An Analysis Of Reporting Custodial Torture : To What Extent Can The Role Of Media Be Appreciated ? By - Neeti Goyal & Harshita Bhala

An Analysis Of Reporting Custodial Torture : To What Extent Can The Role Of Media Be Appreciated ?
 
Authored By - Neeti Goyal  & Harshita Bhala
 
ABSTRACT
The seminar paper attempts to explore the changing dynamics of reporting and reception of news in the areas where certain legislative reforms and judicial activism may not be successful in preventing such custodial atrocities unless the systematic reform by this fourth pillar of democracy.
 
 The researcher attempts to explore and elucidate the issue of Custodial violence that has been gradually increasing in the recent years and how it subsequently become threat to a democratic country. There is no doubt as to role of various public servants in safeguarding life , liberty , freedom of the citizens  but at times while exercising their discretionary powers they may cause damage to one’s reputation or eroding their creditability , media wields an enormous powers which can then subliminally affect a case to know the true  side of story .
 
This paper examines the implications of the media's roles in the India’s   open justice delivery system for its development. It shows how media highlights the prevalent notions in the society to expand the scope critical reporting, initiating trend to find the true picture of the arbitrary acts, and to influence decision making process. Further it also examines the possibility that the media might play a critical role which will then be hailed by civil society. The focus of this is not to engage in the debate over media bias but instead to draw attention to the important role that the media play in coverage of such issues.
 
The methodology of research is doctrinal and sources are secondary in nature. The basic source of information is publically available information on various legal databases, books, journals, articles, etc. For the legal sanctions, help of laws, case laws, reports and legislations are given due consideration.
 
Keywords: Custodial violence , Reporting of Media , Democracy , Politics .
SYNOPSIS
The laws which are made by the Legislative organ of the Government and its application are being done by the different organ which is Judiciary . It has been quite often observed that the
Media‘s interactive capacity and to uphold various concepts like participation , openness etc. but on the other hand it should not be biased in navigating their relationship with the public .In a democratic country such custodial violence which has been increasingly rapidly cannot br tolerated where the  transparent and accountability set up is utmost important .
 
The role of media in a democratic society has emerged as a alternate public sphere where through critical reporting various acts by public servants can be brought to the limelight and its contribution to the India’s   open justice delivery system for its development. It has been  very much clear that the Media plays an important role as to the influencing the public understanding of custodial atrocities by the public servants .
 
Aims and Objective:
·         To understand reporting of the Custodial atrocities by Media in a democratic society .
·         How much extent media intervene in court’s open Justice system and does that role can be appreciated .
·         Do Media really  have enormous powers which can then subliminally affect a case to know the true  side of story .
·         Can the changing dynamics of reporting can directly or indirectly put a check on the discretionary powers exercised by the few public servants .
 
Statement of Problem:
The debate on reporting of such custodial violence is incredibly complicated due to lack of systematic reform by legislative and judicial activism . Hence, the researcher will be dealing with the issue that how media highlights the prevalent notions in the society to expand the scope critical reporting, initiating trend to find the true picture of the arbitrary acts, and to influence decision making process.
 
 
Research question:
1.      Do media plays a vital role as to  in coverage of such issues of Custodial violence and to what extent it is essential in a democratic society ?
 
2.      To what extent media wields an enormous powers which can then subliminally affect a case to know the true side of story ?
 
3.      How Media play an important role to convey such issues and its impact on Government legislations and policies or in decision making process ?
 
Research methodology: The methodology used by the researches is Doctrinal and the sources of information include secondary texts like articles, books, journals.
 
