Case: Petitioner: Shreya Singhal v/s Respondent: Union Of India
Citation: AIR 2015 SC 1523 - Court: Honourable Supreme Court Of India
Bench/Judge: Justice J.Rohinton Fali Nariman, Justice J. Chelameswar.
Judgment Date: 24th March, 2015
 
Statues/ Constitution Involved:

1. Information Technology Act, 2000,
2. Kerala Police Act,
3. The Constitution Of India.

Important Sections/ Articles:

• Section 66A,69A,79 Of The Information Technology Act ,2000.
• Section 118(D) Of The Kerala Police Act.
• Articles 14,19,19(1)(A) & 19(2) Of The Constitution Of India.

Introduction:
One of the most important element for a healthy democracy is establishing a space where citizens can participate completely and effectively in the decision-making process of the particular country. Significantly, Constitution of India also guarantees every citizen the Right to freedom of speech and expression, this right is not only guaranteed by constitution but also through various international conventions like International Covenant on Civil and Political Rights (ICCPR), Universal Declaration of Human Rights (UDHR) and European Conventions on Human Rights and Fundamental Freedom.

At the same time, cases regarding hatred, false information and Sensational reporting of critical issues in order to obtain viewership is also increasing. Therefore, in order to maintain sovereignty and integrity of country the Government also imposes some reasonable restrictions, because the right to freedom of speech and expression under the constitution of India is not absolute.

Shreya Singhal vs Union of India[1] is a landmark case which has created significant impact in the history of Indian legal system. This case revolves around the fundamental right to freedom of speech and expression guaranteed in Article 19(1)(a) of the Indian Constitution.

In this case under Article 32 of the Indian Constitution, Ten criminal and civil writ petitions were filed in the Honourable Supreme Court of India. These writ petitions raised concerns mainly about the provisions of Sections 66 A, 69 A, 79 of the Information Technology Act of 2000[2] and Section 118 (d) of the Kerala Police Act, with respect to the freedom of speech and expression guaranteed under the provisions of Article 19 (1) (a) of the Constitution of India.

Facts:
In the year 2012, Mumbai police arrested two girls named Shaheen Dhada and Rinu Shrinivasan for expressing their displeasure in the Facebook against the Bandh which was declared by Shiv Sena due to death of the leader named Bal Thackrey in Mumbai. One of the girl posted a statement by criticizing the bandh and the other one liked the post on social media. Due to this Mumbai police immediately took action against them under section 66 A of the Information and Technology Act, 2000.

They were arrested by the Mumbai police merely on the purpose of commenting, liking and by believing that their action created hatred and annoyance in the minds of the public at large. But after few days the girls were released but the arrest and the case attracted public protest at large further, media agencies bought into limelight that the provision of Section 66 A of the Information Technology Act, 2000 has violated the right to freedom of speech and expression which was guaranteed under Article 19(1)(a) of the Constitution of India.

Basically, Section 66 A of IT Act,2000 prescribes the punishment for sending obnoxious texts or messages through communication services. The offence that is prescribed under Section 66A [Punishment for sending offensive messages through communication service, etc] of the IT Act,2000 comes under the nature of cognizable offences, therefore police officers can arrest the person and start investigation without any warrant.

Because of this, throughout the country many innocent people who were publishing any objecting political view or opinion which was termed as 'obnoxious content' or 'hatred' according to the government were arrested under this section 66 A of IT Act, 2000. After this incident and protests, in the year 2013 the Union Government of India issued an notice by stating that no individual should be arrested without the prior knowledge of the superior officer, who is not below the rank of Inspector general of police.

Therefore, around ten writ petitions were filed by the people from across the country by challenging the validity of section 66 A of the Information Technology Act, 2000 under Article 32 of the Indian Constitution before the supreme court of India. The filed petitions were clubbed by the Supreme Court of India into a single Public Interest Litigation. Hence, the case was named as the Shreya Singhal v. Union of India[3]. In this case firstly Supreme Court of India issued an interim measure by prohibiting any arrest pursuant to Section 66A unless such arrest is authorized by senior police officers. Further, Honourable supreme court in the case addressed the constitutional validity of the provisions which were challenged.

