Open Access Research Article
“TRIAL BY MEDIA AND ADMINISTRATION OF JUSTICE” AUTHORED
Published Paper
Article Details
AUTHORED BY-
JAYA THAPA
(Asst.
Professor, GNDU, RC, Jalandhar)
I.
INTRODUCTION
Technically speaking,
democracy is the rule of the people; it is a structure supported by the
judiciary, the executive branch, and the legislative. However, given the
media's expansion and ability to reach every part of the nation, it can also be
said that it is the fourth pillar of a democracy. To address the injustices in
our system, it performs a crucial role as a mindful keeper and watchdog of the
social functionaries. By making these injustices known to everyone, it hopes
that they will be corrected. This constantly growing readership and viewership,
when combined with the usage of contemporary technology, has given media
outlets an unmatched role in influencing public opinion. It is impossible to
sufficiently emphasize the need to recognize the media's professionalism and
responsibility in reporting given its expanded position and relevance.
The media is crucial in
forming societal opinion and has the power to alter the whole lens through
which individuals view different events. The current situation is aggravated by
the growing rivalry between news organizations and channels for viewers and
TRPs, which has resulted in a decline in newsworthiness, factual distortions,
and inappropriate intrusions into people's private lives. The current situation
demonstrates that the media has started meddling in judicial procedures and has
changed into a "public court".
II.
MEDIA TRIAL
In simple terms,
"trial by media" refers to the influence of considerable media
coverage on a person's reputation or the impact of the media on a trial
procedure, typically in criminal cases. The development of technology and the
severe rivalry among cable networks for breaking news results in the accusation
of a person even before an inquiry is conducted, which compromises the
administration of justice and jeopardises their right to a fair trial. [1]
A trial is a procedure
that checks how justice is being administered. It is nothing more than judicial
transparency, and the media is crucial in making court proceedings public to
the general public. In a community, judicial independence is essential, yet
there have been many occasions when it has been upheld and the media has
interfered with the judiciary. [2]
When guilt is proven
according to the law's due process rather than by introducing extraneous
elements or interfering with the process, the effectiveness of the legal system
is increased. The Rule of Law, which the Constitution has established for
everyone, is what makes a society strong. When free speech is not suppressed,
despotism is resisted. The legal system has safeguarded press freedom in its
rulings and allowed for fair criticism of the court system, scrutiny of judge
administration, fair reporting of things, and consideration of the case's
merits. Abuse of freedom is the only limitation provided since complete freedom
corrupts.[3]
The delivery of justice
and a fair trial in such a case are further hampered by the trial by media of a
sub-judice subject in a court of law. Arushi's murder, Jessica Lal's murder,
the Hansal Mehta case, the Sushant Singh Rajput case, the Nirbhaya rape case,
etc are some of the very famous examples of media trial. Even though each of
these incidents relates to a different industry, they are all driven by the
media. This brings us full circle to the first query: to what extent may
interference be passed off as the activity of a healthy regulator and to what
extent does it begin to interfere with the court's process? However, it must be
recognised that the media also contributes positively to exposing government exchequer
wrongdoing and bringing attention to the government's repeated inactivity until
action is finally done. Conflicts do, however, develop when the media oversteps
its bounds, attempts to usurp the authority of the judiciary, and passes
judgement on ongoing legal proceedings.[4]
III.
FAIR TRIAL
Though the idea of a fair
trial is difficult to describe, its characteristics are laid out clearly. The
cornerstone of criminal law is a fair trial, which is founded on adversarial
procedures. The notion of a fair trial may be seen in many laws and procedures,
and it is acknowledged in Article 21 of the Indian Constitution since it states
that fairness must be observed in order to follow the administration of
justice. It serves as the main guideline for the criminal justice system.[5]
In Maneka Gandhi v.
Union of India[6], the
Supreme Court ruled that the right to equality rests on the right to a fair
trial, which ensures that there is no prejudice against the accused or
witnesses over the course of the legal proceedings. If everyone has equal
access to the legal system and the courts, discrimination is not permitted at
any point throughout the legal process. Article 21 is based on Article 14, and
any action that is arbitrary or irrational violates Article 21. Therefore, the
right to equality before the law is a basic right; it forbids states from
acting in a discriminatory manner and requires that the legal process be just,
fair, and reasonable.
