn’t spill the beans earlier? Why was there a consensual conspiracy of silence? Why were they lured to keep quiet? Why they compromised themselves just for getting some material benefit? Are they not guilty just like an adulterous women?

It also cannot be ignored that Union Minister Pon Radhakrishnan asked: “If someone makes an allegation that such a thing happened when the incident happened we were playing together while in class 5. Would it be fair? The ‘MeToo’ movement had sullied the image of the country. Will it be right for men to start making similar accusations like them.” Even Union Minister for Tourism K Alphons had cautioned against frivolous complaints by “insincere” people with an agenda. He said that, “People should be extremely careful when they raise an allegation. Yes, if something inappropriate has taken place, it should be in public domain. There should not be any doubt about it, but I hope frivolous complaints are not raised by insincere people to fix people whom they do not like.”

We heard earlier how KWAN founder Anirban Das attempted suicide after sexual misconduct allegations but was saved by an alert police team patrolling the Navi Mumbai bridge! MJ Akbar has vowed to fight for sake of his reputation till the end! There are very few who care for what “mental trauma” a man undergoes when false allegations are levelled against him and he is defamed by “media trial” to the fullest even before charges are framed against him in any court! This must stop once and for all as it mutilates and maims to pieces a men’s integral right to reputation and right not to be defamed and denounced even before any court takes cognizance of the charges levelled against him!

“You do me favors, I do you favors 30 years later

lets call it “me too”

A strong woman does not wait 30, 20, 10 years to speak up, she slaps him on the first “bad touch” and knocks him out

Don’t hide your weakness, the favors in returns that you enjoyed and the work you got by “I was too scared” cry now

You were scared to say NO then because its hard to stand up for what is right and you were scared to loose your status and position in the work place, so YOU CHOOSE to accept the molestation and went back for more …Its very easy to play the abla nari card later and gain sympathy

The Shakti does not wait later to speak up, she silences the evil on spot…

My thoughts on this nonsense of me too

I don’t have me too stories …anyone who tried got a tight slap then and there and I was never afraid to walk out with my head held high ..be it a Job or relationship!

“strong women don’t have me too sob

Stories, they have I gave him thappad

(slap) back short essays”.”

– Geetanjali Arora in Sunday Times of India dated October 21, 2018

Every person must applaud, admire and appreciate Geetanjali Arora for what she has written so courageously on 9 October at 5.35 pm which got published on October 21 in one of the most reputed newspapers of India – The Times Of India! Why should women be treated always as victims? Why should women keep quiet for many decades and then speak up if she herself has nothing to hide from the world?

Does men have no right? Should only women have all the right to speak up whenever she likes? Very few know that a woman had levelled serious allegations against eminent film actor Jitender about an act allegedly done by him 47 years ago when she was very young but the Himachal Pradesh High Court didn’t accept it and rejected the petition as it said that the time limit of lodging the complaint within the limitation period of 3 years was not complied with!

Anyway, coming to the case at hand, while appearing before Additional Chief Metropolitan Magistrate Ravindra Kumar Pandey, senior women advocate Geeta Luthra further argued that Ramani didn’t feel the need to check with the Ministry, department or PRO to confirm if he had resigned before tweeting that he did. “You wiped out 50 years of his hard work with one stroke,” submitted Luthra while rebutting the submissions of Ramani’s lawyer, senior counsel Rebecca John. John had on a previous occasion submitted that, “It is not defamation to impute anything which is true concerning any person if it for the public good… If the imputation of sexual harassment is in good faith and for public it is not defamation. It is not defamation if the imputation relates to something that touches a public question.”

While contesting this submission, Geeta Luthra quipped: “Good faith would have been if you had any evidence. It can’t be for public good. Public good doesn’t mean you will malign someone’s image. Public good is when you’re making a statement then you have to do it with responsibility.”

Most significantly, Geeta Luthra very rightly pointed out while referring to a sexual harassment incident that, “Just by calling it my truth, doesn’t make it a truth… you haven’t proved whether you have made a call to the complainant, you haven’t proved that you met (Akbar).” Luthra also further pointed out that, “This version is a figment of imagination and not truth..After 30 years you are trying to bring something without any evidence. It is all in the air.”

While stating that “whether you make a whisper that a person is a thief or a cheat” it has to be backed with evidence. Luthra told the court that, “You have to have empirical evidence which can stand scrutiny in the court of law. There is no such evidence in this case. There is no investigation.”

As it turned out, Luthra then read out the statement of a witness, Joyeeta Basu who had testified from Akbar’s side. Basu, Luthra claimed, was called a tutored witness. Calling Basu a respected journalist, the counsel said she was a natural witness unlike Ramani’s witness. Luthra also added that, “Her witness is her friend who doesn’t know anything about the alleged incident.”

Needless to say, for Akbar, the defamation complaint was filed as the “malicious tweets by Ramani” had “destroyed my reputation in the eyes of the society”. Luthra also read out another testimony of one Akbar’s witnesses, Sunil Gujral to assert that his reputation was “impeccable”. Gujral was stated to have known Akbar for a long time personally and professionally.

MJ Akbar through his counsel Luthra rightly submitted that, “Harm is done by the man who instigates and ignites the first flame.” The submissions were made by Luthra before Additional Chief Metropolitan Magistrate Ravindra Kumar Pandey. While reading Ramani’s testimony, Luthra told the court that, “She wrote an article without naming anyone because it was a piece of fiction..You said you didn’t name him because he didn’t do anything. The tweet doesn’t say that I’m saying all this because so many women are speaking up.”

Moreover, it cannot be lightly dismissed that MJ Akbar also told the court that Priya Ramani “deliberately, intentionally and maliciously” destroyed evidence by deleting the Twitter account. Akbar’s lawyer Geeta Luthra told the court that, “This strange argument that this Twitter account, the court didn’t tell me to save so I didn’t. How can one take a defence like this?” Luthra also told the court that Ramani knew there was a criminal complaint pending against her.

More to the point, Geeta Luthra also pertinently told the court that, “These are all tweets. They were all primary evidence. Can she destroy evidence…another criminal case can be made out. I would have wanted to cross examine her. This whole thing is destruction of evidence which is not something which is not viewed very seriously…suppose the court wanted to see it. Fact is that everything has been deliberately destroyed to subvert the cause of justice.

Furthermore, Luthra also told the court that, “All evidence which was part of the trial..deliberately, intentionally, maliciously has been destroyed by deleting the Twitter account. These lies have left me defending my reputation in the last few years. It is unpardonable. I wonder at what kind of cost has it come to you. You have damaged a person’s 50 years of reputation.” Luthra also said that, “There was no overt physical attack.”

Adding further more, Luthra said that, “Here also she is self contradictory. She said it was sarcasm then takes alternate defence. Sarcasm is also defamation. Did he do anything or not do anything..same can’t have a non-sarcastic meaning and still be sarcastic…First she says first fourt para are about her. But then talks about ‘shared experience’. Whom did she interview? This has to be before the cause of action. She says it’s my story..what is she trying? Every sentence when examined is contradictory to the next.”