Issues:

1. Whether Section 66A, 69A, and 79 of the Information Technology Act, 2000 are constitutionally valid?
2. Whether 66A of the IT Act, 2000, violates the Right to freedom of speech and expression?
3. Whether the Information Technology (Procedure & Safeguards for Blocking for Access of Information by Public) Rules 2009 and Information Technology "Intermediary Guidelines" Rules, 2011are constitutionally valid?
4. Whether Section 118(d) of the Kerala Police Act is constitutionally valid?

Arguments:
Arguments raised by Petitioner:

• The main argument from the side of petitioner was that Section 66 A of the Information Technology Act was Unconstitutional because, It is violative of right to freedom of speech and expression guaranteed under Article 19 (1) (a) of the constitution of India.
  
  • Words like 'annoyance', 'inconvenience', 'danger', 'obstruction', 'insult', 'injury', 'criminal intimidation', 'enmity', 'hatred' or 'ill- will' are all outside the purview of reasonable restrictions mentioned in Article 19 (2) of the Constitution of India.[4]
  • None of the terms mentioned in this section are defined. Further, they contended that provisions of this section are vague and uncertain therefore the innocent persons are being charged under this Section.
  • Enforcement of this Section would be an insidious form of censorship.
  • It has chilling effect on the freedom of speech and expression. Therefore, it affects the rights of viewer to access various point of views.
  • It discriminates against the users of the internet therefore; it is violative of Article 14 and 21.
  • It suffers from procedural unreasonableness.
  • There is no intelligible differentia between the internet and other mediums of communication (Spoken or written).
     
• Secondly, Learned counsels for the petitioners contended that Section 69 A of the Information Technology Act, 2000 and the Information Technology (Procedure & Safeguards for Blocking for Access of Information by Public) Rules 2009 are unconstitutional because
  
  • In the rules, no pre-decisional hearing has been provided to the originator of the information.[5]
  • Procedural safeguards which are available in Section 95 and 96 of Code of criminal Procedure are not available here.
  • Confidentiality provision affects the fundamental rights of the petitioners; therefore it is problematic.
     
• Thirdly, counsel for the petitioners argued that Section 79 of the IT Act, 2000 and the Information Technology (Intermediary Guidelines) Rules, 2011 are unconstitutional because it is vague, over broad, and violative of reasonable restrictions under Article 19 (2). During the arguments counsels criticized the Rules 3(2) and 3(4) and section 79 (3)(b) on various grounds.
   
• Further learned counsel contended that Section 118 (d) of the Kerala Police Act is unconstitutional because it is violative of rights guaranteed under Article 19(1)(a) and the provisions are outside the purview of Article 19(2) of the Indian Constitution. Further, they questioned the legislative competence of the Kerala Government to pass such an Act.

Arguments raised by Respondent:
In this case the learned additional solicitor general for the respondent effectively defended the arguments which were put forwarded by the Petitioners.

• Firstly and most importantly the constitutionality of Section 66 A of the Information Technology Act, 2000 was defended by the respondent counsel through the following arguments that:
  • The legislature is competent and is in the best position to understand the needs of the people and appreciate the needs of people. The court cannot simply strike down any law that was enacted by the legislation. The court will only interfere when a particular statute is violative of the provisions of Part III of the constitution of India
  • The mere possibility of abuse of the particular provision may not be a ground to declare a provision invalid.
  • Loose language may have been used in Section 66A to protect the people from those violating through the same medium.
  • Vagueness of the provision in itself cannot be a valid ground to declare a whole statute unconstitutional if it is legislatively competent and non-arbitrary.
  • Relaxed standards of reasonable restrictions should apply on a speech made using the medium of the internet, as the medium is different from other mediums of communication.[6]
  • Government is committed to the ensure the idea of free speech and it is assured that the government will not use statutes or provisions to curb free speech unless and until there was any misuse.
  • As enshrined in Article 13 of the constitution of India if the court is not satisfied with any provision, it may apply the Doctrine of Severability, to save a part of the particular Section.
     