According to articles 14,
20, 21, and 22 of the Constitution, every person living within the boundaries
of India has a fundamental right to a fair trial. It goes without saying that
the right to a fair trial, which derives from Article 21 of the constitution
when read in conjunction with Article 14, is more crucial. A "reasonable
restriction" has been placed on the freedom of speech and expression
guaranteed by Article 19(1)(a), pursuant to Article 19(2) and Section 2(c) of
the Contempt of Court Act. In compared to one's right to free speech and
expression, one's right to live in dignity is always given precedence. The media
should think on these things as well. The public's trust in the judicial system
is essential, therefore a fair trial is not simply for the benefit of the
accused. The core of the Indian criminal justice system is the right to a fair
trial. Other rights covered by it include the right to a speedy trial, the
right to legal representation, the right to a public trial, the right to be
present during the trial and question witnesses, the right to be presumed
innocent until proven guilty, the right to not be forced to testify against
oneself, and more.[7]
IV.
FREEDOM OF SPEECH AND EXPRESSION AND
FAIR TRIAL
According to
Article 19(1)(a), "all citizens shall have the right to freedom of speech
and expression." The "public opinion" that is formed about
"economic, political, and social matters" is crucially influenced by
this freedom. This freedom includes discussions on issues of public importance
as well as the "distribution of information," "freedom of
propagation and exchange of ideas," which aid in the creation of one's
perspective and point of view. This freedom also extends to the right to
communicate one's ideas and thoughts on any subject using any kind of media, including "word of mouth,"
"writing," "pictures," "printing," and
"movies," among others. [8]
Justice Bhagwati emphasized the significance of
"freedom of speech and expression" in Maneka Gandhi v. Union of
India[9].
The importance of
preserving "freedom of the press" in a democratic society has been
emphasised by the Apex Court in a number of instances. Press releases often
serve the "public interest" by informing readers of any information
and viewpoints that are necessary for them to form sound judgements. Numerous
news stories and articles are routinely published in the press that expose the
government's flaws. Consequently, the government occasionally seeks to curtail
"freedom of the press." ?Therefore, it is the courts' principal
responsibility to defend the aforementioned freedom and to nullify any legislation
or administrative decisions that conflict with the right to freedom of the
press in violation of the constitution.[10]
In Printers (Mysore) Ltd. v. Assistant Commercial Tax Officer[11],
The Supreme Court reiterated that although "freedom of the press" is
implied from "freedom of speech and expression," there is no clear
clause safeguarding it as a "fundamental right." The "freedom of
the press" is prized in every democratic nation, and the press is
correctly referred to as the "fourth estate" in society.
Any law prohibiting the entry or
circulation of a magazine inside a State is invalid. The petitioner in Romesh
Thappar v. State of Madras[12]
was the "editor," "printer," and "publisher" of a
publication called "Cross Road." However, the Madras government forbade
this newspaper from entering or circulating in Madras by using some of its
powers under the "Maintenance of Public Order Act, 1949". The Court
ruled that the "freedom of propagation of ideas" is guaranteed by the
"freedom of circulation" and is contained in Article 19 (1) (a) of
the Indian Constitution. The Court ruled that it is unconstitutional for a
State to have a statute prohibiting a publication from entering or circulating
there.
Only when "freedom of speech and
expression" is covered by authorised restrictions as defined by Article 19
(2) of the Indian Constitution may "restrictions" be put in place.
Press freedom
in India is generally seen as untouchable until there is a justifiable and
moderate limit placed on it. In a democratic nation, the freedom of the press
must be protected and maintained, but there must also be some reasonable
constraints placed on that freedom. These limitations cannot be arbitrary, and
they may only be enacted for the reasons listed in Article 19(2) of the
Constitution, which are the justifications for restricting "freedom of
speech and expression."[13]
V.
THE REPERCUSSIONS OF A
TRIAL BY
THE MEDIA
The judiciary
will be affected by the media trial if erroneous news stories published by the
media influence judges' decisions, interfere with the administration of
justice, and threaten the independence of the judiciary. The following famous
cases, which had an impact on the judiciary both positively and negatively,
show how media trials affected India.[14]
The Supreme Court looked into the crucial issues surrounding trial by
media in R.K. Anand v. Delhi High Court[15].
