Abstract
The Indian judiciary occupies a paradoxical position in the landscape of press regulation: simultaneously the guardian of constitutional freedoms and, through contempt jurisdiction and injunctive powers, a potential restrainer of media expression. This paper examines contemporary judicial approaches to press freedom in India, analyzing significant decisions from 2024–2026 that illuminate the evolving constitutional balance between Article 19(1)(a) and competing rights under Article 21. Through detailed analysis of recent High Court and Supreme Court pronouncements—including the Kerala High Court’s media trial guidelines, the Delhi High Court’s right to be forgotten ruling in IE Online Media Services, and the Adani gag order litigation—this paper argues that Indian courts are progressively reconceptualizing press freedom as a right requiring continuous calibration against privacy, dignity, and fair trial rights in the digital age. The paper contends that this judicial rebalancing, while constitutionally necessary, creates uncertainty regarding the boundaries of permissible reporting and may produce chilling effects if not accompanied by clear doctrinal standards.
I. Introduction
Freedom of the press in India occupies what Justice B.V. Nagarathna has described as an “interesting constitutional status”—emerging from the interaction between Article 19(1)(a)’s guarantee of speech and expression and Article 19(1)(g)’s protection of occupational freedom.[1] This dual foundation means that press freedom is simultaneously protected from different constitutional angles, yet also subject to correspondingly diverse forms of restriction.
The most serious threats to press freedom, Justice Nagarathna recently observed, “are likely to arise not from direct censorship under Article 19(2), but from regulations justified under Article 19(6).”[2] Ownership rules, licensing laws, advertising policies, taxation, and antitrust law may all be defended as economic regulation, even when they have profound effects on editorial independence. This allows the State to influence the press indirectly while maintaining formal compliance with constitutional guarantees.[3]
This paper examines how Indian courts are navigating this complex constitutional terrain in an era of rapid media transformation. It analyzes three clusters of recent judicial decisions: those addressing the boundaries of media reporting on criminal investigations and trials; those balancing press freedom against privacy and the right to be forgotten; and those confronting prior restraint through injunctive orders in defamation litigation. Together, these cases reveal a judiciary engaged in the difficult task of recalibrating press freedom for the digital age—where information is permanent, algorithms shape visibility, and the distinction between publisher and platform has blurred beyond recognition.
II. Media Trials and the Right to Fair Trial: The Kerala High Court’s LakshmanRekha
A. The Reference and Its Context
In November 2024, a five-judge bench of the Kerala High Court delivered a significant judgment addressing the limits of media reporting on ongoing criminal investigations and trials.[4] The case arose from writ petitions filed as early as 2018, seeking restrictions on media coverage of active criminal cases. The petitions were referred to a larger bench due to concerns over what the court termed “media trials”—the phenomenon of media outlets pronouncing on suspects’ guilt or innocence before judicial determination.[5]
The court’s judgment represents the most comprehensive judicial examination of media trial concerns since the Supreme Court’s observations in Sahara India Real Estate Corp. v. SEBI (2012) and R.K. Anand v. Delhi High Court (2009).[6] It addresses fundamental questions about the relationship between media freedom and the constitutional guarantee of fair trial under Article 21.
B. The Court’s Holding: Drawing the LakshmanRekha
The Kerala High Court unanimously held that while freedom of speech and expression under Article 19(1)(a) is fundamental, it does not grant the media a “licence” to pronounce on an accused’s guilt or innocence before legal authorities have reached a verdict.[7] The court emphasized that unrestricted reporting could prejudice public opinion and undermine trust in judicial outcomes.
Justice A.K. JayasankaranNambiar, writing for the bench, observed that media trials “exceed the limits of ethical caution and fair comment” and project the suspect or accused as guilty or innocent even before the court delivers a verdict.[8] This, the court held, amounts to “a gross violation of the right of the accused, victim, and witnesses to a fair trial” guaranteed under the Constitution.
The court’s central metaphor—the “LakshmanRekha”—captures its conception of media responsibility. Just as Lakshman drew a line that could not be crossed, the media must recognize its own boundaries:
“It is desirable that the media realise its responsibility to society and draw the ‘LakshmanRekha’ themselves without overstepping into the domain of the judiciary and the investigating agency and ensure that no media trial is undertaken, which causes prejudice to the fair trial and has an adverse impact on the privacy and dignity of the accused and the victim.”[9]
C. Constitutional Framework: Article 19(1)(a) and Article 21
The court grounded its analysis in the constitutional tension between Article 19(1)(a) and Article 21. While the media has the right to report facts, this right is subject to reasonable restrictions, especially when it conflicts with an individual’s right to privacy, dignity, and fair trial.[10] The court rejected the notion that press freedom operates as an absolute trump card, emphasizing instead the need for contextual balancing.