• Further the Additional solicitor General defended the validity of Section 79 of the Information Technology Act,2000 and the Information Technology Rules, 2011 by arguing that it was a common practice world-wide for the intermediaries to have user agreements similar to what is stated in Rule 3(2), i.e. intermediaries will have the discretion to bring down some information on the basis of their own judgment.

Judgment:
After hearing the arguments from Petitioners and Respondent, the Court first discussed the most important three fundamental concepts in understanding the freedom of expression i.e., discussion, advocacy, and incitement. According to the Honourable Supreme Court, "mere discussion or even advocacy of a particular cause howsoever unpopular is at the heart" of the Article 19(1)(a). Court further observed that it is only when such discussion or advocacy reaches the level of incitement that Article 19(2) kicks in. [7]

1. The two-judge bench of J. Chelameswar and R.F. Nariman struck down the Section 66A of the Information Technology Act, 2000 in its entirety on the grounds that it is violative of provisions of Article 19 (1) (a), and not saved under Article 19(2).
2. Court upheld the constitutional validity of Section 69A of the Information Technology Act, 2000 and the Information Technology (Procedure & Safeguards for Blocking for Access of Information by Public) Rules 2009.
3. Further, Honourable Supreme court declared Section 79 as constitutionally valid but subject to Section 79(3)(b) being read down to mean that an intermediary upon receiving actual knowledge from a court order or on being notified by the appropriate government or its agency that unlawful acts relatable to Article 19(2) are going to be committed then fails to expeditiously remove or disable access to such material.
4. Similarly, the Information Technology "Intermediary Guidelines" Rules, 2011 has been held valid subjecting to Rule 3 sub-rule (4).
5. Section 118 (d) of the Kerala Police Act, was also struck down by the court on the grounds that it is violative of the provisions of Article 19 (1) (a) and not abiding the reasonable restrictions mentioned in Article 19(2) of the Constitution of India. Further, it has been held that this Act will fall within Entry 1 List III which speaks of criminal law and would thus be within the competence of the State Legislature in any case

Logical Reasoning with relevant case laws and legal provision:
In a democratic country like India every citizen has the right to express their views and also have right to criticize. Government policies and initiatives is also not an exception to it, the citizens have every right to express their views and criticisms to an extent. Significantly the right to freedom of speech and expression was guaranteed and protected under Article 19(1)(a) of the Indian constitution. Even the preamble of the Indian constitution ensures freedom of thought and expression.

In many of the landmark cases also honourable supreme court of India upheld the right to freedom of speech and expression. For example, in one of the oldest and landmark case of Romesh Thappar v. State of Madras the Honourable Supreme court of India held that "freedom of speech lay at the foundation of all democratic organizations."[8]

Further in the landmark case of Bennet Coleman v. Union of India, it has been held that "freedom of speech and press is the ark of the covenant of democracy because public criticism is essential to the working of its institutions."[9] But as an exception to the right to freedom of speech and expression guaranteed under Article 19(1)(a) , Article 19(2) allows the government to impose "reasonable restrictions".

Therefore, as per Article 19(2) state can enact laws to impose reasonable restrictions on the exercise of the right conferred under Article 19(1)(a) in the interests of the sovereignty and integrity of India, the security of the State, friendly relations with foreign States, public order, decency or morality, or in relation to contempt of court, defamation or incitement to an offence.[10] But this won't allow the state to completely curtail the right to freedom of speech and expression.

In many of the landmark cases supreme court of India has clarified the aspect of reasonable restrictions, for example in the case of Sakal Papers (P) Ltd. & Ors. v. Union of India it has been held that "the right of freedom of speech cannot be taken away with the object of placing restrictions on the business activities of a citizen. Freedom of speech can be restricted only in the interests of the security of the State, friendly relations with foreign State, public order, decency or morality or in relation to contempt of court, defamation or incitement to an offence.