INDEX
 
1.      Introduction
2.      A time for changing reporting culture
3.      Media role and public sphere
4.      Exploring Justice system and other acts
5.      Media: A watch dog of the functionaries of society
6.      Conclusion
7.      Biblography
 
 
 
INTRODUCTION
Charles Dickens  during the time of French Revolution once said that It was the best of times, it was the worst of times, it was the age of wisdom, it was the age of foolishness, it was the epoch of belief, it was the epoch of incredulity, it was the season of Light, it was the season of Darkness, it was the spring of hope, it was the winter of despair, we had everything before us, we were all going direct to Heaven, we were all going direct the other way.[1]
 
This statement is aptly used in the contemporary times . The media  is one of those the institutions which are supposed to instill hopes in the worst of times, wisdom in the age of foolishness, spread light in the season of darkness, and so on, as these are supposed to be imposed
 
Custodial torture is virtually a world-wide happening  imposed  upon individuals regardless of sex, age or state of health . This is regarded as one of the  worst form of human rights violation which  has been becoming a  serious  alarming issue  all over the world . Brutal atrocities perpetuated by the public servants or the  law enforcing agencies on the suspects  are menacingly on the increasingly day by day.
 
Media are the integral part of the political life and play an important role in the functioning of our democracy by shaping the public understanding . Mass Media is the and limited by the political, economic and social conditions in which they exist .
 
The media's crucial role in democracies is unquestionable. And for countries in economic and political transition, their checking value is considerably more important. Although India has made significant progress in many areas of economic reform, it has fallen far short of expectations in terms of political and social revolution. Because of the unique arrangement of the media inside India's political power structure, media personnel, particularly senior media editors and managers, adhere to political rather than professional journalistic rules. Their judgments have ramifications in terms of career advancement or demotion in the political hierarchy. Furthermore, the state controls practically every stage of news information collecting and delivery, from press cards ensuring who may conduct interviews to state ownership of news media selecting what can be published and broadcast to approval of online news services permitting what to be published.   This news information market monopoly further strengthens the ability and capability of the media coverage . However In a civil society no right to freedom, howsoever invaluable it might be, can be considered absolute, unlimited, or unqualified in all circumstances. The freedom of the media, like any other freedom recognized under the constitution has to be exercised within reasonable boundaries. Excessive publicity by media hinders the justice delivery by the courts and affects the suspects victims, accused and witnesses by invasion of their privacy rights.[2]
 
Within the closed institutions the public servants or the officials granted permissive discretionary powers, yet minimum mechanisms are in place to guarantee transparency .Media plays an important role in shaping  the opinion of the people  and it is capable of changing the whole viewpoint through which people perceive various events. Presently, the increasing competition between various news agencies/channels to gain ore viewership and TRPs have worsened the situation leading to a degraded quality of news followed by distortion of facts and unreasonable interference in the private life of individuals.[3] The media is critical in disseminating information to the general population. It has tremendous impact over the quality of discourse and the scope of manipulation, because of the signals and perceptions that arise form the  authorities  out of knowledge  and its ability to amplify specific narratives.
 
A time for changing reporting culture
Custodial violence is one of the most serious issues confronting our society, and it has been steadily increasing in recent years. This issue has been hogging the limelight and is the country's biggest threat. People who have been entrusted to serve the law have turned into tormentors themselves. Students of the mass media and popular culture agree on two basic social facts: Popular culture includes a relatively large amount of information and images pertaining to fear, including crime and violence, and audience members perceive social life as very dangerous. It is the relationship between these two "social facts" that remains unclear . [4]Moreover the culture's analogue technologies have aided the evolution of modern society.
 
For media content researchers, the question is whether people's daily experiences of such violence lead them to be more interested in and sensitive to cases of violence, including news stories, as well as providing a motivation for journalists to cover such crime.The fact is that it is well-nigh impossible for the reporter to remain detached, especially in cases of national interest or communal riots . The government has tried to curb the freedom of the press on the ground of maintaining peace, but the Supreme Court has held in number of cases that the government should curb riots, not the freedom of the press. However, now there is a colossal change in the approach with the advent of custodial violence . The media has always been an active contributor to moral panics. But it seems that in a new media environment that includes mobile phones, the internet and social networks there can be situations when the crime and punishment move from the courts to prisons to street. [5]
 
According to the law commission, there is a view that, as a result of the widespread use of television and cable services, the entire pattern of news dissemination has changed, and that several such publications are likely to have a prejudicial impact on suspects, accused, witnesses, and even judges, as well as on the administration of justice in general.[6]The rise of the technology and advancement  and related urban infrastructures  has also given rise to fraudulent activities, which have sparked much debate and discussion among young city dwellers, as well as media coverage and feature film productions, linking imaginings of success to covert practises.
 