Significantly, the court distinguished between reporting facts and expressing opinions on guilt. Reporting on arrests and investigations may be justified at the contemporaneous stage, but expressing definitive views on guilt or innocence constitutes an impermissible intrusion into the judicial domain.[11]This distinction provides a potential framework for evaluating media coverage: factual reportage remains protected, while evaluative commentary that pre-judges outcomes may exceed constitutional limits.
D. Implications and Unresolved Questions
The Kerala High Court’s judgment reinforces the principle that media freedom does not include the right to conduct parallel trials. However, it leaves several questions unanswered. The distinction between “reporting facts” and “expressing opinions” may prove difficult to apply in practice, particularly in an era where editorial choices about framing, emphasis, and selection inevitably shape reader perceptions.
Moreover, the judgment’s reliance on media self-regulation (“draw the LakshmanRekha themselves”) may be optimistic given commercial pressures and competitive dynamics that incentivize sensational coverage. The court declined to issue specific guidelines, leaving it to media organizations to develop their own ethical boundaries—an approach that respects media autonomy but may provide insufficient protection for accused persons.
The judgment also did not address enforcement mechanisms. If media outlets cross the LakshmanRekha, what remedies are available? Contempt of court proceedings remain theoretically available, but their use against media requires careful calibration to avoid chilling legitimate reporting.
III. Privacy, Dignity, and the Right to Be Forgotten: IE Online Media Services v. Nitin Bhatnagar
A. Facts and Procedural History
The Delhi High Court’s decision in IE Online Media Services Private Limited v. Nitin Bhatnagar and Ors. (2025) addresses the intersection of press freedom and digital privacy in a context of particular significance: the continued online availability of news reports concerning individuals who have been exonerated.[12]
The respondent, a senior banking professional, had been arrested by the Directorate of Enforcement in August 2023 in connection with alleged irregularities relating to Moser Baer India Limited. Multiple news reports were published associating him with the alleged offense. Subsequently, however, he was discharged by the jurisdictional court on August 17, 2024, with the court finding no legally admissible evidence against him. The criminal complaint was ultimately dismissed on July 24, 2025.[13]
Despite his exoneration, the news reports remained accessible on digital platforms, continuing to associate him with criminal allegations through search engine indexing and algorithmic recommendation systems. Aggrieved by this continued online availability, the respondent instituted a civil suit seeking injunctions for de-indexing and de-referencing of the impugned articles, arguing that their continued circulation violated his right to privacy, dignity, and the right to be forgotten under Article 21.[14]
The trial court granted interim relief restraining further circulation, leading to the appeal before the Delhi High Court.
B. The Constitutional Conflict: Article 19(1)(a) vs. Article 21
IE Online contended that the reporting constituted fair and accurate reportage protected under Article 19(1)(a), and that the interim injunction amounted to impermissible prior restraint on press freedom.[15] The respondent argued that while the reporting might have been justified when published, its continued circulation after exoneration served no legitimate public interest and caused ongoing reputational harm.
The Delhi High Court reaffirmed that although press freedom is constitutionally protected, it is not an unfettered right. Relying on the Supreme Court’s decision in K.S. Puttaswamy v. Union of India (2017), the court reiterated that the right to privacy under Article 21 encompasses the preservation of an individual’s dignity, reputation, and informational self-determination, particularly in the context of digital dissemination of personal data.[16]
The court also placed reliance on the Kerala High Court’s decision in DejoKappan v. Deccan Herald (2024), which recognized that continued publication of criminal allegations against a person who has been acquitted or discharged may, over time, lose its legitimate public interest and instead operate as a source of unwarranted reputational harm.[17]
C. The Temporal Dimension of Press Freedom
A significant aspect of the Delhi High Court’s reasoning concerns the temporal dimension of press freedom. While reporting on arrests and investigations may be justified at the contemporaneous stage, the evaluation shifts once criminal proceedings conclude in favor of the individual concerned.[18] The court emphasized that the internet’s capacity to preserve and amplify information indefinitely distinguishes digital reporting from traditional print media:
“The continued online availability and algorithmic resurfacing of content associating an individual with criminal allegations, despite their exoneration, has the effect of perpetuating stigma, undermining rehabilitation, and inflicting disproportionate harm on the individual’s dignity and social standing.”[19]
This temporal analysis introduces a dynamic element to press freedom: what is constitutionally protected at one moment may cease to be protected when circumstances change. Publishers cannot rely indefinitely on the original justification for publication; they must continuously reassess whether continued circulation serves any subsisting public interest.
