NATIONAL LAW UNIVERSITY ODISHA, CUTTACK

Media Law Project

Semester VIII

(January 2020 – May 2020)

ROLE OF PRESS IN A DEMOCRACY

SUBMITTED BY: SUBMITTED TO:

ANANT SANGHI (16 BBA 007) MS. SOHINI MAHAPATRA

KUNAL GOSWAMI (16 BBA 028) (ASSISTANT PROFESSOR OF LAW)

 Table of Contents

Research Objectives...................................................................................................................1

Research Questions....................................................................................................................1

Research Methodology...............................................................................................................1

Scope and Limitations................................................................................................................1

Introduction................................................................................................................................2

Chapter I – Role of Press in a Democracy – A Legal Perspective.............................................4

Chapter II – Role of Press in a Democracy – A Utilitarian Perspective....................................7

Chapter III – Role of Press in a Democracy – An Investigation..............................................10

Conclusion and Suggestions....................................................................................................14

Bibliography.............................................................................................................................16
 Research Objectives

 To scrutinise the inter-relationship between press and the Indian constitutional

landscape.
 To elucidate and anatomise the role ought to be played by a responsible press
especially in its operation within world’s largest democracy.
 To investigate the role undertaken by press within the precincts of Indian socio-
political and legal landscape.
 To anatomise the possible blueprints for achieving ideal press freedom from a
panoramic perspective.

Research Questions

 How much freedom qualitatively as well as quantitatively is enjoyed by the press

within the contours of Constitution of India?
 What should be the role of press in a democracy from a utilitarian perspective?
 What is the role played by Indian press in reality?
 If the role played by the press suffers from any vice (if any) then how can it be cured?

Research Methodology

The methodology of research used in this project is doctrinal in kind and qualitative in
character. Both primary and secondary sources of data have been consulted for coming up
with this work which includes commentaries, legislations, journals, cases etc. No empirical
research was employed for coming up with this work.

Scope and Limitations

 Word Limit
Constraint
 Research largely based on Secondary Sources
 Research scope is limited to Indian socio-political and legal landscape

Page | 1
 Introduction

“Democracy is a kingless regime infested by many kings who are sometimes more
exclusive, tyrannical and destructive than one, if he be a tyrant”. It is the fear of being
exposed by the media before the public that most of the politicians keep themselves
under control to some extent”

- Benito Mussolini, Former Prime Minister, Italy

From the dawn of human civilization and even in epochs preceding it dissemination of
knowledge has been the catalyst in the entire epilogue of our robust leap towards modernity,
for instance it was the otherwise simple invention of printing press and dissemination of
knowledge therefrom which has redeemed Europe from the clutches of dark age and religious
orthodoxy and has recalibrated it as the harbinger of industrialization. In today’s post-modern
and neo-liberal era when data is revered as the new currency, information and its propagation
has adorned a new pedestal altogether especially in welfare states with a democratic form of
government. Democracy when visualised from the panoramic perspective often reverberates
popularly as a form of government which is of the people, for the people and by the people or
as a form of government where subjects are the sovereign or as a form of government
enshrining utmost lucidity in its social contract however, the same democracy when
visualised from worm’s-eye view then it is perceived as an animated superstructure
beautifully balancing itself defying gravity upon the buoyancy of four golden pillars viz, the
three wings of government equidistant from each other by virtue of the Montesquieuan
principles have their respective roles, the fourth pillar popularly known as the Press or Media
is placed equidistant from the rest three with the role of keeping the other pillars under
surveillance and to send alarm signals whenever these pillars discontinue to be equidistant by
displacing themselves or if either of them began to rust from inside so that the superstructure
does not crumble.