Further that the State cannot make a law which directly restricts one freedom even for securing the better enjoyment of another freedom. All the greater reason, therefore for holding that the State cannot directly restrict one freedom by placing an otherwise permissible restriction on another freedom." [11]

In the case of Shreya Singhal vs Union of India, the supreme court of India has tried to balance between rights guaranteed in Article 19(1)(a) and reasonable restrictions under Article 19(2). In remarks of the judgment, the Supreme Court has rightly and clearly observed that "when it comes to democracy, liberty of thought and expression is a cardinal value that is of paramount significance under our constitutional scheme".[12]

Further, most importantly, the Court has provided the distinction between discussion, advocacy, and incitement and the court held that reasonable restrictions under Article 19(2) on free speech and expression may be imposed only in instances where incitement is evident. In this case constitutional validity of section 66A of the IT Act was mainly challenged because of its violative nature of right guaranteed under Article 19(1)(a) and also it falls outside the ambit of reasonable restrictions under Article 19(2).

In this case court found that section 66A is capable to limit all forms of internet communications as it doesn't "make any distinction between mere discussion or advocacy of a particular point of view, which may be annoying or inconvenient or grossly offensive to some and incitement by which such words lead to an imminent causal connection with public disorder, security of State etc".[13] Further, section 66A of IT Act fails to establish a clear proximate relation to the protection of public order.

In the landmark case of Romesh Thappar, the term public order has been defined as "a state of tranquillity which prevails amongst the members of a political society". [14]According to the Court in Shreya Singhal's case under Section 66A an offence has been committed by sending a message for the purpose of causing annoyance or insult, but the same law fails to make distinction between mass dissemination and dissemination to an individual without requiring the message to have a clear tendency of disrupting public order.

In this case difference between "Hate Speech and Fair Speech" was also highlighted and according to the Apex court "any innocent comment made by anyone whose aim is not to defame or disrespect anyone cannot fall under the ambit of hate comment."[15] With regards to the vagueness of the section 66A, the Honourable Apex court in the Shreya Singhal's case referred judgments given by U. S. Supreme Court, in series of judgments U.S. Supreme court held that:
"there where no reasonable standards are laid down to define guilt in a Section which creates an offence, and where no clear guidance is given to either law abiding citizens or to authorities and courts, a Section which creates an offence and which is vague must be struck down as being arbitrary and unreasonable."

Further section 66A is also capable of imposing chilling effect because the provision fails to define terms like inconvenience or annoyance therefore "a very large amount of protected and innocent speech" could be curtailed. Therefore, we can understand that section 66A of the IT Act, is unconstitutional. Similarly, Honourable supreme court in the case of Shreya Singhal vs. Union of India also struck down the Section 66A of IT Act and declared it as unconstitutional.

The court, however, denied the allegation of the petitioner that there is no intelligible differentia between the medium of communication through print, live, speech compared to speech on the internet. In the same case an argument was put forwarded by the petitioner's that Section 66A was in violation of Article 14 of the Constitution against discrimination but court rejected the argument and noted that the intelligible difference between information transmitted through internet and other forms of speech, which permits the government to create separate offenses related to online communications.[16]

Critical Analysis of the case:
Judgment given by Justice J. Chelameswar and R.F. Nariman in the case of Shreya Singhal v. Union of India's is a landmark one in the Indian legal history, especially after independence, that too in this recent era where the voice of the common citizens is tried to be silenced! In this case we can definitely say that the Honourable Supreme Court of India took a remarkable step in quashing the section 66A of Information Technology Act, 2000 which is essentially a censorship law.

In this landmark case section 66A was declared as unconstitutional and this landmark judgment upheld the scope of one's Right to freedom of expression guaranteed under Article 19 (1) (a) in the Constitution of India. In this case Apex court not only looked into the constitutional validity of certain sections but the court also focused on some of the other enlightening aspects like importance of the requirement of incitement and not just advocacy or discussion.

This case is an perfect example in which we can understand how acknowledgment of the gaps in the law by judiciary can lead to better and non-arbitrary legislations and how it can create a broader scope of enjoyment of one's rights. By narrowly scrutinizing the arbitrary provisions of the law the honourable Court brought about broader enjoyment of the Right to Freedom of speech and Expression.