D. The Inadequacy of Post-Facto Updates
IE Online argued that several of the impugned articles had been updated to record the respondent’s discharge, thereby addressing reputational concerns. The court rejected this defense, holding that post-facto updates were inadequate to remedy continuing harm.[20]
The court observed that reputational impact is shaped not merely by the accuracy of information within an article, but by the overall manner of dissemination. Headlines, URLs, metadata, and search engine indexing play determinative roles in how information is encountered and interpreted:
“Where the dominant narrative of an article continues to foreground allegations of criminality, a brief clarification appended at a later stage may do very little to alter the public perception originally created. As a result, the association between the individual and the alleged offence may continue to persist, notwithstanding formal corrections or disclaimers.”[21]
This recognition of the gap between formal correction and actual perception reflects sophisticated understanding of digital information ecosystems. The court implicitly acknowledged that in an algorithm-driven information environment, updates that do not alter the core framing of content may be functionally invisible to most readers.
E. Implications for Digital Publishers
The IE Online decision carries significant implications for digital publishers. It signals judicial expectation that news reporting cannot remain static; ongoing reassessment is required, particularly in criminal proceedings coverage. Publishers must consider not only whether reporting was justified when published, but whether its continued circulation remains justified.[22]
The decision also raises questions about the right to be forgotten’s scope in Indian jurisprudence. While the Supreme Court has not definitively recognized this right, lower courts are increasingly giving it effect through Article 21’s dignity and privacy dimensions. The Delhi High Court’s emphasis on “informational self-determination” suggests a conception of privacy that includes control over one’s digital history.
For media organizations, the decision creates operational challenges. Maintaining digital archives indefinitely may expose publishers to liability when circumstances change. Yet removing or de-indexing content raises concerns about historical record and public access to information. The court’s solution—proportionate remedial measures such as de-indexing or restricted access rather than wholesale suppression—attempts to balance these competing interests, but its practical application will require careful case-by-case determination.
IV. Prior Restraint and Corporate Power: The Adani Gag Order Controversy
A. The September 6, 2025 Order
On September 6, 2025, a Delhi court issued an interim injunction in favor of Adani Enterprises Limited, restraining nine journalists and digital platforms from publishing and distributing content the conglomerate considered “unverified and defamatory.”[23] The order applied to some of India’s most prominent journalists and content creators, including Ravish Kumar, DhruvRathee, ParanjoyGuhaThakurta, and Abhisar Sharma.
The court directed immediate takedown of media content, including nearly 140 YouTube videos and over 80 Instagram posts from prominent news outlets and commentators.[24] The Ministry of Information and Broadcasting enforced the order through rapid takedown notices, acting with what critics described as unusual alacrity.[25]
The order was issued ex parte—without notice to the affected journalists or opportunity for them to present their perspective before the restraint was imposed. While the court stated that “fair and accurate reporting based on substantiated and verified material” would remain protected, the order’s sweeping breadth and the speed of its enforcement raised immediate concerns about prior restraint and press freedom.[26]
B. Constitutional Objections: Prior Restraint and Natural Justice
The Adani gag order implicates two fundamental constitutional principles: the prohibition on prior restraint and the requirement of natural justice. The Supreme Court has consistently held, since RomeshThappar (1950), that prior restraint on speech is presumptively unconstitutional, permissible only in the rarest of circumstances.[27] In 2024, the Court reiterated that “the grant of a pre-trial injunction against the publication of an article may have severe ramifications on the right to freedom of speech.”[28]
The ex parte nature of the order compounded the prior restraint concern. Attorney Nakul Gandhi, representing some of the affected journalists, argued that the order “violates fundamental principles of natural justice and constitutional free speech protections.”[29] By silencing journalists without hearing them, the court denied them the opportunity to demonstrate that their reporting was based on verified material and constituted fair comment on matters of public interest.