     <div style="text-align: justify"><br /></div><div style="text-align: justify"><br /></div><div style="text-align: justify">Truth be told, Akbar had filed a defamation case in 2018 stating that Ramani’s allegations were viewed and read by several people online and he received numerous calls from friends and colleagues from the media and political sphere. For having reportedly suffered “great humiliation” and his reputation being “severely tarnished” he had sought court’s intervention. Luthra reiterated that Ramani had some other motive and “there is no public interest. There is no good faith.”</div><div style="text-align: justify"><br /></div><div style="text-align: justify">Without mincing any words, Luthra said that, “What she (Ramani) said does not mean predator. Many people in positions of hierarchy are more powerful but you can’t call them a predator. There are many words to describe a junior-senior relationship.” Luthra also told the court that, “You cannot turn around and say that you are calling a person the media’s biggest predator…You are a journalist. You have to be responsible ..You can’t write as if without any sense of responsibility or accountability..It doesn’t matter what people say post facto. Harm is done by the man who instigates and ignites the first flame. She is not an eye witness. It is fabricated. She is an interested witness.” Luthra told the court that the meaning of the word predator is a person who has propensity for violent sexual behaviour. </div><div style="text-align: justify"><br /></div><div style="text-align: justify">What has really shaken me most is the enlightening editorial written by Ramesh Thakur who is Professor of Public Policy, Australian National University in ‘The Times Of India’ dated November 9, 2018 titled “Believe Evidence Over Gender” which begins by coming straight to the point saying that, “The #MeToo campaign began as a long overdue effort to call out men abusing positions of power and authority to exploit vulnerable women sexually, but then morphed into some settling of scores for dates gone wrong. In the age of social media, #MeToo swarms of screaming mobs, and bird-dogging, the wildest accusations are amplified instantaneously across the whole world. This makes the charge themselves a powerful political weapon.” He rightly suggests the following to check mud slinging matches: “First, ensure anonymity for both or neither. Name only the guilty party after the trial. If the verdict is inconclusive, keep all names confidential. Second, treat both accuser and accused with sympathy, respect and courtesy. Evaluate the testimony of both with equal skepticism, ask questions accordingly, and weigh their statements against the facts. Everyone deserves a fair hearing: no one deserves to be believed in the absence of evidence; and shifting evidence and timeline to suit the narrative warrants over suspicion. Third, match the prosecution and penalty for false accusations to those of conviction. This will put in place a powerful deterrent. Without consequences, the political weaponisation of false charges will continue. Above all, believe evidence over gender. Senator Susan Collins was branded a rape apologist for doing so.”</div><div style="text-align: justify"><br /></div><div style="text-align: justify">It was in 2018 that we saw how in a landmark judgment titled ‘Joseph Shine v Union of India’, the Supreme Court led by Justice Dr DY Chandrachud very rightly decriminalized adultery as it felt that sex with consent cannot be crime and he overruled his father’s decision rendered earlier in Sowmithri Vishnu in 1985! Law has to change with time. Even the definition of rape needs change and sex with consent should not be termed rape. A woman after having consensual sex with a men for many years cannot and should not be allowed suddenly to scream rape and play the victim card by weeping!  The moot question that arises here is: Why the women promptly didn’t lodge complaint if she was forced to enter into sexual relationship? Also, why always men alone be condemned? What if it was women who lured men into sex? Why always women version is to be believed? Why should women not be punished and sent to jail for at least an year if she levels false allegations against a men solely for denigrating, damaging and destroying his untarnished reputation in front of the world? Why should she not be made to pay compensation to him for tarnishing his reputation in front of the world? Why can’t the laws be suitably amended in this regard? Why should only women have right to reputation and right not to be defamed and denounced? Why do we ignore that our laws and Constitution treats men and women as alike? Why should men be deprived of the basic fundamental tenet of law that everyone is innocent until proven guilty? </div><div style="text-align: justify"><br /></div><div style="text-align: justify">It cannot be lightly dismissed that in a criminal case, where the accused will forfeit his liberty if convicted, the standard of proof required to convict him not just is higher but also needs to be proved “beyond all reasonable doubt”. It is high time and all news channels and media groups should refrain from just glamourising “#MeToo” movement and should instead always convince so called “female victims” to approach the court at the earliest and not after 10 or 20 or 30 or 40 or 50 years and fight the legal battle which would seek evidence for both prosecution and proving innocence instead of just levelling the most damning allegations after many decades which only exposes her to “defamation suits” to get real justice for herself! Also, it must be ensured that the identity of both the women levelling the allegations and the men against whom allegations are levelled are not revealed in public until the case is decided at least in the lower court! Such cases too must be decided at the earliest and not after many years as the reputation of both the women and the men suffers enormously which only robs them of their right to privacy which just recently in KS Puttaswamy case has been declared to be a fundamental right!</div><div style="text-align: justify"><br /></div><div style="text-align: justify">It is high time and now women too must be jailed and punished for levelling false allegations. Section 498A of IPC and so also Domestic Violence Act is many times misused and so there must be strict provision for punishing women if her allegations turn out to be false. Women is now no less inferior to men in any field. Then why should she be given blank cheque of exemption if she levels false charge against any men? Even men has the right to reputation and dignity just like women which gets severely compromised when women levels false and wild allegations against men and so should never go unpunished under any circumstances!</div><div style="text-align: justify"><br /></div><div style="text-align: justify">I am certainly not against women getting justice who have suffered at the hands of men but I also simultaneously favour the reasoned and logical stand that, “Men too have right not to be defamed and denounced without facing strictest legal scrutiny in accordance with due procedure of law”. Every Indian women must always abide by what Geetanjali Arora who is herself a female has said which I have quoted right at the beginning! Women are beating men in studies and outsmarting them in every field then why should they take things lying down when it comes to sexual offences?</div><div style="text-align: justify"><br /></div><div style="text-align: justify">Why not lodge complaint at the first place instead of just indulging in character assassination after many years as part of “#MeToo” campaign and getting defamed yourself also and making a huge public spectacle of yourself? Now it is for women to decide for themselves which course of action they would like to adopt but now they must stop laying the victim card and abide in totality by what Geetanjali Arora has said so rightly and never tolerate any sort of any misconduct from any men under any circumstances whatsoever! It is high time and now women must be actually treated at par with men by not always allowing women to play always the “victim card” and encouraging her to always take men head on whenever any men dares to violate her physical or mental integrity in any manner instead of waking up after decades! There can be certainly no denying it!</div><div style="text-align: justify"><br /></div><div style="text-align: justify">Needless to say, MJ Akbar’s case is still pending in court and we have to keep our fingers crossed till the case is finally decided. But certainly the immeasurable pain, anguish and heart bleed that MJ Akbar faced is clearly apparent and one only hopes that justice is done with him and I am sure that judiciary will vindicate the unflinching faith that he has posed in it! </div><div style="text-align: justify"><br /></div><div style="text-align: justify">Sanjeev Sirohi, Advocate,</div><div style="text-align: justify"><br /></div><div style="text-align: justify">s/o Col BPS Sirohi,</div><div style="text-align: justify"><br /></div><div style="text-align: justify">A 82, Defence Enclave,</div><div style="text-align: justify"><br /></div><div style="text-align: justify">Sardhana Road, Kankerkhera,</div><div style="text-align: justify"><br /></div><div style="text-align: justify">Meerut – 250001, Uttar Pradesh</div>

To Constitute AIJS Would Be The Greatest Step Since Independence

Coming straight to the nub of the matter, let me begin penning down my forthright views by first and foremost expressing my utmost happiness to note that Centre has finally decided to get its act together and constitute the All India Judicial Service (AIJS) about which we have been hearing since ages! AIJS is the crying need of the hour and must be debated, discussed and deliberated fully so that all best features are included in it and all possible drawbacks are deleted before it is finally created. There can be no two opinions on it.

It delights me to no end to see that Prime Minister Narendra Modi while addressing a function to celebrate the completion of 50 years of the Delhi High Court on October 31, 2016 set the cat among the pigeons when he sought a debate on creating AIJS which has been hanging fire right since independence. It is most tragic to see that AIJS has always been mocked at by the ruling party in Centre. Even now if AIJS is constituted, it will be the greatest step since independence.