Honestly speaking this is an enlightening judgment which explains about the various doctrines and relates those doctrine with the freedom of speech and expression. In this case Doctrine of Reasonable Restriction and Doctrine of vagueness are mainly used in order to analyse whether the provisions are constitutionally valid or not. With regards to the Doctrine of severability, this case is in an perfect and clear example.

In this case, Learned Additional Solicitor General for the respondent put forwarded the argument that "in the event of Hon'ble Court not being satisfied about the constitutional validity of either any expression or a part of the provision, the Doctrine of Severability as enshrined under Article 13 may be resorted to."[17]

But the learned solicitor failed to mention which part of section 66A can be saved further, in the case of Romesh Thappar v. State of Madras it has been clearly held that "it is not an authority for the position that even when a provision is severable, it must be struck down on the ground that the principle of severability is inadmissible when the invalidity of a statute arises by reason of its contravening constitutional prohibitions". [18]

Therefore in this case of Shreya Singhal vs. UOI also apex court held that "no part of Section 66A is severable and the provision as a whole must be declared unconstitutional".[19] Whenever the landmark case regarding freedom of speech was decided by the Supreme Court its consequences go far beyond an mere individual judgment.

It is one of the landmark and rare judgment where the Apex Court has adopted the extreme step of declaring a censorship law which was enacted by the Parliament as Unconstitutional. The Court has struck down the unconstitutional provision which tried to silence the voice of common people.

Latest Developments:
This landmark decision by the Honourable supreme court of India certainly expanded the freedom of expression by narrowly interpreting the reasonable grounds of restricting the right. Definitely we can say that this landmark case upheld the Right to freedom of speech and expression. But unfortunately there was a setback in enforcement of supreme court order which was given in this landmark case.

Because, it has been 7 year since this section 66A was stuck down. But still now in many states the police are arresting the people under this section. In this modern era where communication is easy and very fast the police officers still appear to have no information that section 66A has been has been struck down by the order of Supreme Court.

For example, two years after this verdict in march 2017, one Zakir Ali Tyagi, an 18-year-old from Muzaffarnagar, Uttar Pradesh was arrested under the Section 66A of Information Technology Act, 2000 for posting a comment on Uttar Pradesh CM Yogi Adityanath and spent 42 days in UP Jail. [20] In 2012 Prof. Ambikesh Mahapatra, Chemistry professor of Jadavpur University, was arrested under Section 66 A of IT Act.

The trial in his case is yet going on even though Section 66 A of the IT Act, was struck down.[21] In October 2018 and in May 2019 also two people were arrested and the charges were framed under Section 66A of IT Act. The two basic reasons that can be attributed to such ignorance of the law are the authorities, including the Magistrates and subordinate court judges are unaware of the recent developments in law, and unaware of recent judgments of the Supreme Court and High Courts. And most importantly, the political powers also influence authority to take steps which are in ignorance of law.

Therefore on January, 2019, People's Union for Civil Liberties who were one of the real petitioners in the Shreya Singhal Case, approached the Supreme Court by highlighting the study and applied for directions to ascertain implementation of the Court's original verdict. PUCL's lawyer argued before the court that prior to the scrapping of Section 66A, there were 229 pending cases under the section. Since then, 1,307 new cases have been registered, of which 570 are still pending. [22] In a counter-affidavit, the Union of India put forwarded comprehensive steps it had taken to make awareness on Section 66A.

This included a letter the Government wrote on 11th January, 2019 and then a remembrance on 14th January, 2019 to different state governments asking them to present data on Section 66A cases and also asking them to close them. But only some states answered. The Supreme Court on August, 2021 issued notices to all states, Union territories and registrars general of High Courts on a plea highlighting continued use of Section 66A of Information Technology Act even though it was held unconstitutional by the court in 2015.

"This cannot continue," the court said further. The Centre also said that both the Ministry of Electronics and Information Technology (MeITY) and the Home Ministry had written to chief secretaries of states, administrators of Union Territories and DGPs of states and UTs, asking them to sensitise LEAs and direct the police not to register cases under the quashed provision.[23]

Further, Apex court in this case upheld the constitutional validity of Section 69A of the Information Technology Act. 69A (Power to issue directions for blocking for public access of any information through any computer resource). Therefore, in the February, 2021 Ministry of Electronics and Information Technology (MeitY) ordered blocking of certain Twitter accounts and tweets under Section 69A of the Information Technology Act.