C. The “John Doe”/”Ashok Kumar” Order Problem
The Adani ruling applied to individuals not specifically named in the case—so-called “Ashok Kumar” orders (the Indian equivalent of American “John Doe” orders). These mechanisms have traditionally been used in intellectual property cases involving unknown defendants, but their expansion to media content raises serious concerns.[30]
Journalist AbirDasgupta noted: “The court’s takedown and gag order, issued without hearing the defendants, is also applicable to ‘John Doe’ defendants, which can extend to absolutely anyone.”[31] This potential for orders to sweep in persons not before the court, without opportunity to be heard, creates significant risks for journalists and content creators who may find themselves subject to restraints they had no opportunity to contest.
D. Government Enforcement and the Chilling Effect
The Ministry of Information and Broadcasting’s rapid enforcement of the takedown order—sending notices to multiple online publishers and content creators within days—amplified its chilling effect. Critics noted that the Ministry acted with an alacrity rarely seen in response to other court orders, raising questions about selective enforcement.[32]
Satirist Akash Banerjee, whose channel “The Deshbhakt” was included in the order sweep, observed: “Look at the alacrity and speed with which the MIB executed the court order. These actions have a chilling effect far beyond those named in the order. At one level, there’s lip service to press freedom, while at another, there’s this happening.”[33]
The Editors Guild of India termed the court order and content takedown “troubling,” stating that the enforcement mechanism “has effectively given a private corporation powers to determine what constitutes defamatory content regarding their affairs, which extends the power to order content takedown.”[34]
E. Partial Judicial Correction
On September 18, 2025, District Sessions Judge Ashish Agarwal set aside the ex parte interim order for four of the journalists after they appealed.[35] The judge’s reasoning was significant: “The court of the senior civil judge ought to have made observations of which material was defamatory… the judge should have granted the defendants a chance before prima facie declaring that they (the posts) were defamatory.”[36]
This partial correction reinforces the principle that ex parte restraints on speech require exceptional justification and careful specification of the material found objectionable. However, it also illustrates the burden placed on journalists to challenge orders that may have already caused irreparable harm to their work and reputation.
F. SLAPP Suits and Strategic Litigation Concerns
The Adani litigation has been characterized by some observers as exemplifying Strategic Lawsuits Against Public Participation (SLAPP)—lawsuits filed primarily to intimidate, silence, or burden critics by forcing them into costly and time-consuming legal battles.[37]
Investigative journalist Ravi Nair, who was among the journalists initially subject to the gag order, noted: “I am fighting another defamation suit, again filed by the Adani Group in 2021. The idea behind such suits is that journalists will feel exhausted due to the legal expenses, time wasted and mental harassment. The process itself becomes a punishment. Hence, people usually hesitate to investigate the corrupt practices of these corporate houses.”[38]
While India does not have anti-SLAPP legislation comparable to that in some US jurisdictions, the phenomenon raises important questions about access to justice and the practical realities of defending press freedom against well-resourced litigants.
V. Judicial Philosophy and Press Freedom: Justice Nagarathna’s Constitutional Vision
A. The Dual Foundation of Press Freedom
In a significant speech at the IPI India Award for Excellence in Journalism 2025, Supreme Court Justice B.V. Nagarathna articulated a sophisticated constitutional vision of press freedom.[39] She emphasized that press freedom in India emerges from the interaction between Article 19(1)(a)—freedom of speech and expression—and Article 19(1)(g)—freedom to practice any profession or carry on any occupation, trade, or business.[40]
This dual foundation has important implications. Because press freedom is protected from two different constitutional angles, attempts to restrict it must satisfy not only the Article 19(2) reasonableness standard but also the Article 19(6) requirements for occupational regulation. Conversely, this dual protection also means that press freedom may be constrained through either provision—through content-based restrictions under Article 19(2) or through economic regulation under Article 19(6).