It needs no rocket scientist to figure out that how much our judicial system which is currently on the verge of collapsing due to a whooping number of pending cases will benefit if AIJS is created soon. While I fully support the creation of AIJS, I don’t support reservation in judiciary at all. I certainly would welcome the inclusion of people from the lower strata of society into the judicial system but only when they enter by their own merit and I know that they can do it on their own. They are no less than others in anyway.

Did Dr BR Ambedkar make a name for himself by coming up through reservation? Selection should only and only be on merit alone. There should be no other criteria for selection. No compromise should be made on merit under any circumstances, come what may!

While craving for the exclusive indulgence of my esteemed readers, let me inform you all that I am not at all against Dalits, oppressed, poor and people coming from lower strata of society entering AIJS. But that should not be at the cost of merit under any circumstances as most unfortunately we have been seeing in other services since last 70 years even though Dr Ambedkar had proposed reservations only for 10 years! In fact, I treat them just like others and very strongly feel that they too can do whatever they want just like others! Why should they be treated worse than disabled?

Who is stopping Centre from imparting free coaching to Dalits and all those coming from lower strata of society? Why can’t more scholarship be given to them? Why can’t they be coached by top successful persons of the field for which they are trying? Why can’t they be allowed free expense for giving as many exams as they like? They can be helped in thousands of ways other than reservations. Why politicians favour only reservation as the best possible way? Did Tina Dabi who topped IAS thus becoming the first Dalit to become a topper did by availing reservation benefit? No, by her merit she made it to the top!

How long will this cancer of reservation be allowed to fester and harm the unity and integrity of our nation endlessly? What precedent are politicians and PM setting by always talking about reservations only and never talking about finishing them as Dr Ambedkar wanted them to finish after 10 years only?

Reservation is the worst form of tool and only spreads hatred in society. Also, once it is inserted in the system, it is never thrown out as we can see in our own country where Dr BR Ambedkar who is the founding father of our Constitution wanted reservation only for 10 years but what an unbeatable irony that 70 years later we still see no end of reservations rather many States have increased it beyond 50% which only draws the ire of Supreme Court. This should never happen in AIJS.

For my esteemed readers exclusive benefit, let me tell them that it has been widely reported in the media that the Centre is getting ready to set up All-India Judicial Service (AIJS) by March 2022, according to a proposal submitted by the law ministry to the Union Council of Ministers. This was reported in ‘The Economic Times’ newspaper dated 2 March 2020 with heading “All-India Judicial Service Likely by March 2022”. So it is not that this cannot be worked out in the near future! It was also pointed out in this newspaper that, “The ministry in its recent presentation to the sectoral group of secretaries informed that AIJS was one of its top priority matters. The reports of the 10 sectoral group of secretaries were reviewed by PM Modi and the Council of Ministers. The biggest challenge is to get all states and high courts on board.”

Needless to say, we must applaud PM Modi’s courage and conviction to do what no PM has ever dared to do even though they too supported it – creation of AIJS. PM Modi has called for debate and discussion on creating AIJS but I very strongly feel that Law Commission has time and again recommended the creation of AIJS, former CJI too have recommended, Parliamentary Standing Committee also has recommended and National Judicial Pay Commission too has recommended then why so much of inordinate delay over it? It must be cleared soon now. After the Modi’s Cabinet clears the landmark proposal, the Union Public Service Commission (UPSC) will be entrusted with the AIJS examinations. The Delhi High Court asked the government in an earlier petition by Ashwini Kumar Upadhyay to decide on creating the IJS. It will again hear another petition by him for creating an IJS.

Be it noted, the move for an AIJS didn’t curry much favour with the higher judiciary in the past. The Chief Justices Conferences in 1961, 1963 and 1965 favoured the creation of an AIJS, but the proposal had to be shelved after some states and high courts opposed it. What should have happened way back in 1960s that we don’t see happening even in 2016 and it is only now after PM Narendra Modi has spoken on its dire need from a public platform and that too while addressing a function of lawyers and judges to celebrate the completion of 50 years of the Delhi High Court that some bright ray of hope has finally emerged.

To put things in perspective, subsequently, the Constitution was amended in 1977 to provide for an AIJS. The proposal was again floated by the UPA government in 2012 when it got it vetted by a committee of secretaries and prepared a cabinet note. But the draft bill was shelved after fierce opposition from high court chief justices. In 1972, the then Chief Justice of India had again endorsed the creation of AIJS.

Enough is enough! Now not any more! No more endless wait for AIJS! If Centre is really serious to combat the more than three and a half crore cases pending in lower courts all across the country, it has just no other viable option left before it but to start the AIJS. Ad hoc measures like re-employing retired judicial officers won’t serve much in the longer turn even though it may provide some relief. It cannot be a permanent cure. Centre must realize this which it has failed to realize in last 70 years.

In the absence of AIJS, it is becoming increasingly difficult to maintain the required judge strength in district courts and high courts. The available judges are unable to clear the huge backlog of over 30 million cases. Inspite of all this, IJS not started till date and mere opposition by few States/High Courts gave a lame excuse to successive Union Governments to just sleep over the matter.

Let me reveal here that in his PIL, Ashwini Upadhyay, who is also a BJP spokesperson contends fiercely that the establishment of IJS under the Article 312 of the Constitution of India, is not only necessary to provide equal opportunity to all prospective Advocates in spirit of Article 16 but also essential to secure fundamental right of fair trial and speedy justice to the citizens in spirit of Article 21. IJS has not been established in spite of constitutional provision and despite the Apex Court strongly endorsing it, he states in his petition. He further states that, while most government department has ‘All India Service’ recruits, the Judiciary is the only setup that does not have a national level selection process to attract the best prospective Advocates. “When IAS officers can be allotted State cadres and adjust to local requirements, why can’t IJS officers? Every organ of the State including the judiciary needs to be accountable to the public. People need to know how judges are appointed, what criteria they have been evaluated on. Many judges appointed by the collegiums or by political intervention may have been brilliant, yet their recruitment process is questionable. Judiciary should reflect social reality and the country’s diversity,” the petition reads.

Significantly, the Delhi High Court asked the government on July 11, 2016 to consider a lawyer’s representation seeking setting up of a All India Judicial Service on the lines of the Indian Administrative and Police Services. A Bench of Delhi High Court comprising of the then Chief Justice G Rohini and Justice Sangita Dhingra Sehgal asked the Ministry of Law and Justice to take a decision on the petitioner’s representation and inform him. In his plea, Ashwini Upadhyay said the step to set up the AIJS was “long overdue and has been hanging fire for ever five decades”. He also pointed out that, “Most government departments now had ‘All India Service’ recruits, the Judiciary does not have a national level selection process to attract the best possible talent”.

Before proceeding ahead, it would be imperative to quickly recapitulate the important events associated with AIJS. It will help us broadly in understanding this subject better. The list of important events are as follows: –

03-01-1977: AIJS inserted into Article 312 by the Constitution (Forty-second Amendment) Act 1976. The purpose of the constitutional amendment was to ensure uniformity in standard of selection and to attract the bright and young talent in judiciary so that fair trial and speedy justice made available to every citizen throughout the country.

27-11-1986: Law Commission submitted in its 116th report titled “Formation of All India Judicial Service” to the Union Law Minister and explained in details the importance and urgent need of All India Judicial Service.

