Human Rights

Censors between the book-ends: A tragic age for book censorship

AparGupta_freedomofspeechThere was a sense of prophecy when D.H. Lawrence penned the first line to Lady Chatterley’s Lover, his novel about how, impervious to how it often ends in loss, we continue to seek romance. The words, “[o]urs is essentially a tragic age, so we refuse to take it tragically”, had a wider prescription. Little did Lawrence know that his book would inspire in India, the nebulous legal standards for obscenity that would become catastrophic for the liberty of authors, publishers, and readers.

In 1964, acting on the prosecution of a bookseller for obscenity under Section 292 of the Indian Penal Code, 1860 (“IPC”) for the sale of this book, a three-judge bench of the Supreme Court of India adopted the “Hicklin test”. The Court stated in Ranjit Udeshi v. State of Maharashtra that, “the tendency of the matter charged as obscene must be to deprave and corrupt those, whose minds are open to such immoral influences and into whose hands a publication of the sort may fall, so far followed in India, is the right test.” Even today, FIRs are filed against authors while courts continue to deliberate the fuzzy standards for obscenity. Moreover, for each word they write, authors have to negotiate several other content-based offences.

The process of banning a book

LadyChatterleysLoverEven though individual prosecutions for obscenity and other offences occur regularly, they do not, by themselves, result in the prohibition of the sale or distribution of a book. This power of forfeiture comes from Section 95 of the Code of Criminal Procedure, 1973 (“CrPC”), which allows a state government to prohibit a publication by a notification in the official gazette. In its the recent decision in State of Maharashtra v. S. Damodar, the Supreme Court, while overturning a ban on James Laine’s book on Shivaji, stated the ingredients of a valid notification prohibiting a publication.

The state government must first form an opinion that the matter constitutes an offence under one of Sections 124A (sedition), 153A (communalism), 153B (insults to religions), 292 (obscenity), or 295A (outraging religious feelings) of the IPC. Secondly, such an opinion should be published in the official gazette. Importantly, a police officer’s power under this process is not limited to the territorial limits of any state in which the ban has been issued. With the power to confiscate and prosecute publications made available throughout India therefore, even when a book banning notification is issued in Maharashtra, it is often pulled from sale from online bookstores and bookstores in other states.

A statutory opportunity to contest such a ban is provided in Section 96 of the CrPC itself. It allows appeals to the High Court of the state in which the notification for banning has been issued. Further, this right of appeal is not limited to the author or the publisher. Any other person may sue as well. Section 96 therefore, is one of the few provisions of law, which expressly recognises the right to read and the public injury from a ban. It is interesting to note that this provision in its original form can be traced to the Code of Criminal Procedure, 1889 and so ideologically, does not sprout from our constitutional jurisprudence.

TheSatanicVerses_SalmanRushdieSince such a power to ban a publication is available only to the state government, the Union Government has made inventive use of the Customs Act, 1952 (“Customs Act”), most glaringly to prohibit the import of Salman Rushdie’s The Satanic Verses through a notification dated October 5, 1988 under Section 11 of the Customs Act. Rushdie is not alone. Many books on Kashmir and critical accounts of the assassination of Mahatma Gandhi and the Sino-Indian War remain banned by customs authorities.

Private censorship

Though censorship of books by the state in the manner described above has decreased in frequency over the past few years, a worrying trend has emerged in which private persons have successfully caused the censorship of many books. Such censorship, either through a private compromise with the publisher or through a court injunction that is issued before the case is heard on evidence, is mostly a result of allegations of defamation. Defamation exists independently as a criminal offence and as a civil wrong.

Section 499 of the IPC defines the offence of defamation. People found guilty can be sentenced to imprisonment for up to two years. The civil wrong is based on common law and is derived from the judgments of courts and plaintiffs usually seek damages and a perpetual injunction against the defendant from publishing or distributing the work. In practice however, due to delays, criminal trials are itself a process in harassment for authors and publishers and civil suits are compromised after interim injunctions are liberally issued.