B. The Threat of Economic Regulation
Justice Nagarathna identified a crucial insight: the most serious threats to press freedom may arise not from direct censorship, but from regulations justified as economic measures. “Ownership rules, licensing laws, advertising policies, taxation, and increasingly antitrust law may all be defended as economic regulation, even when they have profound effects on editorial independence.”[41]
This allows the State to influence the press indirectly while maintaining formal compliance with Article 19(1)(a). A press outlet may be legally free to criticize the government, yet economically constrained in ways that make such criticism costly or unsustainable. Editors internalize the risk that critical coverage may lead to withdrawal of advertising contracts—particularly when governments, public sector undertakings, and political parties are major advertisers.[42]
C. The Problem of Press Capture
Justice Nagarathna flagged “the recent trend of attempts to capture the press” as having “not only economic underpinnings but also political overtones.”[43] Media outlets may remain editorially independent on paper, yet their capacity to pursue adversarial journalism is limited by the interests of owners whose economic or political ties may be threatened by such reporting.
This raises what Justice Nagarathna termed a “normative question: if press freedom depends on economic viability within competitive markets, can it truly be free? Will there then be a free and balanced press? The press may be free from the State yet dependent on corporate power which may in turn be dependent on State patronage.”[44]
D. The Reader-Supported Press Ideal
Justice Nagarathna offered a potential solution to the dilemma of economic dependence: a press sustained by its readers rather than by advertising revenue or corporate ownership. “When someone takes a subscription, they’re really saying, this kind of reporting is worth backing. A press sustained by its readers is always better placed to serve the public interest and fend off political pressures.”[45]
This vision of reader-supported journalism recognizes that economic independence is essential to editorial independence. However, it also acknowledges the practical difficulties: “Good journalism doesn’t run on goodwill alone.”[46] Civil society must recognize that independent reporting is a public good worth paying for—a recognition that requires cultural as well as economic transformation.
Vi. Synthesis: The Emerging Constitutional Balance
A. From Absolutism to Calibration
The cases examined in this paper reveal a judiciary moving away from absolutist conceptions of press freedom toward a more calibrated approach that weighs competing constitutional values. The Kerala High Court’s media trial guidelines, the Delhi High Court’s right to be forgotten ruling, and Justice Nagarathna’s economic analysis all reflect a recognition that press freedom must be balanced against privacy, dignity, fair trial rights, and the practical realities of economic dependence.
This calibration is not necessarily hostile to press freedom. By acknowledging competing values, courts may actually strengthen the constitutional case for press freedom by demonstrating that it survives such balancing rather than being easily overridden. The Delhi High Court’s nuanced approach in IE Online—requiring de-indexing rather than deletion, recognizing the legitimacy of original publication while restricting indefinite circulation—exemplifies this calibrated methodology.
B. The Digital Transformation Imperative
Digital transformation fundamentally alters the constitutional analysis of press freedom. The internet’s permanence means that publication is no longer a discrete event but a continuous process of making information available. Algorithmic curation means that information visibility is shaped by forces beyond editorial control. The “right to be forgotten” emerges as a necessary complement to the right to publish precisely because digital information does not naturally fade over time.
Courts are grappling with these transformations on a case-by-case basis, developing doctrine incrementally. The IE Online decision’s recognition that digital reporting requires continuous reassessment represents an important step toward doctrine adequate to the digital age. The Adani gag order litigation’s focus on the scope of injunctive relief and the mechanics of enforcement similarly reflects judicial engagement with the specific challenges of digital content regulation.
C. The Unresolved Tension: Prior Restraint
Despite these doctrinal developments, prior restraint remains a deeply contested area. The Adani gag order demonstrates that courts remain willing to issue broad injunctions restricting speech, particularly in defamation cases involving powerful litigants. While the subsequent partial correction suggests appellate scrutiny can provide a check, the initial orders may nevertheless cause irreparable harm before they can be challenged.
The Supreme Court’s clear statements against prior restraint have not been fully operationalized in lower court practice. Developing clearer standards for when interim injunctions against speech may issue—including heightened pleading requirements, clear specification of objectionable material, and demonstration of irreparable harm—remains an urgent task for judicial development.
VII. Conclusion
The Indian judiciary’s approach to press freedom is undergoing significant evolution. Confronted with the challenges of digital transformation, corporate power, and competing constitutional rights, courts are developing increasingly sophisticated frameworks for balancing press freedom against other values.
The Kerala High Court’s articulation of the “LakshmanRekha” for media trials, the Delhi High Court’s recognition of the right to be forgotten in digital reporting, and Justice Nagarathna’s analysis of economic threats to press freedom collectively represent a maturing constitutional jurisprudence. These developments acknowledge that press freedom, while fundamental, operates within a complex ecosystem of competing rights and practical constraints.