The detrimental impact of press freedom on public press relative trust is both good and bad news for democratic growth. On the one hand, citizens recognising the biases of more authoritarian-dominated public media, which is largely controlled by the state, is encouraging. Citizens' trust in the public media in more democratic but still fragile regimes, but at the other hand, is concerning in this new era of democratic collapse. Citizens may not be attentive to initial changes caused by media bias, and hence may not respond quickly enough to government attempts to limit democratic venues and curtail media freedom. Our key finding is that more press freedom has a large negative estimated influence on the wide cast gap: the less free the media in a country is, the higher the levels of relative faith in the media are.[7]
 
The legislative, executive, and judiciary are the three foundations of democracy, but the press is the fourth estate. It is an institution that has enormous power and influence, and as a result, it must be held accountable. In a Kirati piece published in 1927, Bhagat Singh bemoaned the loss in the quality of journalism. He expressed himself as follows: "Journalism, which was formerly held in high regard, has now devolved into a filthy profession. These individuals incite people's emotions by using bold headlines to pit them against one another, causing them to fight. Riots erupted in multiple locations, not just one or two, as a result of provocative pieces published in local media."  The crucial question is why is the credibility of the media being questioned? Is it due of the manner in which facts are presented? It is commonly stated that reporting must be truthful and objective, but the question is whether this is true and if not then is that a myth .
 
This media has been used by many journalists as a means of gaining power. The most essential issue is the ownership pattern. How can an industrialist separate her/his commercial interests if she/he owns a media house and operates multiple industries? One of the commercial ventures is the media house. One thing is clear: raising money for the sake of operating a newspaper or television station appears to be appropriate, but raising money for the sake of running a newspaper or television station is wrong and vile. The Indira Gandhi government made an attempt in 1971 when the 'Diffusion of Ownership and Delinking from Big Business Bill' was tabled in Parliament. One of its stipulations was to separate the media house from the rest of the company. However, due to the pressures of the business world, it was unable to see the light of day. The widespread media coverage as well as other technical advancements have made the information ubiquitous but disinformation and misinformation are also in circulation in equal means.[8]
 
Media role and public sphere
The media plays a critical role in communicating such concerns and their impact on government legislation and policies, as well as in the decision-making process. The media, in particular, play a crucial role in blurring the lines between the private and public realms. For example, addresses how electronic media have eroded conventional barriers between private and public, such as the uniformity of experience or the fact that access to information is no longer based on physical location.
 
As a result, there is an urgent need to address a number of unanswered questions about how the media can assist audiences in blurring the lines between public and private life. Does connectiveness in the private domain, for example, turn it into a public domain? For the articulation of public concerns, which types of actors do civilizations normally rely? Do different types of issues evoke participation from different types of actors? These kind of questions suggest that connectiveness should be investigated as a crossroads of several levels of traditionally defined public and private activities. On one level, television viewers observe, watch, and witness. On the other hand, they may engage in physical interaction with others. On the other hand, they might focus on bigger, well before implications for what they're perceiving. On each level, it's possible that the activity they do while watching "connects" them with others.
 
Media events typically provide a focused setting for television viewing that bears considerable potential for connectiveness. Media events thereby allow audiences the choice of framing a number of occasions in ways that make the use of focused viewing behavior not only an appropriate but a preferred way of connecting with others. Connectiveness is also potentially significant to many media events because they often function as rites of passage. Members of societies use media events to enter into negotiation with themselves or others about their values, beliefs, and priorities .[9]
 
Television was presented as a centralised endeavour that exemplified and praised India's technological accomplishments; it was also a potent weapon for central authority to sway public opinion, despite being removed from a larger political conversation about cultural hegemony, independence, and democracy. From the several  decades that followed, India's government had the monopoly on electronic media broadcasts, resulting in a state-controlled media culture in the still-developing democracy .
 