Freedom of press is absolutely non-negotiable for any democracy to excel and for prevalence
of sovereignty of the citizenry over their chosen service providers i.e. the government. The
role of press in any democracy is quintessential be it in establishment of democracy, as a
medium of social change, as an instrument of awareness, as a whistleblower of any
unscrupulous practice within the precincts of power corners, as a fierce critic of governance
failures and many more. It would not be wrong to perceive press as the sense-organs in the
anatomy of the organism called the society or nation. In this paper the authors are going to
anatomise the role of press in a democracy initially through the prism of socio-legal
perspective, followed by an utilitarian scrutiny if the role ought to be played by the press in a
democracy which in turn will be succeeded by an investigation scrutinizing the role played by
the press in a democracy.
 Chapter I – Role of Press in a Democracy – A Legal Perspective

As mentioned in the introductory section of the paper, in a democracy like India, media or
press is considered to be the fourth pillar of a democratic society after executive, legislature,
and judiciary in a democracy where the doctrine of separation of power is the basis of
governance as mentioned earlier. The interface between the media and common man has
enhanced largely over time. The media (print or electronic) has become a part of the life of
the people of India, who are largely dependent on the media coverage for entertainment and
information. Starting from the issues relating to common man, their feelings, their necessities,
their expectations and every aspects of their life closely associated with the media. Media
keeps the peoples awakened and there is no denying the fact that it has become one of the
major instruments of social change. In a democratic set up, it is media which strengthens the
democratic norms and values and also accelerates the pace of development. The role of press
in a democracy may be manifold and looked at from various perspectives but the press must
perform its role within the contours of the Grundnorm or the fundamental document of
governance in the country that is the Constitution of India.

The preface to the Indian constitution, the preamble promises to secure for every citizen of
India, freedom of thought, articulation and conviction. The media derives its rights from
Article 19(1)(a) of the Indian Constitution which talks about the Freedom of Speech and
Expression as freedom of press is not particularly stated under the Indian Constitution.

Article 19(1) reads as: 19(1) All citizens shall have the right - (a)to freedom of speech and
expression. The right is subject to reasonable restrictions set out in Article 19 (2) which states
that – “Nothing in sub clause (a) of clause (1) shall affect the operation of any existing
law, or prevent the State from making any law, in so far as such law imposes reasonable
restrictions on the exercise of the right conferred by the said sub clause in the interests of
the -

 sovereignty and integrity of India

 the security of the State
 friendly relations with foreign States
 public order
 decency or morality or
  in relation to contempt of court, defamation or incitement to an offence.”

Along these lines, the media has similar rights no more and no less than any person to
compose, distribute, flow or communicate. After the independence of India when the
constitution was being drafted, the question aroused before the constitutional makers of India
that whether or not to have a separate provision for press like in Constitution of America, or
to include the freedom of press in right to speech and expression as in constitution of
England.

In this context, Dr. B.R. Ambedkar, the Chairman of Drafting committee powerfully argued
that, - “The press is simply another way of describing a citizen or an individual. The media
has no superior privileges which are not to be given or which are not to be exercised by the
voter in his separate capacity. The executive of press or the editor are all citizens and
therefore when they select to write in a newspaper they are just exercising their right of
freedom of speech and expression and in my decision then no special mention is necessary of
the freedom of press at all”1.

Hence, in Indian constitution the right to press was inserted in freedom of speech and
expression i.e., Article 19(1)(a). Free press is the need of democracy and is more important
for a huge democratic country like India.

In India in the absence of any exact article in the constitution for free press, it was the
judiciary who promoted and safeguarded the independence of press. In Brij Bhushan v State
of Delhi the honourable Supreme Court held that freedom of speech and expression
guaranteed under Article 19 (1) (a) can be curtailed only and only by adhering to a strict
interpretation of the grounds given under Article 19 (2). The facts of the case were that an
English weekly was subject to pre-censorship on the ground of “public order” which was not
included as a ground under Article 19(2). The court held that since public order was not a
restriction under Article 19(2), thus, the right to freedom of expression cannot be curtailed on
this basis. This led to the grounds of “public order” and “Friendly relations with foreign
states” being added by the Constitution (first amendment) Act, 1951.