10-4-1995: The Hon’ble Supreme Court in WP(C) 1022 of 1989, All India Judges Association v Union of India, directed the Union Government to take immediate measures for setting up the All India Judicial Service. The Union Government sought the views of the State Governments and High Courts on constituting the All-India Judicial Service before moving a resolution in Rajya Sabha.

10-2-1997: Union Government submitted a status report n constituting the All India Judicial Service in the Apex Court. Out of 25 states, 08 states endorsed AIJS, 08 states conditionally agreed upon AIJS, 07 states disagreed on AIJS and 02 states not responded. Out of 18 High Courts, 04 High Courts endorsed AIJS, 04 High Courts conditionally endorsed the AIJS, 03 High Courts disagreed with AIJS and 07 High Courts not responded on AIJS.

24-10-2009: Hon’ble Chief Justice of India endorsed the All India Judicial Service in his inaugural address in a conference titled “National Consultation for Strengthening the Judiciary towards Reducing Pendency and Delays” in Delhi.

25-10-2009: Conference titled “National Consultation for Strengthening the Judiciary towards Reducing Pendency and Delays” unanimously adopted the resolutions presented by Union Law Minister for establishment of All India Judicial Service and increase in the strength of judges by 25% to reduce the pendency of cases from 15 years to 3 years.

19-05-2014: Hon’ble 41st Chief Justice of India Sh. R.M. Lodha on the eve of assuming charge reiterated the need of the All India Judicial Service. He said: “Setting up of All India Judicial Service, being planned by the government on the lines of the IAS and IPS for recruiting judges for subordinate courts, should be given serious thought. A national consensus is lacking as some states have raised reservations on the framework of the Indian Judicial Service. Those states should also be brought on board.”

It must be emphasized here that the Law Commission of India has four times – in its 1st, 8th, 77th and 116th reports called for Indian Judicial Service. The Apex Court has twice – first in 1991, then in All India Judges Case (1992) endorsed the creation of AIJS. It is imperative to ensure fair selection of incumbents and to attract bright and best law graduates to judiciary.

Be it noted, Centre too strongly felt that to prevent the fresh law graduates from rushing to the all enticing private and corporate sector, it is imperative that All India Judicial Service be started immediately and they too are made eligible just like we see in case of Civil Services. Presently, what we are seeing is that the best talent is wasting no time in jumping on the bandwagon of corporate and private sector who is ever ready to hire them at attractive prices. To stop this to a great extent, it is all the more imperative that AIJS be started immediately without any more delay!

Most significantly, it cannot fbe lightly dismissed that three most eminent Judges in the annals of the Apex Court – Justice VR Krishna Iyer, Justice JS Verma and Justice MN Venkatachaliah gave their joint views on the constitution of All India Judicial Service as follows: “We agree with the urgent need to constitute the All India Judicial Service envisaged by Article 312 of the Constitution of India; at par with the other All India Services like the IAS, to attract the best available talent at the threshold for the subordinate judiciary; which is at the cutting edge of the justice delivery system to improve its quality. Moreover, the subordinate judiciary is important feeder-line for appointments to the High Courts. The general reluctance of competent lawyers to join the Bench even at the higher level adds an additional urgency to the problem. AIJS will in due course of time, also help to improve the quality of the High Courts and the Supreme Court. The modalities for creating the AIJS to achieve its avowed purpose, and the necessary constitutional changes and the legal framework can be worked out after acceptance of the proposal in principle.”

No less significant is the irrefutable fact that the First Law Commission of India, headed by learned MC Setalwad, with the benefit of the opinion of the then Chief Justices of India KN Wanchoo and Justice MC Chagla and eminent jurist Nani Palkhiwala among others, had made a strong recommendation for the constitution of an All-India Judicial Service, like the IAS and IPS. The felt need for such a service increased several fold in the last 57 years since that recommendation was made.

It is worth noting that in its 77th Report presented by the Law Commission of India to the then Law Minister Shanti Bhushan, it was noted in Para 9.6: “At the same time, we are of the view that the suggestion to have an All India Judicial Service of the same rank and same pay-scales as the Indian Administrative Service should receive serious consideration. According to article 312, as now amended, Parliament may by law provide for the creation of one or more all-India services (including an all-India Judicial Service) common to the Union and the States. We are conscious of the fact that a school of thought and many States are strongly opposed to the creation of All India Judicial Service. The objection is mostly based upon the consideration that since the proceedings before the subordinate courts would be conducted in regional languages, members of the higher judicial service hailing from other States would not be in a position to efficiently discharge their functions. This difficulty can be obviated if, like recruits to the Indian Administrative Service, the recruits to the All India Judicial Service also undergo a training period of two years. During that period, they can acquire also familiarity with and mastery of the regional language of the State to which they are to be allocated after the completion of their training period. The requirement about practice at the bar may perhaps have to be waived for recruitment to All India Judicial Service, as they will be recruited at a comparatively younger age. It should, however, be essential that the competitors are graduates in law.”

Para 9.6A of this very 77th Report further notes: “Another reason which should weigh in favour of the creation of the All India Judicial Service is the attraction that an All India Service holds for bright young graduates, including law graduates. The result is that many of them compete for and are selected for the Indian Administrative Service. If the All India Judicial Service is created with the same rank and pay scale as Indian Administrative Service, the Judicial Service would hold perhaps greater attraction for bright law graduates. The Judicial Service in such an event would not be denuded of talented young persons. The Law Commission presided over by Shri Setalvad also felt this difficulty and observed that an important factor which detracts from the attractiveness of the judicial service is the inferiority of the status of a judicial officer compared with that of the executive officer. The Law Commission in this connection referred to the following observations of an experienced Chief Justice: –

“One reason why meritorious young men or young practitioners of some standing keep away from the judicial service is the comparative inferiority of the status of district judicial officers vis-a vis officers of the district executive. Formerly, the district judge, like the district magistrate, used to be a member of the Indian Civil Service and its position in the District was superior to that of the District Magistrate. Under the present system, the district magistrate is a member of the Indian Administrative Service which is a service of an all-India character, while the district judge is a member of the higher judicial service which is a State service. The difference in the category of the cadres to which they belong is reflected in the status they occupy in relation to each other and in the estimation of the public vis-à-vis the district judge feels small and is treated as a person of little consequence. Nor can the district judge attain the sense of independence which he might have acquired, if he had not been under the administrative control of the State Government in regard to his service.”

It must also be brought out here that Parliament Standing Committee endorsed the AIJS in its 64th Report (Para – 50). The Report says: “All India Judicial Service has been envisaged under Article 312 of the Constitution of India. The Committee expresses its concern over the delay in its creation. The Committee insists that All India Judicial Service may be created without further delay to attract best talent to the subordinate judiciary from where 33% of the judicial officers are elevated to the Bench of High Courts. Reservation as per existing policy of the Government may be made applicable in All India Judicial Service.”

It is also worth pointing out that the first-ever National Judicial Pay Commission (NJPC), headed by Justice K Jagannatha Shetty who is a former Judge of the Supreme Court and who submitted its report in November, 1999 too recommended constitution of All India Judicial Service in the cadre of District Judges as per provision of Article 312(3) of the Constitution of India. The NJPC mooted that the District Judges, directly recruited and promoted, should constitute the AIJS. Seniority of All India Judicial Service will be on All India basis and as per the ranking in the select list. The inter-se seniority between direct recruits and promoters will be determined according to the date of allotment of promotion. Such direct recruit must thus be annexed to the respective State Judicial Service within the three-tier system. At present, there are only three All India Services i.e. The Indian Administrative Service (IAS), Indian Police Service (IPS) and Indian Forest Service (IFS). While the first two were inherited from British Raj, the IFS is the only All-India Service which was created after independence. It was constituted in 1966 under the All India Service Act, 1951 by the Government of India.