The researcher also explored that Media events also foster, directs and focused conduct of individuals  that encourages them to connect with one another or to various institutions. Because media events are planned around specified programming, they provide audiences with watching scenarios that have a defined beginning and finish, allowing them to engage in activities that are outside of their normal routine. Civil rights lawyers, non-governmental organisations, and former government offcials working in this field argue that not all fatalities in judicial custody or at the time of inquiry are caused by torture or beatings, and that some can be related to illnesses or medical malpractice. Those in police custody, on the other hand, are frequently the victims of violence.
 
The dominance of mainstream players in media governance, reinforced by concerns about grassroots enterprises' long-term viability, results in legislation that restricts community media access and participation. Civil-rights activists and social movements have risen in size and prominence, resulting in new civic engagements and citizen involvement patterns that are driving bigger discussions on media and democracy. Since then, the debates have shifted from a call for freedom of expression to media reform, media justice, a desire for a more democratic media landscape, and the establishment of alternative grassroots communication networks. The reliance of democracies on communication for collective decision-making has been a hot topic of discussion.
 
The fact that large media corporations are rapidly shifting away from the original public-service paradigm of journalism, which was committed to providing not only entertainment but also information and education, has become a rising source of concern. Today's platter includes a multi-cuisine combination of entertainment, sensationalism, sex, and violence, in other words, pretty much everything that sells. In global newsrooms that have centralised production in the world's largest cities, the space for development reporting, in-depth investigative journalism, and a push for social transformation is steadily narrowing.
 
The concept of a 'public sphere', developed in its most advanced form by Jufrgen Habermas, unambiguously placed 'undistorted communication' at the centre of the schema: By 'the public sphere' we mean first of all a realm of our social life in which something approaching public opinion can be formed. Access is guaranteed to all citizens. A portion of the public sphere comes into being in every conversation in which private individuals assemble to form a public body. They then behave neither like business or professional people transacting private affairs, nor like members of a constitutional order subject to the legal constraints of a state bureaucracy. Citizens behave as a public body when they confer in an unrestricted fashion - that is, with the guarantee of the freedom of assembly and association and freedom to access and publish their opinions - about matters of general interest.This type of communication in a broad public body necessitates specific techniques of distributing information and affecting individuals who hear it. The public sphere's media nowadays are newspapers, periodicals, radio, and television.[10] By this he simply means that the public sphere is a specific sphere which 'mediates between society and state' and there can be no public sphere without a public .Also he tried to explain the relationship between these public sphere and the custodial atrocities which are increasing but at times while exercising their discretionary powers they may cause damage to one’s reputation or eroding their creditability.
 
Exploring Justice system and other Executive’s Acts
The media should not usurp the judiciary's functions or deviate from objective and unbiased reporting. Judges start considering media criticism when making decisions if they go against the media's point of view, which is why in most high-profile cases, the judgement passed by the media becomes the final verdict in trial courts.[11] It is necessary to strike a balance between press freedom and the right of a victim to a fair trial in the event of a crime. As a result, the media holds great power that can subtly influence a case. The issue is not with the media uncovering societal wrongdoings. The issue occurs when they exceed the permissions granted to them and do things that they should not be doing.
 
In case of excessive media coverage of a suspect or accused before a trial hampers a fair trial or portrays him as a person who committed the crime, it may result in disproportionate interference with the administration of justice ,necessitating contempt of court actions against the media. But on contrary to this they only can find the true side of the stories so that they can protect the rights of the common man .However , regulating journalistic behavior is insufficient, unfortunately, to prevent the infringement of civil rights. Apart from civil society, the judiciary and the media are the best tools for checking power. The roles of these two institutions are complimentary, but they have strangely become hostile. Both are essential to safeguard the common man from both governmental and individual strength, and to act without fear or favour.
 