1
Constituent Assembly Debates, Vol. VII p 780 (2nd December 1948)
The Supreme Court in Romesh Thapar v. State of Madras2 observed that right to circulation is
as important as right to publication.

In Sakal News Papers v. Union of India3 indirect effort by Government to restrict the
freedom, by passing the Newspaper (Price and Pages) Act 1956, which empowered the
government to regulate the space for advertisement, was struck down by judiciary as it,
would have direct impact on circulation.

If the judiciary has protected the rights of press it has also constrained it in the interest of
justice. The Apex court in State of Bihar v. Shailabala Devi4 held that speech and expression
on part of an individual which inflames or boosts ferocious crimes such as murder, etc. will
undermine the security of the state and circulation and publication of such content needs to be
curbed. The court in the case of Dr. D.C. Saxena v. The Chief Justice of India5 has held if
preservation of democracy is the foundation for free speech, society equally is authorized to
regulate freedom of speech or expression through democratic action. The cause is evident,
e.g., that society accepts free speech and expression and also puts restrictions on the right of
the majority.

The discourse here-above clearly elucidates the quantum of inter-relationship of press with
our Grundnorm, the Constitution of India both in qualitative and quantitative frontiers. The
drafters of our constitution have equated and treated alike otherwise differently placed
subjects viz, the disseminators of knowledge or the press and its receivers i.e. the common
citizenry in terms of the privilege and immunity that should be at their disposal against the
state actions to curb their freedom of speech and expression. This erroneous application of
the equality doctrine in the guise of idealistic pursuits have inevitably made the press
vulnerable and prone for succumbing under authoritarian dictates on account of lack of
immunity. The judiciary has time and again stepped in to safeguard the freedom of press but
if freedom of press remains dependent upon the suzerainty of the judiciary then it inevitably
questions the foresight of the makers of the constitution and qualitative mediocrity of the
immunity granted to press by virtue of the constitution of world’s largest democracy.

2
AIR 1950 SC 124.
3
AIR 1962 SC 305.
4
AIR 1952 SC 329.
5
(1996) 5 SCC 216.
 Chapter II – Role of Press in a Democracy – A Utilitarian Perspective

In this part of our research paper we shall deal with the role of press in a democracy through
a theoretical and utilitarian prism. This Benthamite perspective would aid us to deduce what
should be the ideal role of press in a democracy which in turn would provide us the required
objectivity to anatomise the actual role played by media on the touchstone of these objective
deductions.

Normative Roles of Media – from the perspective of media democracy approach

Media democracy is a democratic approach to media studies that advocates for the reform of
mass media to strengthen public service broadcasting and develop participation in alternative
media and citizen journalism in order to create a mass media system that informs and
empowers all members of society and enhances democratic values.

1. Monitory Role – This role of the press and media involves organized scanning of the
people, status and events and potentially relevant sources of information. The
information gathered is evaluated and verified. The media has to stay alert and restrict
absolute political power. It provides information to individuals to make their own
decisions under this role.
2. Facilitative Role – Using journalism as a means to improve the quality of public life
and promote democratic forms. It acts as a glue to hold community together. And it
also enhances the ability and desire to listen to others.
3. Radical Role - Going to the "root" of power relations and inequality in society and
exposing their negative impacts upon the quality of everyday life and the health of
democracy. Oppositional to commercial/mainstream media which tend to protect the
interest of the powerful and fail to provide information that raises critical awareness
and generated empowerment. Cultivating political advocacy motivates engaging in
political social democracy.
4. Collaborative Role - Collaboration between media and state should always be open
and transparent.

Role of Media in Indian Democracy

Media is considered as a backbone of any democracy. The following role are played by the
media in Indian democracy –
1. The media works as a watchdog of the government and carries every report of the
action of administration thereby keeping the people informed about the day to day
happenings taking place around them.