It is high time and now as PM Modi has himself said that the setting up of AIJS must be debated, discussed and deliberated upon before finally transforming it into reality. But it must be done soon. It should have happened right at the time of independence but 74 years later we see it still has not materialized! No delay any longer!

It must be underscored that uniformity in standards for selection will definitely improve the quality of different High Courts and will minimize the scope of partiality, arbitrariness and aberrations in judicial selection and simultaneously the quality of dispensation of justice will improve considerably right from the top to the bottom, as it essentially hinges upon the quality of judges recruited. It is the larger public interest that will be served if AIJS is created and also the interest of fair trial and speedy justice. The recruitment of Judges right from the entry level should be handled by an independent agency just like UPSC and can be named National Judicial Service Commission (NJSC).

It would be the job of NJSC to ensure that only and only the best talent selected through open competition is selected into AIJS thereby ensuring fair and transparent selection process just like IAS, IPS and others are selected into Civil Services by UPSC. Also, there should be comprehensive training of 2-3 years after selection in AIJS to be undergone in National Judicial Academy as we see in Bhopal.

We see court cases not ending even after more than 50 years. This completely erodes and tears apart the otherwise irrevocable faith of people in getting justice from courts. In foreign countries like USA, UK and Canada cases are decided very soon. But in India it is exactly the opposite. This must change if we want to project the image of India as a global destination centre for investment. That can happen only when cases are decided in time. Fair, fast and uniform justice keeps the people’s faith ingrained in the system which is so important for the successful functioning of any democratic country. Access to fair, fast and uniform justice is deeply rooted in the concept of democracy and regarded as a basic human right.

For cases to be decided in time, we need to have adequate number of judges which in turn is possible only if AIJS is started at the earliest. There is just no other viable option available and Centre must grab it with both hands and do the needful so that people at large benefit the most from it for whom justice is really meant. Only such a meritocratic service with open competitive examination and 2-3 years of comprehensive training to all the trainee judges and assured standards of probity and efficiency would be able to ensure “Fair Trial and Speedy Justice’ to citizens in spirit of the Article 21. Unnecessary delay gradually declines the citizenry faith in judicial system which is most dangerous. Fragmentation of faith has the effect potentiality to bring in a state of cataclysm where justice may become casualty. This will only usher in lawlessness which we can allow only at the cost of our own peril!

Needless to say, Opposition too must play its role well by cooperating in ensuring that the Bill for AIJS is passed with thumping majority in both Houses of Parliament. It must be noted that the Union Government cannot do anything unless the Council of States in this behalf passes a resolution to this effect, which is a mandatory requirement for creation of the same as also specified in Article 312. Centre must move a resolution in this regard without further delay. Delay of 70 years is quite a long delay by itself. Now no more alibis of any kind.

It is well accepted by thinkers, philosophers, academicians and jurists that if fair, fast and uniform justice is to be secured to all the citizens, and equality before the law and equal protection of the law has to be ensured, India needs the best talent in the judiciary. Needless to say, the quality of justice dispensation will ameliorate considerably right from subordinate courts to the Apex Court by initiating the AIJS and by establishing a NJSC like UPSC which is of seminal and pivotal concern.

To sum it up: It is in the interest of all concerned that the guilt or innocence of the accused is determined as quickly as possible. This in turn is possible only if there are adequate Judges. Adequate judges can be made available only if they are recruited in large strength through AIJS just like we see in case of IAS, IPS, IFS and other Civil Services. This alone explains why I mince no words to state emphatically that, “To constitute AIJS would be the greatest step since independence”. It brooks no more delay anymore now! I am sure that PM Narendra Modi would take further necessary steps to ensure that AIJS is given the green signal and after getting it passed in Rajya Sabha with the cooperation of Opposition as we saw recently in case of GST is soon brought into action! It is the young generation especially those who have just graduated or are about to graduate in Law in any part of India that will benefit remarkably by leaps and bounds if PM Narendra Modi takes this landmark and momentous decision anytime soon! I only hope that it does not again turn out to be an endless wait for them also as we saw most unfortunately in the past! Let’s hope fervently that history will not repeat itself again!

Sanjeev Sirohi, Advocate,

s/o Col BPS Sirohi,

A 82, Defence Enclave,

Sardhana Road, Kankerkhera,

Meerut – 250001, Uttar Pradesh

Recent Research in Migration and Gender Issues

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Media Trial During Investigation Interferes With Administration Of Justice

In a well-written, well-drafted, well-articulated, well-reasoned and well-worded judgment titled Mr Nilesh Navalakha and others vs Union of India and others in Public Interest Litigation (ST) No. 92252 of 2020 with Interim Application No. 95156 of 2020 that was delivered on January 18, 2021, the two Judge Bench of Bombay High Court comprising of Chief Justice Dipankar Datta and Justice GS Kulkarni minced no words to pronounce in no uncertain terms that media trial during criminal investigation interferes with administration of justice and hence amounts to ‘contempt of court’ as defined under the Contempt of Courts Act, 1971. The Court also held that media reports interfering with criminal investigation, before the initiation of trial, can amount to interference with administration of justice. Very rightly so! We had seen for ourselves how raucously the Sushant Singh Rajput case was discussed in different news channels.

To start with, as a prelude, the Bench first and foremost sets the ball rolling by first and foremost observing in para 1 that, “While COVID-19 was wreaking havoc in the country and causing unimaginable misery [viz. the working class losing jobs and thereby their livelihood, innumerable innocent lives being lost including those of migrant labours not only due to its direct but also indirect effects, the health-care system in all the States across the country facing extreme stress, justice seekers finding the justice delivery system almost inaccessible, etc.] and thus creating an atmosphere of severe tension and despair in the country, the unnatural death of a relatively young film actor (hereafter “the actor”, for short) in Mumbai on June 14, 2020 became the cynosure of the electronic media. The manifold problem, hardship and inconvenience brought about by the pandemic all over the country notwithstanding, various TV channels initiated intense discussion during prime time on the probable cause of death of the actor. Some of such channels, resorting to “investigative journalism” as they call it, sought to spread the message among its viewers that Mumbai Police has been passing off a homicidal death as a suicidal death and that a close acquaintance of the actor, who herself is an actress (hereafter “the actress”, for short), had orchestrated his death. What followed such reportage is noteworthy. The actor’s father had lodged an FIR at Patna, Bihar naming the actress as an accused for his son’s homicidal death. Incidentally, the actor hailed from Bihar prior to making a career in films and settling down in Mumbai. To conduct investigation into such FIR, police personnel from Bihar landed in Mumbai. Citing the pandemic, such personnel were promptly quarantined. It is not necessary for the present purpose to ascertain who were behind such move and what the motive was. Suffice it to note, the actress applied before the Supreme Court for transfer of a First Information Report at a police station in Patna and all consequential proceedings from the jurisdictional court at Patna to the jurisdictional court at Mumbai, under section 406 of the Code of Criminal Procedure (hereafter ‘the Cr.P.C’ for short) read with Order XXXIX of the Supreme Court Rules. Upon hearing the parties, the Supreme Court passed an order dated August 19, 2020 entrusting the Central Bureau of Investigation (hereafter “the CBI”, for short) with investigation into the complaint of the actor’s father. In compliance with such order, the CBI took over investigation. In due course of time, the Enforcement Directorate (hereafter “the ED”, for short) and the Narcotics Control Bureau (hereafter “the NCB”, for short) too joined the fray by launching separate prosecution suspecting offences under the Prevention of Money Laundering Act, 2002 and the Narcotics Drugs and Psychotropic Substances Act, 1985 (hereafter “the NDPS Act”, for short), respectively. After the intervention of the Supreme Court, it had been the claim of some of the TV channels that Mumbai Police’s vicious attempt to suppress the homicidal death of the actor, which had been unearthed by “investigative journalism”, stands validated by reason of the order of the Supreme Court. It had also been the claim of one of the TV channels that because of its persistent vigorous demands for divesting Mumbai Police of investigative powers in the case that truth has triumphed with the CBI being entrusted with the investigation by the Supreme Court. Investigation by the CBI, the ED and the NCB are still in progress.”