The media covers and presents the case to the public in such a way that if a judge issues an order that contradicts the media verdict, he or she may be perceived as corrupt or biassed by many. As a result, judges begin to consider media criticism when making decisions. This is why, in most high-profile cases, the media verdict becomes the final verdict in trial courts.
It is now time to turn our attention to the role of the judiciary.There's no need in repeating the fact that our courts have stepped in on several instances when the administration and Parliament have trampled on people's rights, and the damage would have been irrevocable if it hadn't been for them. However, it is also true that it has left citizens to fend for themselves on countless instances. In truth, the innocent and trusting citizens of this country have never found a soul mate in this great institution, the judiciary. The absence of everything indigenous—the language, the clothing, and the manner of addressing justices of the higher judiciary—is one of the most noticeable aspects of it. The media sensation has a significant impact on the trial. The trial by media, also known as the media trial, has a negative impact on and obstructs a free and fair trial for the purpose of delivering justice. In many circumstances, the media goes beyond its freedom of speech and expression by broadcasting and publishing materials that are detrimental to the parties' interests, such as the parties' character, pictures, witness criticism, and so on. A media trial could be harmful to the parties' case or sway the court's decision since, to be honest, no one wants to be judged by the media.
In  a case of Printers (Mysore) Ltd v. Asstt. Commercial Tax Officer [12], the Supreme Court has reiterated that though freedom of the press is not expressly guaranteed as a fundamental right, it is implicit in the freedom of speech and expression.The Supreme Court in the case of Rattiaram v. State of Madhya Pradesh [13], observed that the fair trial is the heart of criminal jurisprudence. A fair trial is a fundamental right guaranteed by Article 21 of the Indian Constitution. Hence, human rights are violated when a fair trial is denied. Also, the court in Mohd Hussain Ali v.The State (Govt. Of NCT)[14] , stated that In the spirit of the right to life and personal liberty, everyone has the right to a fair trial by a competent court. As a result, because the right to a fair trial is a basic right, it cannot be denied to anybody under the Constitution. The decision was highly applauded by civic society. True, Parliament refused to acknowledge the problem and did not pass legislation to address it, so the court's action has attracted praise and public support, endowing legitimacy to its overreaching.
 
 The court has expressed concern about the political interference in administrative functioning. We notice that much of the deterioration of the standards of probity and accountability with the civil servants is due to the political influence or persons purporting to represent those who are in authority. Santhanam Committee on Prevention of Corruption, 1962 has recommended that there should be a system of keeping some sort of records in such situations. Rule 3(3) (iii) of the All India Service (Conduct) Rules, 1968 specifically requires that all orders from superior officers shall ordinarily be in writing. Where in exceptional circumstances, action has to be taken on the basis of oral directions, it is mandatory for the officer superior to confirm the same in writing. The civil servant, in turn, who has received such information, is required to seek confirmation of the directions in writing as early as possible and it is the duty of the officer superior to confirm the direction in writing [15]The Supreme Court's decision raises various questions, including whether political masters are exclusively accountable for the body politic's worsening health, and if the Supreme Court has the authority to issue such directives. Transfers and postings have undeniably become a lucrative industry for politicians. By making the appropriate connections, even journalists have made fortunes in this field. Transfers are frequently utilised as both incentives and punishments, and upright officials are frequently reprimanded while those skilled at blandishment are rewarded.
 
Although the importance of the media cannot be overstated because it keeps the public informed, educated, and vigilant, and also at times when required act as a watchdog on government functionaries and abuses by making them available to the public through various mediums such as television, radio, newspaper etc. however, media houses, acting as ‘public court’,  are beginning to interfere with court proceedings, completely overlooking the significant  gap between an accused or suspected and a normal citizen.
 
Media: A Watch dog
It's difficult to imagine a strong democracy without putting communication at the centre. The fight for 'communication rights,' its activism, and attempts to curtail it are not only indicators of how important free media has become in modern life, but also a yardstick by which social scientists can assess the efficiency of a nation-commitment state's to democracy and its future. The media's power in a democracy stems from its role as society's 'watchdog,' or 'fourth estate,' supporting the other three pillars of democracy - the administration, legislature, and judiciary - by providing the necessary checks and balances on problems that affect the general public. Alternatively, it serves as a venue of contestation, where citizens can openly voice their opinions on major policy issues in the 'public domain' without fear of official pressure or control.
 