The case resulted from an undercover investigation by the private television
network NDTV into the unholy alliance between the prosecution, its witness, and
the defence in the infamous BMW hit-and-run case that claimed the lives of six
people when a speeding BMW was driven by the scion of a powerful and wealthy
family. The Delhi High
Court then started the Suo-Moto contempt proceedings and found the special public
prosecutor and the defence attorney guilty of contempt of court and barred them
from testifying in the case. The trial was still ongoing even eight years after
the incident when NDTV aired a sting operation to reveal how a senior attorney
representing the accused was negotiating to sell out in favour of defence. The
Supreme Court was then given the appeal, in which it was argued that NDTV had
engaged in trial by media and could only have broadcast the stings with the
authorization of the High Court. The Supreme Court of India disagreed, stating
that while such a course would not be a journalistic exercise, it would instead
include the media serving as a special vigilance agency for the court.
In the
Jessica Lal Case, popularly known as the Jessica Lal Murder Case, Manu
Sharma v. State of Delhi[16].
The case started with the 1999 cold-blooded murder of a young woman. The woman
worked as a barmaid at a prestigious Delhi restaurant. Manu Sharma, the key
suspect, was the son of a prominent politician. In 2006, the Delhi trial court
cleared all nine defendants in the case. There was a great deal of public
outrage at the acquittal, and the media went on the attack about how the
accused's political ties were used to manipulate the trial, how the witness
became hostile, and how poorly the prosecution handled the case. The public's
responses to the ludicrous injustice were afterwards covered by the media. As a
consequence, the Delhi High Court ordered a suo moto reinvestigation of the
case before waiting for the state's appeal against the accused's acquittal. The
retrial, which was held mostly as a result of pressure from the media, resulted
in the conviction of those who had previously been found not guilty.
The murder of
a 14-year-old schoolgirl in her house was the subject of Nupur Talwar v.
Central Bureau of Investigation[17]
(Arushi Talwar Case), which brought
tabloid journalism to a new low. In their scurrilous coverage of the inquiry,
the media showed a reckless disregard for the law. The case brought up
significant legal issues that call for resolution aside from media trial,
privacy invasion, confidentiality breach, and defamation of both living and
deceased individuals. The media pryed into Aarushi and her parents' private
life, publishing her private letters and painting her father as a murderer in the
process. Before the
crime had been proven in court, the victim's parents were falsely accused of
killing their daughter. The victim's parents received a life sentence due to
the media's interference, which influenced the judges' verdicts. The victim's
parents appealed the conviction, and after the Allahabad High Court heard their
appeal, the court cleared the parents of Arushi Talwar of all charges,
concluding that the CBI had failed to establish their guilt beyond a reasonable
doubt. By accusing the victim's parents of murder before the court's decision,
the media influenced the outcome of the Arushi Talwar case.
The Supreme
Court of India convened a constitution bench of five judges in Sahara India
Real Estate Corporation Ltd. v. SEBI[18], also known as the media
guidelines case, in 2012 to discuss whether guidelines should be framed by the
court in regard to the media reporting of ongoing cases or reporting of cases
that are pending before the court. In this case, there was an unauthorised leak
of privileged communication by a private television channel. While recognising the media's right
to cover court proceedings and the presumption of open justice, the Supreme
Court of India held that there may be some exceptional situations where media
coverage could negatively affect the administration of justice. In these
situations, media coverage may be delayed for a short period of time by the
Supreme Court or the High Courts. Such an order of postponement must pass the
tests of necessity and proportionality.
In a number of
high-profile cases involving wealthy and powerful individuals, such as the
Jessica Lal murder, in which a young woman who was serving drinks in a
restaurant was shot to death because she refused to serve drinks to the son of
a wealthy and powerful politician, The case of Nitish Katara, in which a young
man who was in love and dated the daughter of a powerful politician was
kidnapped and killed; the priyadarshini matto case, in which a young law
student was raped and killed because she turned down the advances of the son of
a powerful police officer. In these cases, the media played a significant part
in ensuring that justice was done and ensuring that the families of the victims
received justice through relentless campaigning for justice, publicising faulty
investigations, and exposing the connection between defence and prosecution.
What might have been a hopeless battle for the relatives of the victims was
turned into a national demand for a fair trial thanks to the media's
mobilisation of public opinion.
VI.
MAJOR INFLUENCE
a.
Influence of Media on Accused: There
may be substantial prejudice against the accused if the media portrays a
suspect or an accused as if he has already been found guilty before the trial
in court. Even if the accused individual is ultimately found not guilty
following a fair trial, this may not enable him to restore his damaged
reputation in society. Excessive media coverage portraying him as someone who
actually committed the crime amounts to an improper interference with the administration
of justice and should be grounds for legal action against the media for
contempt of court. [19]
b.