WendyDoninger_TheHindu_TheDescentofAirIndia_BhargavaThe most visible instance of a criminal trial resulting in a compromise for pulping a book is the case of Wendy Doniger’s The Hindus. The book was withdrawn pursuant to a compromise between its publisher Penguin and Dinanath Batra, a former general secretary of the education wing of the Rashtriya Swayamsevak Sangh, who had instituted a complaint case under various offences against them. The author’s public statement to quell the criticism faced by the publisher blamed substantive offences in Indian law, specifically Section 295A of the IPC. Another recent instance is that of Bloomsbury withdrawing Jitender Bhargava’s The Descent of Air India under the terms of the settlement of the criminal defamation case instituted in a Mumbai court by Praful Patel, the former Union Minister for Civil Aviation.

The position with respect to civil suits is not much better. It took five years for Kushwant Singh to have an interim inunction lifted from the Delhi High Court for a chapter he wrote about Maneka Gandhi which she alleged, was defamatory. Setting aside the interim injunction, the High Court rebuked the Single Judge’s order stating that its observations about the “high thinking, higher living and high learning of the author are TheBeautifulAndTheDamned_Deb_SaharaTheUntoldStory_Tamalsubjective moralistic observations.” Other recent court injunctions include ones issued by a district court in Silchar against a chapter in Siddharth Deb’s, The Beautiful and the Damned and against Tamal Bandyopadhyay’s Sahara: The Untold Story. One senses a pattern where it is easier to get an interim injunction and then coerce the author to drop a passage than for the author to appeal the injunction, persevere, and then publish the book in its entirety.

More often, one finds that even before a case is filed through the device of a legal notice to the publisher quoting exaggerated and anticipated damages, private parties successfully prevent publications. A recent attempt at this was made by Reliance Industries who sent a legal notice claiming a hundred crore rupees as damages from the author of Gas Wars, Paranjoy Thakurta. Distressingly, such bullying often finds success. Quite recently, Orient Blackswan withdrew Megha Kumar’s Communalism and Sexual Violence: CommunalismSexualViolence_GasWars_PrananjoyGuhaThakurtaAhmedabad Since 1969 following a legal notice sent by Dinanath Batra against another book in its catalogue! Following the receipt of the notice, the publisher commenced a review of its entire catalog, resulting in the withdrawal. Many blame the publishers, but most blame the laws which allow such offence. Though experienced litigators often term such actions as an abuse of law, many would ask, if the law permits such abuse, isn’t the law by itself abusive?

Liberalism through judgments?

In this raging debate, a popular opinion is that the higher judiciary has imparted a liberal reading of the law in favor of authors. This impression is only grounded in rhetoric for several reasons. Quite obviously, most authors and publishers have to wait for years and exhaust the process of appeals before they can approach the higher courts. Any such remedy therefore is an illusory one. Even when writ remedies or an accelerated appeals process is availed of, the approach of the High Courts and the Supreme Court has generally been conservative.

Most often, the higher judiciary examines irregularities either in the criminal procedure or in the banning notification alone. It helps that complainants do not reason the ingredients of the offence complained of and that banning notifications are passed without stating any grounds for the opinion. The examination does not go deeper and the higher courts generally prefer to remand the case for a trial by evidence or defer to the opinion of the state government. Even when such a process-based scrutiny is applied, courts do not hesitate to become censors by themselves.

Legal Research AdvertisementTwo of the latest book banning cases from the Supreme Court illustrates this point. In State of Maharashtra v. S. Damodar, the Court only looked at the ingredients of the banning notification issued by the state government, which made reference to a FIR registered under Section 153A. Since the Court had previously quashed the FIR, it set aside the banning notification. Prior to doing this, in an oral hearing, the Court made a suggestion to delete the alleged offensive passages to enable the state government to lift the ban on the book.

The second instance is where the Supreme Court, in Sri Baragur Ramachandrappa v. State of Karnataka, upheld the notification banning Dharmakaarana, a Kannada novel by P.V. Narayana. In reaching its decision to uphold the banning notification, the Supreme Court cited additional “offensive” passages that were not cited in the banning notification. In a sense, it seemed that the Supreme Court was substituting its own reasons for the ban, going beyond the ones given by the state government. As with Damodar’s Case, the Court again asked the author to delete the offending passages.

Even otherwise, it remains beyond dispute that the underlying substantive law, in spite of attempts to limit its application by precedent, remains subjective. During such a subjective assessment, the content by itself is often examined, and the subjectivity in the law allows for tremendous discretion and inconsistency. A good illustration of this is the recent Supreme Court decision in Aveek Sarkar v. State of West Bengal, where a two-judge bench of the Supreme Court expressly stated that the Hicklin test is outdated and moved towards the more liberal “community standards test” as laid down by the United States Supreme Court in Miller v. California.