2. The media is considered as fourth pillar of democracy. It makes us aware of various

activities like politics, sports, economic social and cultural activities etc. It is also like a
mirror which shows the bare truth and sometimes it may be harsh.

3. The media also exposes loopholes in the democratic society, which ultimately helps
government in filling the vacuums of loopholes and making a system more accountable,
responsive and democratic friendly. Thus, the democracy without media is like a vehicle
without wheels.

4. Media acts as a bridge between the people and the government and also a very powerful
tool with the ability to make and break the opinion of the people. It has the capacity to swing
perceptions or evoke emotions. This is why it has gained faith of the public. Media, through
its various means of newspapers, television and cinema is what rules the heart and mind of
people.

5. The Media can act as an agent of social change and education- The media has helped to
shape the democratic society by giving emphasis to issues that are at one point in time, would
have been considered strictly private such as child birth, child care, domestic violence, and
sexual harassment.

6. Media as a medium of communication - Media in exercise of freedom of expression is

essential to communicate the thoughts, views, ideas, philosophy, ideals and activities.
Communication keeps society together and cohabitate. For healthy growth of civilization
world, the free flow of information and ideas is essential.

7. Modern Methods of interpersonal Media communication include seminars dramas, public

meeting and workshops etc. these are effective media methods to address small and medium
gatherings, which can be used as grounds for advocating the Human Rights and building
public opinion.
8. Media technology has got a crucial role in everyone’s life today. Media has got a great job
of bringing social change in whatever the topic covers from entertainment to all the on-going
issues.

9. In any democratic country the media plays a vital role in creating, moulding and relating
public opinion. Over the years the media became so powerful that it soon acquires the status
of fourth pillar or estate as it was aptly described by the British politician Edmund Burke. It
has become so indispensable for the democratic functioning that Thomas Jefferson who was
the third US president (1801-1809) said, “Were it let to me to decide whether we should have
a government without newspapers or newspapers, without a government. I should not
hesitate for a movement to prefer the letter”.

10. Other Roles - Media today touches almost every aspect of our public life. Media plays a
very important and crucial role in enlisting and educating the people. The media can aid
public involvement through advocating issues and transferring knowledge, skill and
technologies to the people. Awareness about various rural development programs,
propagation of family planning could be spread by using the media. It made farmers aware of
the new and improvement methods of agriculture and protection of the crops. Media plays
very emphatic role in awakening people against many evils prevailed in the society like child
marriage, killing of female unborn child, the evil practice of child labour etc. though
educational programs, it can cover many students in a single platform. The university Grant
Commission telecast educational programs for the benefit of the school and college students
all over India. Media can ignite scientific temper among the students for development of
science. The government can use the media more effectively to make it an instrument of
social change. Media has exposed a number of corrupt practices, hidden deals, thus putting a
check on the cancer in the form of corruption in the society.6

6
Mohd Ayub Mir, The Role of Media in Indian Democracy (2019) 6 IJRAR, 584.
 Chapter III – Role of Press in a Democracy – An Investigation

The discourse in the previous chapter has thrown light on what is the in principle and ideal
role of media in a democracy. In this chapter we shall put forth some worthwhile instances
which give Indian press and media its reputation and rank on the World Press Freedom Index.
We shall first start with highlighting certain illustrations when the Indian media bossed the
role of a democratic media on the contours and principles discussed, followed by some of the
illustrations in the current scenario which kind of justify its abysmal position in the world
tally of press freedom.

Instances when Indian Media and Press proved its mettle

1. The Hindu’s Bofors Expose

The Bofors scandal that broke in 1987 marked a watershed for India — it was the first time
corruption became an intensely public and political issue. The scandal was uncovered mostly
The Hindu and reported by Chitra Subramaniam-Duella and N. Ram. Almost 200 documents
relating to Bofors were secretly sourced, verified and translated from the Swedish language
before being published along with interviews and analytical pieces. Such was the public fury
stoked by this investigation that the government in power eventually ending up on the losing
side in the 1989 general election. Interestingly, the Bofors expose was also featured as one of
the 50 great stories produced by Columbia Journalism School alumni—N. Ram is one
himself—in the past 100 years.