Influence of Media on Witness: If the
names of the witnesses are made public, there is the possibility that the
police and the accused or his associates would put pressure on the witnesses.
The witnesses initially wanted to back down and leave the situation. Then,
witness protection suffers a severe loss. This raises the issue of whether
hostile witness testimony is admissible as evidence and whether the law should
be changed to forbid witnesses from revising their testimony.[20]
c.
Influence of Media on Judges and Court: Judges
are not exempt from criticism on either their professional conduct as judges or
their personal conduct. However, it is cause for concern when critiques of them
are unfounded or completely unfounded and may tend to erode public trust in
judicial institutions. A judge must protect himself from these pressures.
Judges or juries may be indirectly influenced by a media article, regardless of
whether judges are cognizant of this impact or not. According to the Supreme
Court, a media- or public-driven trial is the exact opposite of the rule of law
and can result in a miscarriage of justice.[21]
VII.
REGULATIONS AND
GUIDELINES
In the case of Sahara India Real Estate Corporation Ltd. and Ors. v.
SEBI[22], the Hon'ble Supreme Court of India appointed a five-judge Constitution
Bench while the appeal was pending. Despite the Court's temporary injunction,
some outlets reported the judgment's proceedings. The Court established proper
guidelines for media reporting on matters that are under consideration in
Court, including the public disclosure of documents related to Court
proceedings and the manner and scope of publicity to be given by media to
pleadings filed in proceedings in Court that are ongoing and have not yet been
decided upon. The Court also recommended the measures listed below:- [23]
1.
Prior restraint: Our judicial
system's cornerstone is Open Justice. It fosters confidence in the legal and
judicial systems. The ability to access open justice is not unrestricted,
though. Under the inherent powers of the court, such decrees banning publication
for a brief period during a trial are admissible whenever the court is
convinced that the interest of justice thus requires.[24]
2.
Contempt of Court Act, 1971: Even yet
there is occasionally a significant risk of prejudice from fair and accurate
trial coverage, not in the current trial but in a subsequent or related trial.
Only if it can be proven on the facts of a specific case that the inaccurate
reporting of court proceedings amounts to a significant interference with the
administration of justice will it be considered contempt. Section 4 was created
to offer a privilege to the author of the publication as long as it is truthful
and accurate.[25]
3.
Order of Postponement of publication: The
First Amendment in the US guarantees an unrestricted right to free speech,
however the Indian Constitution does not due to the Heads of Restrictions under
Article 19(2) and the fact that such a right is subject to reasonableness
testing. These include strategies like ordering retrials, switching the court's
location, ordering acquittals even at the appellate level, etc. The courts have
developed orders of postponement of publications/publicity in appropriate
cases, as indicated above, keeping in mind the timing (the stage at which it
should be ordered), its duration, and the right of appeal to challenge such
orders. These orders were developed as a preventive measure by the courts to
protect the press from being prosecuted for contempt and also to prevent
administration of justice from being prejudiced.[26]
4. Right
to approach the High Court/ Supreme Court
In light of the law
enunciated above, anyone, whether an accused or an aggrieved person, who
genuinely believes that the content of the publication and its effect
constitutes an infringement of his/her rights under Article 21 to a fair trial
and all that it entails, would be entitled to approach an appropriate Writ
Court and seek an order postponing the offending publication/broadcast or
postponement of reporting of certain phases of the trial (including of the
victim or the witness or the complainant). The Court may grant such preventive
relief after weighing the right to a fair trial against other rights protected
by Article 19(1)(a), keeping in mind the aforementioned principles of necessity
and proportionality, and keeping in mind that such orders of postponement
should be for a brief period of time and should only be used in situations
where there is a real and substantial risk of impairing the proper
administration of justice or the fairness of the trial.
The principle of a fair
trial now informs and animates many areas of the law, according to the Hon.
Supreme Court's ruling in the case of Zahira Habibullah Sheikh & Anr vs.
State of Gujarat[27].
It is reflected in many laws and customs.A fair trial would undoubtedly entail
a trial before an impartial judge, a fair prosecutor, and a calm courtroom
environment. A fair trial is one in which there is no bias or prejudice for or
against the defendant, the witnesses, or the issue under trial.
VIII.
IS MEDIA TRIAL A
CONTEMPT OF COURT?