Though many would celebrate this shift in precedent, it should be greeted with cautious optimism. Since, the judgment in the Ranjit Udeshi Case was pronounced by a three-judge bench, the observations in Aveek Sarkar by a two-judge bench appear to be per incuriam. Secondly, there exists a vast gap between doctrinal liberalism and its practical application. For years at end, district courts will continue to apply the time honed Hicklin test. Finally, even substantively, the application in Aveek Sarkar is by a panel of judges who sit in the place of the jury and apply “community standards”. While this may often lead to outcomes that favour expression over censorship, it again inheres subjectivity in application. The purported high thresholds set by Aveek Sarkar, remain only in theory.

These cases demonstrate that the Supreme Court is often clumsy and lacks ideological consistency its free speech jurisprudence. In his personal essays explaining the motivations for the themes and styles that would offend many, D.H. Lawrence stated that he had set out to conquer taboos. In this, he failed in India. Sections of our society remain conservative and puritanical to the extent of being exclusionary against views that do not conform to their beliefs. Worse, the law allows their annoyance as an offence and their morality as legality. Close to a century since Lady Chatterley’s Lover was first written, we still remained tethered to Victorian virtues trapped in legal codes. It comes as some comfort that authors rarely care about law when they write, for they have “got to live, no matter how many skies have fallen”.

Apar Gupta is a partner at Advani & Co., and was recently named by Forbes India in its list of thirty Indians under thirty years of age for his work in media and technology law.

Human Rights

The power of licences to censor

AparGupta_freedomofspeechAny study of censorship has to commence with the power of licensing. Shortly after the War for Independence, our colonial masters realised that it was inefficient to enforce criminal sanction for each distinct act of dissent when the mode of expression itself could be prevented by prescribing a set of licensing conditions. Simply, why pulp the paper when you can seize the printing press?

The establishment of a monopoly

The initial prohibition on vernacular publications slowly gained sophistication. The first feature of the licensing system was the express creation of a state monopoly through statute. Private industry had to then operate within a set of requirements prescribed in the statute. Take for instance, the licensing of telegraphs.

Though the physical apparatus of a telegraph has ceased operation, the Telegraph Act, 1885 still holds the field. Under Section 4, the Central Government has the exclusive privilege of establishing, maintaining, and working telegraphs in India. So, even after the process of liberalisation and iterations of the National Telecom Policy, every private telecom operator remains a mere licencee of the Central Government. This licence, which may be a Unified Access Services licence or an Internet Service Provider licence often becomes a unilateral contract prescribed by the Government. All private operators, and by extension their subscribers, have to adhere to the conditions in these contracts.

Licences in India control the medium of dissemination, the substantive content that is disseminated, and some times even the receipt of content. This is all done on the basis of the medium itself, as the law discriminates between newspapers printed on paper, movie exhibitions, television signals, and telephone conversations. Layered and complex, the law consists of law made by Parliament and the State Legislatures. The regulation of newspapers today illustrates this well.

Licensing through registration

Sisir Kumar Ghose (above) was the founder of the Amrita Bazar Patrika, a newspaper that was said to be a principal target of the Vernacular Press Act, 1878, which was passed under the Governor Generalship of Lord Lytton. The law provided for submitting to the police, all the proof sheets of Indian language newspapers before publication.
Sisir Kumar Ghose (above) was the founder of the Amrita Bazar Patrika, a newspaper that was said to be a principal target of the Vernacular Press Act, 1878, which was passed under the Governor Generalship of Lord Lytton. The law provided for submitting to the police, all the proof sheets of Indian language newspapers before publication.

One of the largest mediums in terms of reach, an absolute monopoly has not been expressly prescribed for newspapers. The relevant legal provisions of the system of licensing are contained in the Press and Registration of Books Act, 1867 (“the 1867 law”). Even though the Statement and Objectives state the innocent objective of ensuring that copies of every publication are properly archived by the State, the law goes much beyond ensuring a comprehensive catalogue of the news. The law, which also applies to books and pamphlets, calls for the compulsory declaration of the name of the printer and publisher and the registration of every printing press before the District Magistrate.