2. Tehelka’s Defence Deals Expose

Even as the nation was trying to find its feet after being knocked off balance by the massive
Bhuj earthquake, on March 13, 2001, Tehelka published an investigative report that ripped
the lid off the murky world of defence deals. Carried out using hidden cameras, the
investigation (called Operation West End) publicized secret videotapes of top politicians,
bureaucrats and military official accepting bribes from two reporters (who posed as arms
agents). The resulting furore created a major political storm and led to the resignation of
those indicted by the videotapes. Interestingly, the same year, Tehelka also blew the lid of the
explosive match-fixing scandal in Indian cricket.

3. Indian Express’s Cement Scam Expose

On the morning of August 31, 1981, readers of the Indian Express woke up to find a
meticulously-researched expose on corruption in the grant of government cement quotas,
complemented by supporting evidence and a blistering analysis that ran into 7,500 words.
The swift, bold and bloodless journalistic coup has since come to be known as India’s
Watergate – or the Cement scandal. Almost overnight Arun Shourie, the then-executive
editor of the Indian Express, became a national “hero” for his consciously studied and
fearlessly pursued investigation of organised corruption in high places.

4. Indian Express’s Human Trafficking Expose

Ashwini Sarin is known as the man who showed how investigative journalism can further the
cause of democracy. The Indian Express reporter is best known for his incisive report on
human trafficking that created a whole discourse around flesh trade, controversial as it may
have been. In 1981, he exposed the sordid racket by breaking the law himself (when he
bought a tribal girl named Kamala) and show how easy it was to buy humans in India. His
work also inspired the movie and play named ‘Kamala‘.

5. Open Magazine’s Nira Radia Tapes

In November 2010, Open magazine carried the transcripts of telephone conversations

between Nira Radia (a political lobbyist cum PR honcho) and politicians, industrialists,
officers of corporate houses and senior journalists. The tapes — wire-tapped by the Income
Tax department on a tip-off by the Central Board of Direct Taxes — shone a harsh light
on the murky manipulations that take place at the highest levels in the country to manoeuvre
government formation, influence public opinion, and cater to corporate interests.

Recent Instances when the Indian Media justified its low World Press Freedom Index Rank

1. CAA, Shaheenbagh Protest and Delhi Riots

Partial reporting and misinformation was evident with the coverage of the recent Delhi Riots.
The mainstream media’s entire agenda in this reporting was to spread Islamophobia and
garner confidence of the majority towards the government. In doing so it has resorted to
unscrupulous practices like selling misinformed narratives which has exponentially increased
communalism among the Indian masses. All have either distorted, outright lied, misquoted
and/or even gone so far as cropped images.7

2. Tablighi Jamat, a scapegoat for Covid19 pandemic by the Indian mainstream

media.

Indeed, it was irresponsible of the Tablighi Jamaat, a Muslim religious organisation, to hold a
gathering of more than 2,000 delegates, including foreigners, at Nizamuddin Markaz, its
headquarters in Delhi, between March 13-15. Even though the nationwide lockdown was
announced a week later and the Jamaat cooperated with the police to evacuate its premises,
the organisation should have cancelled the planned event suo motu, taking a cue from the
suspension of congregational prayers at the holy mosques in Mecca and Medina. But no
amount of irresponsibility justifies the mainstream media’s unprecedented demonisation of
Jamaat members. On March 30, a week into the lockdown, news channel after news channel
began discussing “Markaz virus”, “Corona Jihad” and “Corona Jamaat” – as if to indicate
that the Tablighi Jamaat was carrying out a concerted campaign to spread the disease in India.