Trial by
Media is an act of contempt of court that requires punishment. The Contempt of
Court Act distinguishes between civil and criminal forms of contempt. The three
categories of criminal contempt are scandalising, prejudicing trials, and
impeding the administration of justice.
Prejudice
or interference with the judicial process: This clause was inspired by the
natural justice principle that "every accused person has a right to a fair
trial" and "Justice may not only be done but must also seem to be done."
There are many different ways that attempts are made to sway a trial. If these
cases are allowed to proceed, the people involved will be found guilty of
crimes they did not commit. To stop such biased and unfair trials, contempt of
court was established. No publication intended to taint the minds of the jury,
intimidate witnesses or parties, or foster an environment where the
administration of justice would be challenging or impossible does not
constitute contempt. Only when a case is capable of being tried by a judge can
comments on open cases or party abuse be considered contempt. No editor has the
authority to act in the capacity of an investigator in an effort to sway the
jury against anyone.
In the case
of Y.V. Hanumantha Rao v. K.R. Pattabhiram and Anr[28].,
Chief Justice Gopal Rao Ekkbote of the Andhra Pradesh High Court stated the law
regarding interference with the due course of justice well, stating that: “ If
someone prejudices the truth before it is established in the proceedings, it is
a contempt of court, even if they genuinely believe what they are saying to be
true. A further rule that can be added to the general rule of a fair trial is
that no one shall unfairly pressure one of the parties to a cause to withdraw
his complaint or defence through misrepresentation or any other means. The
preservation of the law we just stated in its entirety is always regarded as
being of utmost importance. However, when stating the law in this manner, it is
important to remember that there must be "a real and substantial danger of
prejudice."”
However,
neither the commencement of the litigation nor its conclusion is prohibited by
our law of contempt. The court's spokesperson, Justice Shah, stated succinctly
that the law relating to contempt of court is "well settled" in the
case of In re P.C. Sen[29].
According to R. v. Grey[30],
any action taken or writing made public that has the intention of holding a
court or judge in contempt, undermining their authority, or interfering with
the administration of justice or the lawful procedures of the court,
constitutes contempt of court.
Speaking or
writing scandalously about the court, insulting the parties to an action, or
prejudicing the public in favour of or against a party before the case is heard
are all examples of contempt by speech or writing. The public should not be
prejudiced against those involved as parties in cases before the case is
finally heard, so courts of justice have a duty to protect their proceedings
from being misrepresented. Speeches or writings that inaccurately portray the
Court's proceedings, prejudice the public in favour of or against a party, or
include reflections on the parties to a proceeding are considered to be in
contempt. It is grave contempt to speak in a way that might affect the outcome of
a trial that is currently underway, whether it be civil or criminal. Comments
on ongoing proceedings made by the parties or their solicitors usually
constitute a more serious contempt than remarks made by outside sources. In all
cases involving commentary on ongoing legal proceedings, the key question is
not whether the publication actually impedes the administration of justice, but
rather whether it has a tendency to do so. It is more important to determine
whether it is planned to obstruct the administration of justice than it is to
determine the contemner's intention.”
In Saibal Kumar Gupta and Ors. v. B.K. Sen and Anr[31]
case , The Supreme Court held that ruled that it is not acceptable that a
different investigation is going on along with the nations regular courts are
working. These media investigations are then published in newspapers and starts
a new trial. This
opinion is supported by the fact that such newspaper behaviour tends to
obstruct the administration of justice, regardless of whether the investigation
tends to favour the accused or the prosecution. A newspaper trial is in no way
comparable to what transpired in this case.”
IX.
SUGGESTIONS
In order to remove the
long list of prohibitions and restrictions, media must first turn to the law,
including statutes, legal doctrine, court rulings, and guidelines.
Second, reporters can
acquire a knowledgeable mindset and comprehension regarding the protocol for
covering court proceedings, particularly when it comes to sensitive subjects or
investigative journalism. To improve the difficulties of investigative
journalism, enhance informative journalism, and safely transmit stories into
the public domain, media must operate within the legal framework and must apply
implications of law with legal insights.
The
"Press Council of India" (PCI), a statutory organisation, is
responsible for raising and preserving the standards of print media. The Press
Council of India Act of 1978 grants the PCI a very narrow range of authority.
The Act must be changed in order to give the PCI more authority to take action.