The researcher attempts to explore that the two aspects stand out of democracy : First, the maturing of mass democracy in most societies has coincided with developments in mass communication as a crucial role in the organisation of public life and opinion formation on matters that affect the 'citizenry.' Second, democracy can be defined as a political system in which state institutions and civil society are two players, even if they are at opposite ends of the spectrum, opposing each other yet linked in the daily power struggles. For our purposes, these power talks represent a battle between the state's media control and citizens social access to media, with the goal of moving the balance of power from the core to the periphery, or at the very least bridging the gap between the two. In the end, it comes down to a battle for legitimacy.
 
A growing concern has been how powerful media conglomerates are increasingly moving away from the initial public-service model of journalism that was committed to providing not just entertainment but information and education. What is put on the platter today is a multi-cuisine mix of entertainment, sensationalism, sex, and violence, in short just about anything that sells. The news media are in crisis across the developed world. Journalism as we know
 ?it is being described, obviously with some exaggeration, as 'collapsing','disintegrating', in 'meltdown'. In this digital age, there is gloom in most developed
 country, or 'mature', media markets over the future of newspapers and also
 broadcast television.[16] The press and media monopoly has grown significantly in industrialised countries, weakening diversity, pluralism, and the values of serious journalism. Monopolistic tendencies and aggressive business practises aiming at increasing market share and eliminating competition have also been seen in the Indian press. A duopoly or monopoly has arisen in various Indian newspaper markets.
 
The fact is that bureaucrats in the country are corrupt and are  self-seekers with a few happy exceptions. Rajiv Gandhi described the nature of bureaucracy with these word as : We have government servants who do not serve but oppress the poor and the helpless, who do not uphold the law but connive with those who cheat the state and the whole legions whose only concern is their private welfare at the cost of society. They have no work ethic, no feeling for the public cause, no involvement in the future of the nation, no comprehension of national goals, no commitment to the values of modern India. They have only a grasping mercenary outlook, devoid of competence, integrity and commitment.[17] The justification for media is also backed by the fact that in a democracy, having a transparent and accountable system is critical. The media, through campaign journalism, gives the public a platform to express their opinions and so ensures their participation.
 
To that extent, Public Service Broadcasting (PSB) as a model that emanated from a focus on public good has been able to include a sizeable amount of public-interest programming without having to chase the advertising pie. But the system has had its own set of shortcomings that have prevented it from attaining its ideals and virtually crippled it from within, forcing many media reformers to look for answers beyond the media giants and PSB. The otherwise good model of PSB has been plagued by issues of governance and modes of financing the system[18].
 
Conclusion
The mass media effect on public life ethics, as shown by the press's position as a watchdog in scrutinising the behaviour of government officials, is thought to be critical to democracy. The relationship between the media and the public officials and the policy maker is useful and informative. The media also plays an important role in exposing government corruption and in bringing the government's inactivity to light on numerous occasions, resulting in action being taken. Instead of fabricating tales to sensationalise issues, the media should assist those who own them in learning the truth.
 
Researcher wanted to shed light on media trends but focuses more on the increasing unethical or the arbitrary acts by these public officials will not be acceptable .It is time every one should realise that the issue of human rights is no longer an issue which can be left to government alone to deal with but Media can also play and vital role as to the in the case of custodial violence or deaths for those who do not speak against the custodial authorities for the fear of reprisals.
 
The media's growing importance in today's globalised and tech-savvy world was rightly put in the words of Justice Learned Hand of the United States Supreme Court when he said, “The hand that rules the press, the radio, the screen and the far spread magazine, rules the country”[19]. Every institution is vulnerable to misuse, and every liberty, if left unchecked, has the potential to devolve into a licence for chaos and anarchy. This is the point at which we are securely planted today. The specification of 'standards of performance' needs revision and updating. But there can be little doubt that over the long term the conception of socially responsible news media has been influential and has come to stay [20]. In India, rising levels of criminalization are frightening individuals and advocates alike. Experts believe that laws prohibiting custodial voilence are routinely broken, and that many officials regard violence as a valid technique.
 