Maps of India were flashed, showing the Delhi Markaz as the epicentre from where arrows
pointed to other states. A TV news channel graphic depicted a man wearing a skull cap
alongside a caption that said “almost 60 per cent of new (April 1-3) coronavirus cases in
India linked to the Jamaat.8

3. Pulwama Attack and its aftermath

The long-simmering crisis of credibility in the Indian news media reached a boiling point in
the weeks following the deadly terrorist attack in Pulwama, Jammu & Kashmir last month.
India’s television stations dispensed with even basic journalistic rules, as seasoned reporters
declared unequivocal allegiances and experienced editors parroted exaggerated claims.

7
Priyanka Deo, ‘Biased Mainstream Media Carries Grave Consequences for Indian Democracy’ (News 18,
March 18, 2020) <https://www.news18.com/news/opinion/biased-mainstream-media-carries-grave-
consequences-for-indian-democracy-2541333.html> accessed 18 April 2020
8
Irena Akbar, ‘It Was Naive to Expect They Would Forget Their Hatred Towards Muslims in a Crisis’ (The
Wire, 20 April 2020) <https://thewire.in/communalism/it-was-naive-of-us-to-expect-india-would-forget-its-
hatred-towards-muslims-in-a-crisis> accessed 20 April 2020
Theatrics abounded, with toy-gun totting warrior anchors in army fatigues drumming up an
atmosphere of hate and violent jingoism.9

The Indian media has ascribed to itself the role of an amplifier of the government propaganda
that took two nuclear states to the brink of war. Many TV newsrooms were transformed into
caricatures of military command centres, with anchors assessing military technology and
strategy (sometimes incorrectly). Some even dressed for the occasion in combat gear.
Speculation and conjecture were repeated ad infinitum, and several journalists even took to
social media to encourage the defence forces.

The media continued to promote government positions on the crisis, other critical political
issues dropped out of public scrutiny. The controversy surrounding the Rafale deal and
allegations of corruption against the government were suddenly side-lined, as was the order
for the eviction of more than a million forest dwellers (that was later stayed) and a hearing on
the repeal of Article 370 before the apex court.

The entire episode is emblematic of a broader trend in Indian media. Many news channels are
not only owned, operated or invested in by politically influential families, but also are
sometimes run for the express purpose of advancing party positions. To make matters worse,
between 2013 and 2019, editors of channels and publications have been sacked and replaced,
primarily because of their criticism of the ruling Bharatiya Janata Party.

As such, very few media establishments in India have been able to stand against the influence
of political leaders. Now, along with the media’s legitimization of an ideology that promotes
violence — including riots and lynchings — its performance after Pulwama leaves severe
doubts as to whether it is engaged in journalism or the propagation of Hindu
majoritarianism.10

9
Prem Anand Mishra, ‘India needs Aazadi from Biased Media: It is killing Indian democracy’ (National Herald,
25 November 2019)< https://www.nationalheraldindia.com/opinion/india-needs-aazadi-from-biased-media-it-is-
killing-indian-democracy 25 Nov 2019> accessed 20 April 2020
10
Suchitra Vijayan and Vasundhara Sirnate Drennan , ‘After Pulwama, the Indian media proves it is the BJP’s
propaganda machine’ (Huffington Post, March 5, 2019)
<https://www.washingtonpost.com/opinions/2019/03/04/after-pulwama-indian-media-proves-it-is-bjps-
propaganda-machine/> accessed 19 April 2020
 Conclusion and Suggestions

The essence of the large sections of Indian mainstream media is that. There is no objective
truth but a lot of malice, there is no accountability but to serve the regime. This crisis of
Indian media is writing a new history that recommends the death of critical journalism with
constant manufactured opinion and no accountability. Media as propaganda is quite inherent
to its functioning but this nakedness of representing the regimes’ voice against the objective
truth is killing Indian democracy all in the name of freedom of the press. This crisis has
ceased to become a disease now. News Anchors have become Judge and pass their judgment
shamelessly without any ethical consideration. This making of new history is to make people
consumers than citizens whose only job is to remain a passive entity. It is eroding India’s
democratic credentials. News has lost it worthiness and the priorities are shifted from people
to serve the regime and its supported business houses that control and set the agenda, all in
the name of freedom of the press.