A.G. Noorani, in a series of articles published in the Economic and Political Weekly, has documented how this law has been used to enforce (often unlawful) censorship in smaller towns and areas outside metros. The smaller vernacular press also lacked the financial muscle and the professional networks to draw attention, and to resist these attempts. He has highlighted the fact that such declarations are often used by the state administration to harass owners and editors and has also cited one instance where a District Magistrate, relying on a highly technical rule, cancelled the registration of a local newspaper.

Indirect attempts at censorship

This 1867 law pales in comparison to the effort made by the Union Government to neuter the press with the enactment of the Newspaper (Price and Page) Act, 1956, which empowered the Union Government to regulate the prices of newspapers in relation to their pages and sizes and to regulate the allocation of space in newspapers for advertising. In Sakal Papers Ltd. v. Union of India, the Supreme Court determined the constitutionality of this law. The judges stated expressly that the attempt to limit monopolies by fixing prices against the number of pages printed was an attempt to interfere with the freedom of circulation of newspapers and declared parts of the law repugnant to the fundamental right to freedom of speech and expression under Article 19(1)(a) of the Constitution of India, and hence unconstitional.

This decision however, did not impede governments from regulating the content in newspapers through licensing. The Newsprint Policy for 1972-73 made under the Newsprint Control Order, 1962, attempted to ration newsprint. The owners of the Times of India approached the Supreme Court alleging that it violated their fundamental rights, and in Bennett Coleman and Co. and Others v. Union of India, Justice Sikri, speaking for the majority said that the measure was “not newsprint control but newspaper control.” While the Court declared the policy to be contrary to Article 21 for being arbitrary and against Article 19(1)(a), it also emphasised that the power of the government to import and control the distribution of newsprint cannot be denied. The exercise of such power however, has to be within the bounds of the Constitution.

Reframing the law

IPThe Union Government has recently proposed an update to the antiquated 1867 law, increasing its thresholds. Firstly, the Draft Press and Registration of Books Bill, 2013 proposes to extend the coverage of the law to online editions of newspapers. Secondly, it proposes a substantive review of the application for registration itself and prohibits persons convicted of acts of terror and unlawful activity from making such publications. While a convicted terrorist may be guilty of terrorism, such a conviction does not extinguish fundamental rights and it is not understood how such an absolute and complete pre-censorship can be imposed.

A larger concern is the continuity in approach with the 1867 law and the proposals only seek to make the law more onerous. This colonial mistrust of the Press is misplaced with our aspirations of being a mature democracy that trusts its citizens and this amount of regulation is an indicator that rather than tackling such issues with better policing and increased transparency, State entities fear that publications will prompt law and order problems.

This will be a theme in my forthcoming columns as well, specifically focusing on the regulation and censorship of movies and the broadcast of television content. I hope to demonstrate that rather than merely extending the existing regulations, we need a nuanced debate impugning the basis of our colonial laws. With the spread of Internet and mobile communication, we are witnessing a change of season. Laws are becoming redundant, not with the progress of time, but with the progress of technology. Licensing regulations, which sprouted with a sepoy revolt and were then bonded in fabian socialism, need to be shed this autumn.

(Apar Gupta is a partner at Advani & Co., and was recently named by Forbes India in its list of thirty Indians under thirty years of age for his work in media and technology law.)

Human Rights

Not just false fire alarms: time to re-examine Indian laws that limit speech and expression

AparGupta_freedomofspeechA terse ruling by the United States Supreme Court in Shenk v. United States (1919) contains a powerful metaphor on legal arguments about the freedom of speech and expression. “The most stringent protection of free speech”, Justice Holmes said speaking for the Court, “would not protect a man in falsely shouting fire in a theatre and causing a panic”. Even though the Court has since moved away from it as a legal standard (Brandenburg v. Ohio (1969)), it continues to clearly illustrate the idea that the freedom of speech and expression is a conditioned right subject to constitutional limitations. For instance, the Supreme Court of India quoted Justice Holmes in the Ramlila Maidan Incident Case (2012).

Original limitations on free speech

The Constitution of India (“Constitution”) follows this scheme and provides a conditioned right to the freedom of speech and expression. Article 19(1)(a) provides for the fundamental right to freedom of speech and expression and Article 19(2) places restrictions on it. Known as “reasonable restrictions” today, they permitted the legislature to make enactments that fall within the grounds enumerated under it.