Adding more to it, the Bench then observes in para 2 that, “Apart from the above, a couple of TV channels aired several programmes raising questions as to the manner of investigation by Mumbai Police and also as to why the actress had not been arrested in view of materials that such channels had gathered through “investigative journalism”. One of them even went to the extent of obtaining opinion from the viewers on whether the actress should be arrested. One other channel flashed that the actor had been murdered. The persistent efforts of the channels for arrest of the actress did bear fruit in that although the CBI did not find reason to arrest her, she came to be arrested by the NCB. After a monthlong incarceration, this Court by its order dated October 7, 2020 granted the actress bail upon recording a finding that materials collected thus far by the NCB prima facie did not suggest that she had committed any offence under the NDPS Act.”

Most significantly, the Bench then further waxes eloquent to hold in para 349 that, “Having given our anxious consideration to all aspects of the matter, we are inclined to the opinion that the press/media ought to avoid/regulate certain reports/discussions/debates/interviews in respect of and/or touching upon any on-going inquiry/investigation into a criminal offence and that only those items are presented for reading/viewing and otherwise perceiving through the senses which are merely informative but in public interest instead of what, according to the media, the public is interested in. No report/discussion/debate/ interview should be presented by the press/media which could harm the interests of the accused being investigated or a witness in the case or any such person who may be relevant for any investigation, with a view to satiate the thirst of stealing a march over competitors in the field of reporting. Accordingly, we direct the press/media to exercise restraint and refrain from printing/displaying any news item and/or initiating any discussion/debate/interview of the nature, as indicated hereunder:

a. In relation to death by suicide, depicting the deceased as one having a weak character or intruding in any manner on the privacy of the deceased;

b. That causes prejudice to an ongoing inquiry/investigation by:

(i) Referring to the character of the accused/victim and creating an atmosphere of prejudice for both;

(ii) Holding interviews with the victim, the witnesses and/or any of their family members and displaying it on screen;

(iii) Analyzing versions of witnesses, whose evidence could be vital at the stage of trial;

(iv) Publishing a confession allegedly made to a police officer by an accused and trying to make the public believe that the same is a piece of evidence which is admissible before a Court and there is no reason for the Court not to act upon it, without letting the public know the nitty-gritty of the Evidence Act, 1872;

(v) Printing photographs of an accused and thereby facilitating his identification;

(vi) Criticizing the investigative agency based on half-baked information without proper research;

(vii) Pronouncing on the merits of the case, including pre-judging the guilt or innocence qua an accused or an individual not yet wanted in a case, as the case may be;

(viii) Recreating/reconstructing a crime scene and depicting how the accused committed the crime;

(ix) Predicting the proposed/future course of action including steps that ought to be taken in a particular direction to complete the investigation; and

(x) Leaking sensitive and confidential information from materials collected by the investigating agency;

c. Acting in any manner so as to violate the provisions of the Programme Code as prescribed under section 5 of the CTVN Act read with rule 6 of the CTVN Rules and thereby inviting contempt of court; and

d. Indulging in character assassination of any individual and thereby mar his reputation.”

For the sake of clarity, the Bench then makes it clear in para 350 that, “These are not intended to be exhaustive but indicative, and any report carried by the print media or a programme telecast by a TV channel, live or recorded, ought to be such so as to conform to the Programme Code, the norms of journalistic standards and the Code of Ethics and Broadcasting Regulations; in default thereof, apart from action that could be taken under the prevailing regulatory mechanism, the erring media house could make itself liable to face an action in contempt, i.e., criminal contempt within the meaning of section 2(c) of the CoC Act which, as and when initiated, would obviously have to be decided by the competent court on its own merits and in accordance with law.”

Quite remarkably, the Bench then observes in para 351 that, “It has been urged on behalf of the media houses that on diverse occasions, the guests are invited to speak and address the audience on a particular topic during programmes which are telecast live and, in such cases, it is difficult for the media houses to censor the statements of such guests. What the media houses say could be true, but that would not grant any speaker the license to either abuse or defame any particular individual, who could be the target of the speech, to tarnish his reputation in the eyes of the viewers or to indulge in interference with and/or obstruction to administration of justice by such public speaking. In case of the former, the targeted individual could sue the media as well as the speaker for defamation, which must ordinarily sound in damages but in case of the latter, both the media house and the speaker may be proceeded against for criminal contempt. It would not be enough for the media house to put up a disclaimer at the end of the programme that it does not associate itself with the views of the speaker and thereby evade liability. To obviate such situation, the media houses would be well advised to inform, guide and advise the guest speakers to refrain from making public utterances which are likely to interfere with and/or obstruct administration of justice and thereby attract contempt. The role of the anchor, in such cases, is also important. It is for him/her to apply his/her mind and avoid the programme from drifting beyond the permissible limits. Muting the speaker if he flies off or shows tendency of flying off at a tangent could be one of several ways to avoid embarrassment as well as contempt.”

In the same vein, the Bench then holds in para 352 that, “At the same time, while emphasizing on the need for a free, fair, effective and meaningful investigation of an FIR disclosing commission of cognizable offence by an accused ~ be it a celebrity or an ordinary person ~ to be conducted by the investigative agency, we also consider it appropriate to remind the investigative agencies that they are entitled to maintain secrecy in course of investigation and are under no obligation to divulge materials thus collected. If indeed there is leakage or disclosure of materials, which has the potential of stifling a proper investigation, it could pave the way for such information being laid before the competent court having powers to punish for criminal contempt under section 2(c) of the CoC Act and in an appropriate case, for being dealt with in accordance with law.”

In addition, the Bench then also adds in para 353 that, “That apart, one of the suggestions of Mr.Datar seems to us to be worthful and hence, we observe that Mumbai Police as well as the other investigating agencies may consider the desirability of appointing an officer who could be the link between the investigator and the media houses for holding periodic briefings in sensitive cases or incidents that are likely to affect the public at large and to provide credible information to the extent such officer considers fit and proper to disclose and answer queries as received from the journalists/reporters but he must, at all times, take care to ensure that secret and confidential information/material collected during investigation, the disclosure whereof could affect administration of justice, is not divulged. Such officer, if at all appointed, would nonetheless be instructed to bear in mind the decision of the Supreme Court in Rajendran Chingaravelu (supra). There, the Court warned of the growing tendency among investigating officers (either police or other departments) to inform the media, even before completion of investigation, that they have caught a criminal or an offender and that such crude attempts to claim credit for imaginary investigational breakthroughs should be curbed. The investigating agency should refrain from such acts that would prejudice not only the investigation but also the trial before the Court. We say no more on this topic.”