Yet significant challenges remain. The Adani gag order controversy reveals the continuing vulnerability of journalists to prior restraint and the potential for well-resourced litigants to weaponize defamation law against critical reporting. The absence of clear standards for interim injunctions against speech, and the lack of anti-SLAPP protections, leave journalists exposed to strategic litigation designed to exhaust rather than to vindicate legal rights.
For India’s press to fulfill its constitutional role as the fourth pillar of democracy, it requires not only judicial protection but also economic independence and professional self-discipline. The courts can articulate the constitutional boundaries of press freedom, but they cannot ensure that media organizations operate within those boundaries ethically, nor can they guarantee the economic viability that enables fearless journalism.
Justice Nagarathna’s call for a reader-supported press, and her recognition that “a free press is not created by decree; it evolves through interaction between readers, writers, and editors,”[47] captures this essential truth. The constitutional framework for press freedom provides necessary protection, but the vitality of that freedom ultimately depends on the society it serves.
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[1]Justice B.V. Nagarathna, Speech at IPI India Award for Excellence in Journalism 2025 (Feb. 27, 2026), reported in “Media cannot perform its role under constraint, fear or influence: SC Judge”, NAGALAND POST (Feb. 27, 2026) [hereinafter Nagarathna Speech].
[2] Id.
[3]Id.
[4] “In re: Media Reporting on Criminal Investigations and Trials”, 2024 SCC OnLine Ker 6494.
[5]See* India Today, “Press must draw ‘LakshmanRekha’, ensure against media trial: Kerala High Court” (Nov. 8, 2024), https://www.indiatoday.in/india/law-news/story/kerala-high-court-bars-media-from-judging-guilt-in-active-criminal-cases-2630324-2024-11-08.
[6]Sahara India Real Estate Corp. v. SEBI”, (2012) 10 SCC 603; “R.K. Anand v. Delhi High Court”, (2009) 8 SCC 106.
[7]Kerala High Court Judgment, ¶ 18.
[8] Id. ¶ 22.
[9] Id. ¶ 28.
[10]Id. ¶ 31.
[11] Id. ¶ 35.
[12]IE Online Media Services Private Limited v. Nitin Bhatnagar and Ors.”, 2025 SCC OnLine Del 9281.
[13]Id. ¶ 4.
[14]Id. ¶ 6.
[15]Id. ¶ 8.
[16]Id. ¶ 15 (citing “K.S. Puttaswamy v. Union of India”, (2017) 10 SCC 1).
[17]Id. ¶ 17 (citing “DejoKappan v. Deccan Herald”, 2024 SCC OnLine Ker 6494).
[18]Id. ¶ 22
[19]Id. ¶ 23.
[20]Id. ¶ 28.
[21]Id. ¶ 29.
[22]VrindaPatodia, “When The Internet Refuses To Move On: Media Reporting, Discharge And Dignity”, MONDAQ (Jan. 28, 2026), https://www.mondaq.com/india/media-entertainment-law/1737452.
[23]Adani Enterprises Ltd. v. John Does, Interim Order, Delhi District Court (Sept. 6, 2025).
[24]Murali Krishnan, India’s Adani gag order fuels press freedom fears, DEUTSCHE WELLE (Sept. 22, 2025), https://www.dw.com/en/india-adani-business-conglomerate-gag-order-free-speech/a-74095798.
[25]Express View on Adani defamation case: Do not gag*, INDIAN EXPRESS (Sept. 20, 2025), https://indianexpress.com/article/opinion/editorials/express-view-on-adani-defamation-case-do-not-gag-10260236/.
[26]Krishnan, “supra note 24.
[27]RomeshThappar v. State of Madras, AIR 1950 SC 124.
[28]Quoted in INDIAN EXPRESS, ‘supra’ note 25.
[29]Krishnan, ‘supra’ note 24.
[30]Id.
[31]Id.
[32]INDIAN EXPRESS, ‘supra’ note 25.
[33]Krishnan, ‘supra’ note 24.
[34]‘Id.’
[35]INDIAN EXPRESS, ‘supra’ note 25.
[36]‘Id.’
[37]Krishnan, ‘supra note 24.
[38]Id.
[39]Nagarathna Speech, supra note 1.
[40]Id.
[41]Id.
[42]Id.
[43]Id.
[44]Id.
[45]Id.
[46]Id.
[47]Id.