Article19(2)_1950 The ink had not dried on the Constitution when petitions were filed in various courts testing the extent of some laws that criminalised speech. While gauging the validity of such laws, the Supreme Court was called in to interpret Article 19(2).

Petitions challenging public order statutes

The Supreme Court interpreted the scope of Article 19(2) as it stood originally in two batches of petitions before it — Romesh Thappar v. State of Madras (1950) and Brij Bhushan v. State of Delhi (1950). In Romesh Thapar, the Court held parts of the Madras Maintaince of Public Order Act, 1949 to be beyond the ambit of the grounds contained in Article 19(2) and struck them down as unconstitutional. On similar reasoning, Brij Bhushan held pre-censorship orders issued under the East Punjab Public Safety Act, 1949 to be unconstitional. Justice Fazal Ali dissented persuasively in both cases, arguing that the enactments fall within the ambit of Article 19(2). H.M. Seervai, citing the presumption of constitutionality, has agreed with his views.

Some High Court judgments also did what the Supreme Court did. For instance, the crime of sedition and the Press (Emergency Powers) Act, 1931 were held unconstitutional. These petitions set the stage for the Parliament of India to consider the first amendment to the Constitution of India.

The 1st Amendment

On May 16, 1951, a mere sixteen months after the Constitution was adopted, a bill to amend it was introduced in the Parliament. The 1st Amendment Bill stated that “…Article 19(1)(a) has been held by some courts to be so comprehensive as not to render a person culpable even if he advocates murder or other crimes of violence” and sought to amend and expand Article 19(2). Importantly, the word, “reasonable” was inserted in the Bill after a Select Committee report was adopted on May 29. Article 19(2) was then amended by the Constitution (First Amendment) Act, 1951.


The Supreme Court was considerably accommodative in the constitutional appraisal of laws alleged to be in conflict with the amended Article 19(2). In Ramji Lal Modi v. State of Uttar Pradesh (1957), the constitionality of Section 295A of the Indian Penal Code, 1860, which contained the offence of insulting a religion, was challenged. The provision was in the news recently when publisher Penguin India claimed that the threat of prosecution for this offence was the reason it withdrew a book by Wendy Doniger.

Analysing it, the Court held that “the expression ‘in the interests of’ occurring in the amended Cl. (2) of Art. 19 had the effect of making the protection afforded by that clause very wide and a law not directly designed to maintain public order would well be within its protection if such activities as it penalised had a tendency to cause public disorder.” With the passage of time, there has been growing recognition that Article 19(2) as amended, was framed for the convenience of a police constable and not for the liberty of artists, writers, and citizens.

The necessity of reasonable restrictions

Justice Oliver Wendell Holmes Jr. did not enjoy false fire alarms.
Justice Oliver Wendell Holmes Jr. did not enjoy false fire alarms.

Even though the Supreme Court has not struck down many such laws as unconstitutional, it has often limited their operation by reading requirements into them. The scope of Article 19(2) has been considerably expanded and cases such as Romesh Thappar and Brij Bhushan are no longer good law but the judiciary has often seized upon the requirement of “reasonableness” in support of these limitations. Take the example of the cases on sedition, an offence contained in Section 124A of the Indian Penal Code, 1860.

The Supreme Court in Kedar Nath Singh v. State of Bihar (1962), while holding the provision to be constitutional, placed several limitations on it by holding that only those acts that had the intention or tendency to incite public disorder or violence would invite prosecution. The Court noted that it was clear that “criticism of public measures or comment on Government action, however strongly worded, would be within reasonable limits and would be consistent with the fundamental right of freedom of speech and expression.”

This sentiment can also be seen in the recent case of Pravasi Bhalai Sangathan v. Union of India and Others (2014), where it refused to issue directions for increased penal sanctions against ‘hate speeches’. The Court asked the Law Commission of India to study the applicable law and said, “It is desirable to put reasonable prohibition on unwarranted actions but there may arise difficulty in confining the prohibition to some manageable standard and in doing so, it may encompass all sorts of speeches which needs to be avoided .”

However, given that every few weeks, the Press highlights instances of the egregious abuse of these provisions, many have questioned the effectiveness of these court crafted doctrines and limitations.