A law prohibiting the
media from reporting anything detrimental to the rights of the accused in
criminal cases, from the time of arrest through the investigation and trial,
has been recommended by the 200th Law Commission Report "Trial by Media:
Free Speech versus Fair Trial Under Criminal Procedure." The report makes
it abundantly clear that a number of pre-trial publications have a negative
effect on the institution of the judiciary by impairing the administration of
justice.
There ought
to be a set minimum requirement to work in the media. It is important to inform
the media professionals about media laws and restrictions. This will enable
them to establish boundaries early on in their professional careers.
The extent to which these
guidelines can be used to protect competing interests is unquestionably
enormous. The Court must establish guidelines on media reporting of judicial proceedings
that are sub judice. The Court can make the necessary changes by establishing
guidelines in this area rather than drafting additional legislation or
proposing amendments to the current comprehensive legislation of the Contempt
of Courts Act, 1971. The accused's right must be effectively protected from
threats posed by negative publicity.
X.
CONCLUSION
Our 50th Chief Justice of
India, CJI DY Chandrachud said “A major issue that has percolated our
system is trial by media. The presumption of innocence postulates that a person
is presumed innocent until found guilty by a court of law. However, there
have been instances when the media has carried narratives that make a person
guilty in the eyes of the public, even before the court finds them guilty. This
can have long-lasting repercussions on the life of the affected individuals, as
well as on due process”[32]. Media is the cornerstone of our Indian
democracy which operates for the greater interest of society but legal process
should not be hindered by the media coverage of a matter. The rule of law must
prevail and the mandate of freedom of press must be construed to be limited to
placing a matter in the consciousness of the society without any presumption
being given. The Court is a competent forum for such decisions and these forums
must be allowed to function without spreading prejudice in the public opinion.
Right to free and fair trial under Article 21 of the Indian Constitution must
be upheld.
XI.
BIBLIOGRAPHY
·
UNPUBLISHED LLM DISSERTATION:
i.Manasvika S., A Critical Study on Trial by Media with Special Reference to Right to
Fair Trial (2017) (Unpublished LL.M dissertation, Christ University).
ii.Arunav Talukdar, MEDIA TRIAL AND RIGHT TO FREEDOM OF SPEECH AND EXPRESSION: AN ANALYSIS
(2018) (Unpublished LL.M dissertation, National Law University, Assam).
·
INDIAN CONSTITUTION PROVISIONS:
i.Article 19 of the Indian
constitution.
ii.Article 21 of the Indian
constitution.
i.Mohd. Aqib, “Judiciary
and Media Trial: A Need for Balance” 5 IJLHB
155 (2019).
ii.Sanatan
Deshpande and Priyank Jagawanshi, “A critical analysis
of media trial and its effect on Indian judiciary” 6 IJRAR173 (2019)
iii.Devika Singh and Shashank Singh,
“Media Trial: Freedom of Speech VS.
Fair Trail” 20 IOSR-JHSS 88
(2015).
·
WEBSITES:
[3] Manasvika S., A Critical Study on Trial by Media with Special Reference to Right to Fair Trial (2017) (Unpublished LL.M dissertation, Christ University).
[4] Ibid.
[5] Ibid.
[8] Arunav Talukdar, MEDIA TRIAL AND RIGHT TO FREEDOM OF SPEECH AND EXPRESSION: AN ANALYSIS (2018) (Unpublished LL.M dissertation, National Law University, Assam).
[10] Indian Express Newspapers (Bombay) Pvt. Ltd. v. Union of India, AIR 1986 SC 515.
[14] Sanatan Deshpande and Priyank Jagawanshi, “A critical analysis of media trial and its effect on Indian judiciary” 6 IJRAR173 (2019)
[16] AIR 2010 SC 2352.
[18] AIR 2012 SC 3829.
[19] Devika Singh and Shashank Singh, “Media Trial: Freedom of Speech VS. Fair Trail” 20 IOSR-JHSS 88 (2015).
[27] 1981 AC 303 (CA)
[28] AIR 1975 AP 30.
[29] AIR 1970 SC 1821.
[30] (1900) 2 Q.B.D. 36 AT p. 40.
[32] "Media Trials Make Person Guilty Before Courts Decide": Chief Justice, available at: https://www.ndtv.com/india-news/media-trials-make-person-guilty-before-courts-decide-chief-justice-dy-chandrachud-3884730
(last visited on MAY 29, 2023)
Article Information
“TRIAL BY MEDIA AND ADMINISTRATION OF JUSTICE” AUTHORED
Authors: JAYA THAPA
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/06/17
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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