 
Media, being the fourth estate of government, impacts the quality of democracy in any state and asserts its role by strengthening and intensifying the quality of democracy. The Indian judiciary, in order to uphold the great values enshrined in the Constitution, acts by stepping in when the Parliament and the executive ride roughshod over citizensThe justification for media is also backed by the fact that in a democracy, having a transparent and accountable system is critical. The media, through campaign journalism, gives the public a platform to express their opinions and so ensures their participation. Journalism is going through a major transformation, influencing "virtually every area of news production, reporting, and reception."
        

[1] Charles Dickens, A Tale of Two Cities (Penguin Classics, UK, 2003).
[2] Indian Journal of Law and Human Behavior Volume 5 Number 2 (Special Issue), May - August 2019 DOI: http://dx.doi.org/10.21088/ijlhb.2454.7107.5219.8
[3] Mohd. Aqib, Utkarsh Dwivedi. Judiciary and Media Trial: A Need for Balance. Indian J Law Hum Behav. 2019;5(2):155–161.
[4] In The Communication Environment The mass media and popular culture influence social life in different ways. Much of the media research has focused on media content (cf. Comstock 1980).
 
[5] Sudhanshu Ranjan , Media And Judiciary: Revitalization Of Democracy, Journal of the Indian Law Institute , July-September 2015, Vol. 57, No. 3 (JulySeptember 2015), pp. 415-436 .
 
[6] Law Commission of India, 200th Report on Trial by Media: Free Speech versus Fair Trial Under Criminal Procedure Code, 1973
 
[7] Devra C. Moehler and Naunihal Singh, Whose News Do You Trust? Explaining Trust in Private versus Public Media in Africa, Political Research Quarterly , JUNE 2011, Vol. 64, No. 2 (JUNE 2011), pp. 276- 292.
[8] Sudhanshu Ranjan, MEDIA AND JUDICIARY: REVITALIZATION OF DEMOCRACY, Journal of the Indian Law Institute , July-September 2015, Vol. 57, No. 3 (JulySeptember 2015), pp. 415-436 .
[9] Barbie Zelizer, From Home To Public Forum: Media Events And The Public Sphere , Journal of Film and Video , Spring and Summer 1991, Vol. 43, No. 1/2, Audiences (Spring and Summer 1991), pp. 69-79.
 
[10] Habermas, Jurgen (1996) 'Civil society and the political public sphere', in Jurgen Habermas (translated by William Rehg) Between Facts and Norms: Contributions to a Discourse Theory of Law and Democ racy, Cambridge, MA: MIT Press.
 
[11] Indian Journal of Law and Human Behavior Volume 5 Number 2 (Special Issue), May - August 2019 DOI: http://dx.doi.org/10.21088/ijlhb.2454.7107.5219.
[12] 1994 SCC (2) 434.
[13] AIR 2012 SC 1485.
[14] Mohd. Hussain @ Julfikar Ali v. The State (Govt. Of Nct),Criminal Appeal No. 1091 of 2006.
[15] Government of India, Report on Civil Service Reforms (2004), available at. http:// www.performance.gov.in/ sites/ default/ files/ document/CivilServiceReforms2004.pdf (last visited on Aug.10 , 2015)at 278.
[16] N. Ram, Sectional President's Address: The changing role of the news media in contemporary india, Proceedings Of The Indian History Congress , 2011, Vol. 72, Part-II (2011), Pp. 1289-1310.
[17] Quoted in N.C. Saxena, Administrative Reforms for Retter Governance 13 (National Social Watch, Daanish Books, Delhi, 2012).
[18] Saima Saeed , Negotiating Power: Community Media, Democracy, and the Public Sphere, Development in Practice , Jun., 2009, Vol. 19, No. 4/5 (Jun., 2009), pp. 466-478 .
 
 
[19] Right to Privacy in Sting Operations of Media. http://odisha.gov.in/e-magazine/ Orissareview/2013/may/engpdf/57-61.pdf .
[20] N. Ram, Sectional President's Address: THE CHANGING ROLE OF THE NEWS MEDIA IN CONTEMPORARY INDIA, Proceedings of the Indian History Congress , 2011, Vol. 72, PART-II (2011), pp. 1289-1310.