As it turned out, the Bench then also adds in para 354 that, “Finally, what remains for our consideration is Mr.Kamath’s suggestion that if any adverse order is passed by the UOI against an erring news broadcaster for violation of the Programme Code and such order has the effect of abridging the right guaranteed under Article 19(1)(a), this Court may direct that the same as against the broadcaster will remain in abeyance for a period of 15 days or so as to enable the news broadcaster to approach the appropriate Court for relief. We do not consider such suggestion worthy of acceptance. It is not open to the High Courts to further legislate when a legislation is in place. The duty of the High Court would be to interpret the law, if the occasion therefor arises. It is only in exceptional cases where there is no legislation covering a particular topic/subject but right of a subject is infringed or threatened to be infringed that the court may consider attempting to issue guidelines/directions to be followed till such time legislation in that behalf is made. While we have ourselves suggested measures that need to be followed so as to enforce the right to life of individuals accused of criminal offences under investigation as well as laid down guidelines for media reporting on criminal investigation at the prechargesheet stage, the latter is with the obvious intent of marking the ‘lakhsman rekha’ within which the media must operate to avoid contempt of court. However, in view of the provisions of the CTVN Act and the CTVN Rules, it is considered unnecessary to make any direction of the nature suggested by Mr.Kamath.”

In conclusion, the two Judge Bench of Bombay High Court in this noteworthy case makes it crystal clear that media trial during investigation interferes with the administration of justice and this is just not acceptable. All the news channels must always comply with what the Bombay High Court has held so explicitly, elegantly and effectively in this leading case. It also made it amply clear that doing media trial as stated above amounts to contempt of court as defined under the Contempt of Courts Act, 1971. The slew of directions that were remarkably issued by the Bombay High Court as we discussed above must be implemented in letter and spirit! It was also made amply clear that the media trial not only runs counter to the Program Code framed under the Cable TV Act but also interferes with the criminal investigation by police. It was also rightly held that, “Press media ought to avoid discussions, debates relating to criminal investigation and should confine only to informative reports in such matters in public interest. Media should observe restraint in discussions about ongoing investigation so as not to prejudice the rights of the accused and witness.” Media must comply now!

Sanjeev Sirohi, Advocate,

s/o Col BPS Sirohi,

A 82, Defence Enclave,

Sardhana Road, Kankerkhera,

Meerut – 250001, Uttar Pradesh.

Rape Victim Also Suffers Discrimination From Society

It is quite refreshing, rejuvenating and reasonable to learn that the Supreme Court most recently on January 20, 2021 in a latest, landmark, learned and laudable judgment titled Ms. X vs The State of Jharkhand & Ors in Writ Petition (Civil) No. 1352 of 2019 asserted quite unambiguously that a rape victim suffers not only a mental trauma but also discrimination from the society. This was held so by a three Judge Bench of the Apex Court comprising of Justice Ashok Bhushan, Justice R Subhash Reddy and Justice MR Shah while disposing a writ petition filed by a rape victim belonging to a Scheduled Tribe in Jharkhand. The victim had approached the Apex Court in 2019 by filing a writ petition stating the purpose therein.

To start with, the ball is set rolling of this notable judgment authored by Justice Ashok Bhushan for himself, Justice R Subhash Reddy and Justice MR Shah by first and foremost pointing out in para 1 that, “This writ petition has been filed by a rape victim invoking the jurisdiction of this Court under Article 32 of the Constitution.”

To put things in perspective, the Bench then quite remarkably puts forth in para 2 that, “This Court entertained the writ petition and while issuing notice on 29.11.2020 passed the following order: “Issue notice. Mr. Tapesh Kumar Singh, learned standing counsel for the State of Jharkhand, accepts notice on behalf of respondent/State. Let the respondent/State file an affidavit giving details of all proceedings initiated by the petitioner or against her and the status of those proceedings. We, however, observe that the respondent no.3/Home Secretary shall also ensure that the concerned police authorities are instructed to ensure protection of the petitioner. List after four weeks.”

To be sure, it is then stated in para 3 that, “A counter-affidavit has been filed on behalf of the State of Jharkhand to which rejoinder has also been filed by the petitioner. The petitioner has also filed certain additional documents.”

While elaborating on the facts of the case, the Bench then elucidates in para 4 that, “From the pleadings of the parties following facts emerged:

The petitioner claims to be a Scheduled Tribe in the State of Jharkhand. The petitioner was born on 24.12.1984. On 31.03.1998, petitioner was taken away by one Basant Yadav. Petitioner’s father, Rajender Badaik, lodged a complaint. Basant Yadav was apprehended on 02.04.1998. Father of the petitioner and Police of the concerned Police Station got the marriage of the petitioner solemnised with Basant Yadav. After one year of the marriage, one son was born, named Manish Yadav. Petitioner filed a complaint as well as case for maintenance against her husband, Basant Yadav.”

While continuing in the same vein, the Bench then points out in para 5 that, “The petitioner obtained divorce from Basant Yadav and the custody of son was given to Basant Yadav. On 08.06.2002, petitioner went to Dultonganj on asking of Basant Yadav to meet her son on which date she was raped by one Mohd. Ali and three other accused. Case No.162 of 2002 under Section 376/34 read with Section 3(xi) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989was registered in which accused, Mohd. Ali was apprehended and put on trial.”

Furthermore, the Bench then also points out in para 6 that, “The petitioner lodged an FIR against the DY. Inspector General of Police on 02.08.2005 under Section 376,376(2)(a)IPC and Section 3(1)(xii) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act,1989 on which on 03.08.2005 Case No.304 of 2005 was registered. The petitioner also lodged an FIR against an Inspector General of Police on which Sessions Trial No.257/2006 was registered. Certain other criminal cases got registered by the petitioner against different persons, some of which were filed under Section 376 IPC. In the Sessions Trial 11 of 2006, the accused Mohd Ali was convicted on 15.02.2014 with 10 years RI.”

Now as regarding the FIR, the Bench then states in para 7 that, “In the FIR lodged against Dy. Inspector General of Police final report was submitted which was accepted by the Court on 06.08.2007 insofar as FIR lodged against Inspector General of Police, Sessions Judge acquitted the Inspector General of Police by judgment and order dated 23.12.2017 against which criminal appeal has been filed in the High Court of Jharkhand. A criminal case was also lodged against the petitioner.”

While elaborating on the petitioner’s case in the writ petition, the Bench then enunciates in para 8 that, “The petitioner’s case in the writ petition is that she being the rape victim, whose identity was disclosed by the media and after knowing that the petitioner is a rape victim, no one is ready to give her accommodation even on rent. The petitioner in the writ petition invoked jurisdiction of this Court in the matter of rehabilitation of the petitioner. The petitioner also prays for direction to the respondent to protect the petitioner and her children’s life. The petitioner after divorce from her first husband got married to one Rajesh Kujur with whom a son was also born. The petitioner has also lodged criminal case being No.56/2004 against her husband Rajesh Kujur which resulted in acquittal.”

Needless to say, it is then stated in para 9 that, “The petitioner has also filed a copy of the legal notice dated 09.08.2019 which was sent by the landlord of the petitioner asking the petitioner to vacate the premises on the ground of non-payment of rent. The petitioner sent a letter dated 05.12.2019 stating that the landlord had sealed the house on 04.12.2019.”

While elaborating on counter affidavit by the State, the Bench then lays down in para 10 that, “In the counter-affidavit by the State, the State has given a tabular chart containing status of 7 criminal cases which were initiated by the petitioner. In paragraph 7 one of the cases mentioned in the chart is the case filed against Mohd. Ali, Mohd. Ali was convicted on 15.02.2014 under Section 376(2)(g) IPC and Section 3(1)(xii) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. In other criminal cases either the accused were acquitted or trial is pending in some cases. In two FIRs lodged by the petitioner, in the year 2018 under Section 354 A(ii) as well as under Section 376, 448 and 506 IPC respectively the investigation is said to be going on.”