It can be stated without much hesitation that in recent times instead of being a fundamental
pillar of democracy, media will become a deceitful, distrustful and dangerous institution to
the country. Communal and caste divisions will only increase. In a diverse nation like India,
this has severe impacts. Disrespect, distrust, hatred, division, hurt, damage and fatality to
innocent citizens at a large scale.

The authors would like to conclude this discourse with utmost optimism and belief that It is
about time for mainstream media to really think about how to sell objective reporting. That is,
if they are vested in the progression of the country. We live in times where bad news sells.
But it is only the media and funders of these media platforms that can completely change this
around. Stop the incorrect reporting. Ban fake news. Make it not okay to insult leaders
without any objective cause. The misinformation is creating alienation, ignorance and
misinformed extremism among the people. It won’t be long before Indian democracy
completely falls apart.

The authors would further like propose certain suggestions to redeem the press from the
miseries with which it is plagued.

1. Enactment of Legislations immunising the journalists – Even in colonial India, the

trade union leaders were granted certain immunity against malicious criminal
 prosecutions. The role played by a journalist is no less important for prevalence of
democracy than that of a labour leader. Thus, it becomes imperative in absence of any
special privilege for the press granted by the constitution the individual journalists
who are often targeted by the coercive machinery of the state like the police must be
immune with certain legislative privileges against unwarranted prosecution and
harassment.
2. Upheaval of the revenue model of the media houses - As already discussed certain
political and business families do control a large quantum of shares in the mainstream
media houses. As a result the press serves as a mouth piece of these stakeholders and
does nothing more than the act of propaganda at their behest. This is no surprise but
simple logic that such media houses cannot rob their own overlords. This entire
revenue model needs to be recalibrated wherein the media depends for its existence
not upon certain powerful overlords but upon the common citizenry who are its
readers and the only way they can exist is by serving quality information to them.
 Bibliography

News Websites and Blogs

 Irena Akbar, ‘It Was Naive to Expect They Would Forget Their Hatred Towards
Muslims in a Crisis’ (The Wire, 20 April 2020) <https://thewire.in/communalism/it-
was-naive-of-us-to-expect-india-would-forget-its-hatred-towards-muslims-in-a-crisis>
accessed 20 April 2020
 Prem Anand Mishra, ‘India needs Aazadi from Biased Media: It is killing Indian
democracy’ (National Herald, 25 November 2019)<
https://www.nationalheraldindia.com/opinion/india-needs-aazadi-from-biased-media-
it-is-killing-indian-democracy 25 Nov 2019> accessed 20 April 2020
 Priyanka Deo, ‘Biased Mainstream Media Carries Grave Consequences for Indian
Democracy’ (News 18, March 18, 2020)
<https://www.news18.com/news/opinion/biased-mainstream-media-carries-grave-
consequences-for-indian-democracy-2541333.html> accessed 18 April 2020
 Nikhil Imandar, ‘How Narendra Modi has almost killed the Indian media’ (Quartz
India) <https://qz.com/india/1570899/how-narendra-modi-has-almost-killed-indian-
media/> accessed 20 April 2020
 Suchitra Vijayan and Vasundhara Sirnate Drennan , ‘After Pulwama, the Indian
media proves it is the BJP’s propaganda machine’ (Huffington Post, March 5, 2019)
<https://www.washingtonpost.com/opinions/2019/03/04/after-pulwama-indian-
media-proves-it-is-bjps-propaganda-machine/> accessed 19 April 2020

Articles

 B.Mugundhan, C. Renuga, ‘A Study On Freedom Of Press In India: With Reference

To Article 19’ (2018) International Journal of Pure and Applied Mathematics 3957-
3973.
 Mohd Ayub Mir, The Role of Media in Indian Democracy (2019) 6 IJRAR, 584.