The way forward

Assem Trivedi, Binayak Sen

The prosecutions of Binayak Sen, cartoonist Aseem Trivedi, and the Kashmiri students at Swami Vivekanand Subharti University present a mismatch in the doctrinal limitations imposed by Court precedent and the prosecutions that disregard them. These errors are corrected, if ever, through the appeals process but not before a punishment is visited in the form of pre-trial detention or even by the harassment caused by the prosecution itself. The Supreme Court’s precedent seeks to limit the application of such penal provisions but it is often disregarded at the stage of trial. This experience makes a strong case for their amendment or repeal. Though inconvenient given the current state of our polity, the proper forum for arguments about changing laws affecting speech and expression in India is the floor of the Parliament, not the Chief Justice’s court.

A concluding caveat on the arguments to amend Article 19(2) itself, rather than delete specific penal laws. Article 19(2) only provides an outer limit for legislation and not a constitutional imperative for the enactment of reasonable restrictions on speech. Today, the vast expanse of our penal laws not only prevent false fire alarms in cinemas but even criminalise the screening of movies. The time is ripe for the Law Commission of India to study how the laws that limit speech and expression are defined by their abuse and intolerance of dissent.

Apar Gupta is a partner at Advani & Co., and was recently named by Forbes India in its list of thirty Indians under thirty years of age for his work in media and technology law.

Human Rights Lounge Uncategorized

Drawing a line – Why I lost my enthusiasm for Draw Mohammed Day

I didn’t quite know what to make of Draw Muhammed Day on May 20.

True to South Park canon, the source of the problem is a Canadian. Fox News had published her name as the originator of the idea that went viral, even though she has long backed off. The issue dates back to Viacom’s censorship of the 201st episode of South Park. The bi-centennial anniversary was a celebration of South Park’s major characters and plotlines. Yes, even the Super Best Friends who were resurrected to show Buddha snorting cocaine and Jesus using porn. Ironically, Viacom bleeped the show extensively and in particular, Kyle’s teaching point at the end. Allegedly, what Kyle had learnt that day concerned not cowing down to absurd terror. The Canadian was objecting to such censorship.

In the beginning, the banning of Facebook was just one more thing to roll your eyes at Pakistan for. Yet, trawling the pictures people had posted, I saw mainly pure Islamophobia on display. Many drawings depicted the Prophet as a pig. Others invest him with devilish aspects. A common theme was him abusing little girls as a paedophile. Soiling himself was almost a leitmotif. Then there were some that were so ridiculous in their attempt to be offensive that they had genuine artistic merit. Case in point- the I am Muhammed and I have a bread roll in my bum cartoon.

This is not to say that all of the cartoons were designed to be offensive. My favourite had to be the simple stick figure sniffing a flower. Someone had also drawn a rather good portrait of the boxer Cassius Clay. There was even a montage of the long tradition of aesthetic paintings of the Prophet in Shia culture.

When it comes to depicting the Prophet, the issue is more complex than a freedom of expressionversus religious sensitivity debate. This point is best expressed by Karseten Kjar’s documentary Bloody Cartoons. Made as part of a series for BBC entitled Why Democracy?, it peels back layers of the carefully planned protests against Denmark to find it is not much different from the Rushdie fatwa issue. The Satanic Verses controversy is seen by many as a classic wag-the-dog exercise by the Ayatollah. He needed to shore up political support for the war against Iraq, which wasn’t going well. The scene that seals the deal in the documentary is when the filmmaker buys the last poster of Muhammed (depicted in a Disneyish hero iconography) in an Iranian Islamic super-store. The Iranians were going to stop publishing the hero poster to show solidarity with their Sunni Arab brothers (whose guts they ordinarily hate and fought above-mentioned war with).

In many ways this represents how much freedom of expression has shrunk due to that old villain: globalisation. When Super Best Friends was aired in 2001, no one took any notice of it. The Danish cartoons controversy has changed all that. Viacom no longer airs the episode that ran unimpeded for nearly ten years.

The Facebook, er, face-off between offended Muslims and those who are blatantly enjoying the anonymity of the Internet to rile them is very different from traditional conflict. It is not one artist against some fundamentalists. It is thousands of common people versus each other.

I quickly lost any enthusiasm for what had initially seemed a genuine grass-roots reprisal against fear, through social networking. There is a line between challenging the oppression of blasphemy and expressing hate against a people.

Somewhere, cartoons had stopped being funny.

Shubhodeep Shome is a writer and lawyer.