Interestingly enough, the Bench then quite significantly concedes in para 16 that, “There can be no denial that the petitioner is a rape victim. Even if we do not take into consideration other criminal cases filed by the petitioner under Section 376 IPC, in Case No.162/2002 where allegation of rape was made on 08.06.2002 the accused, Mohd. Ali has been convicted under Section 376(2)(g) IPC for 10 years RI. The petitioner being a rape victim deserves treatment as rape victim by all the authorities.”

What’s more, the Bench then most significantly acknowledges in para 17 that, “A rape victim suffers not only a mental trauma but also discrimination from the society. We may refer to the judgment of this Court in Nipun Saxena and another vs. Union of India and others, (2019) 2 SCC 703, wherein following observations were made by this Court:

“12. A victim of rape will face hostile discrimination and social ostracisation in society. Such victim will find it difficult to get a job, will find it difficult to get married and will also find it difficult to get integrated in society like a normal human being. ………””

Of course, it is then brought out in para 18 that, “The petitioner herself has brought on record few orders passed in Writ Petition (Cr.)No.229 of 2014 (Padma @ Shushma Badaik vs. The State of Jharkhand and others)filed by the petitioner before the High Court of Jharkhand where in the order dated 12/11.09.2015 statement on behalf of the Counsel for the State was recorded by the High Court that State is ready to provide free education to the children of the writ petitioner. Following is the statement recorded by the High court on 12/11.09.2015:

“Counsel for the State has submitted that State is ready to provide free education to the children of the writ petitioner. If she will give her consent, her children shall be admitted in the Govt. Boarding School at Gumla and the expenses shall be borne by the Government.””

Quite significantly, the Bench then makes it clear in para 20 that, “On an inquiry by the Court as to which authority is to ensure that the minor children of the petitioner are provided free education, learned counsel submitted that it is Deputy Commissioner, Ranchi who can take the appropriate measures to ensure that the minor children of the petitioner are provided free education. Learned counsel for the State has submitted that education upto the age of 14 years in the State of Jharkhand is free which is provided by the State. We, thus, are of the view that Deputy Commissioner shall take appropriate steps to ensure that minor children of the petitioner are provided free education in any Government Institution at Ranchi.”

No less significant is what is then stated in para 21 that, “The petitioner has also raised grievance regarding her identity which has been disclosed by the media. The petitioner has annexed certain materials along with writ petition and the additional documents. Section 228-A of the Indian Penal Code which has been inserted in the Indian Penal Code by Amendment Act 43 of 1983 with effect from 25.12.1983 makes disclosure of the identity of the victim is an offence. Section 228-A is as follows:

“Section 228A. Disclosure of identity of the victim of certain offences etc.—(1) Whoever prints or publishes the name or any matter which may make known the identity of any person against whom an offence under section 376, section 376A, section 376B, section 376C or section 376D is alleged or found to have been committed (hereafter in this section referred to as the victim) shall be punished with imprisonment of either description for a term which may extend to two years and shall also be liable to fine.

(2) Nothing in sub-section (1) extends to any printing or publication of the name or any matter which may make known the identity of the victim if such printing or publication is—

(a) by or under the order in writing of the officer-in-charge of the police station or the police officer making the investigation into such offence acting in good faith for the purposes of such investigation; or

(b) by, or with the authorisation in writing of, the victim; or

(c) where the victim is dead or minor or of unsound mind, by, or with the authorisation in writing of, the next of kin of the victim:

Provided that no such authorisation shall be given by the next of kin to anybody other than the chairman or the secretary, by whatever name called, of any recognised welfare institution or organisation.

Explanation.—For the purposes of this subsection, “recognised welfare institution or organisation” means a social welfare institution or organisation recognised in this behalf by the Central or State Government.

(3) Whoever prints or publishes any matter in relation to any proceeding before a court with respect to an offence referred to in subsection (1) without the previous permission of such Court shall be punished with imprisonment of either description for a term which may extend to two years and shall also be liable to fine. Explanation.—The printing or publication of the judgment of any High Court or the Supreme Court does not amount to an offence within the meaning of this section.””

It is worth noting that it is then specified in para 22 that, “This Court in Nipun Saxena and another (supra) has occasion to consider Section 228-A wherein this Court in para 50.1 has issued following directions:

“50.1. No person can print or publish in print, electronic, social media, etc. the name of the victim or even in a remote manner disclose any facts which can lead to the victim being identified and which should make her identity known to the public at large.”” It cannot be just glossed over and has to be taken most seriously!

Simply put, the Bench then further elaborates in para 24 stating that, “With regard to the payment of compensation to the petitioner as a rape victim, along with additional documents the petitioner has brought on record materials to indicate that the decision was taken by the District Legal Services Authority, Ranchi to pay compensation of Rs.1,00,000/- by letter dated 06.03.2017. The letter of the Secretary, District Legal Services Authority, Ranchi has been brought on record by the petitioner herself. The grant of compensation has been considered under the Jharkhand Victim Compensation Scheme, 2012 as amended in 2016.”

As it turned out, the Bench then more significantly makes it clear in para 26 that, “The next grievance which has been highlighted by the petitioner is the petitioner’s inability to get any rented accommodation in Ranchi due to she being a rape victim. In the counter-affidavit filed by the State, it is clear that the petitioner has lived at several/different places but due to the dispute with the landlord she has to leave the premises. There are various Central as well as State Schemes for providing residential accommodation to persons living below poverty line and other deserving cases, the Deputy Commissioner, Ranchi may consider the case of the petitioner for allotment of any housing accommodation under Prime Minister Awas Yojna or any other Scheme of the Centre or the State.”

Finally, the Bench then concludes by holding in para 27 that, “In view of the foregoing discussion, we dispose of this writ petition with the following directions:

(1) The Deputy Commissioner, Ranchi is directed to take measure to ensure that minor children of the petitioner are provided free education in any of the Government Institutions in District Ranchi where the petitioner is residing till they attain the age of 14 years.

(2) The Deputy Commissioner, Ranchi may also consider the case of the petitioner for providing house under Prime Minister Awas Yojna or any other Central or State Scheme in which petitioner could be provided accommodation.

(3) The Senior Superintendent of Police, Ranchi and other competent authority shall review the Police security provided to the petitioner from time to time and take such measures as deem fit and proper.

(4) The District Legal Services Authority, Ranchi on representation made by the petitioner shall render legal services to the petitioner as may be deemed fit to safeguard the interest of the petitioner.”

On the whole, the Bench very rightly made it clear that the petitioner deserves treatment as rape victim by all the authorities. It was also conceded by the Bench that this was also more so due to the irrefutable fact that she suffered not just mental trauma but also endless discrimination that she suffered from society. The directives that the Bench issued as discussed above thus stands fully justified!

Sanjeev Sirohi, Advocate,

s/o Col BPS Sirohi,

A 82, Defence Enclave,

Sardhana Road, Kankerkhera,

Meerut – 250001, Uttar Pradesh

THE RELATIONSHIP BETWEEN LINGUISTICS AND HISTORY

Title	THE RELATIONSHIP BETWEEN LINGUISTICS AND HISTORY
Author	HUSSAIN ALI WANAS and WafaaHadi Habeeb
Edition	1
Volume	1
price	500
Year Of Allotment	2021
Book Version	PaperBack
Book Description	This book is about THE RELATIONSHIP BETWEEN LINGUISTICS AND HISTORY. This is an analytical study done by two authors jointly. This will book help readers in understanding the intricate relations that exist between linguistics and history.
ISBN Number	“978-93-86954-60-2”
Language	English
Imprint	PEN2PRINT

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