Before this step by MeitY in February 2019 itself, Jio users were unable to access certain sites like Indian Kanoon, Reddit and Telegram because all of which were blocked based on the government orders under the section 69A. Most importantly in the year 2020, 59 Chinese apps, including TikTok, and Cam Scanner, were blocked under this section. [24] But from my aspect and recent incidents chances are there for misuse of this Section 69A, because it has been and it can be used as a tool to silence the voice of citizens!

Conclusion:
Because of numerous reasons, Shreya Singhal vs. Union Of India (U.O.I) is one of the landmark and significant judgment with regards to the freedom of speech and expression in the history of Indian Legal System. In this case, Honourable supreme court effectively protected the rights of people as well as safeguarded the interest of society.

The Judgement given by Honourable Judges J. Chelameswar and R.F. Nariman not only upheld the fundamental right of citizen to freedom of speech and expression but certainly expanded the limits for freedom of speech and expression. In a way we can say that this judgement, is a turning point for Article 19(1)(a) because everyone has a right to express their political opinions without any fear of having any arbitrary and unreasonable restrictions.

But even though, Section 66A of the IT Act, 2000 has been struck down by Supreme Court's Order dated 24th March, 2015 numerous cases has been filed against the innocent people under Section 66A. Police officers and even subordinate court judges were not aware of this supreme court's order.

Therefore, state must take effective actions without merely providing circulars to the Higher officials. Then only this landmark judgment can be practical and fruitful. Even thousand culprits can escape, but, one innocent person should not be punished! As a whole this is one of the enlightening case. And the landmark judgment is really appreciable and most importantly it upholds and increases the people's trust on Judiciary!

References:

1. https://globalfreedomofexpression.columbia.edu/cases/shreya-singhal-v-union-of-india/
2. https://indianexpress.com/article/explained/explained-the-shreya-singhal-case-that-struck-down-section-66a-of-it-act-7408366/
3. https://www.thehindu.com/opinion/lead/The-judgment-that-silenced-Section-66A/article59870557.ece
4. https://www.mondaq.com/india/it-and-internet/451642/impact-of-shreya-singhal-judgment-on-intermediaries
5. https://theprint.in/theprint-essential/all-about-section-69a-of-it-act-under-which-twitter-had-withheld-several-posts-accounts/597367/
6. https://catalystsforcollaboration.org/case-study-singhal-v-union-of-india/
7. https://www.commoncause.in/pdf/Draft-o-d-7.pdf
8. https://indianlawportal.co.in/shreya-singhal-v-union-of-india-2/
9. https://rmlnlulawreview.com/2019/06/23/shreya-singhal-case-and-its-enforceability-a-failed-attempt-by-the-supreme-court-to-save-freedom-of-speech-and-expression/
10. https://cis-india.org/internet-governance/blog/shreya-singhal-judgment.pdf
11. https://www.scconline.com/blog/post/tag/shreya-singhal-case/
12. https://www.thenewsminute.com/article/who-went-court-against-draconian-sections-it-act-21989

End-Notes:

1. Shreya Singhal v. Union Of India, AIR 2015 SC 1523.
2. Information Technology Act, § 66 A, No. 21, Acts of Parliament, 2000 (India).
3. Shreya Singhal v. Union Of India, AIR 2015 SC 1523.
4. Para 3 of Shreya Singhal vs. Union Of India (U.O.I)[AIR 2015 SC 1523]
5. Para 108 of Shreya Singhal vs. Union Of India [AIR 2015 SC 1523].
6. Para 27 of Shreya Singhal vs. Union Of India (U.O.I)[AIR 2015 SC 1523].
7. Para 3 of Shreya Singhal vs. Union Of India (U.O.I)[AIR 2015 SC 1523].
8. Romesh Thappar v. Madras, (1950) S.C.R. 594.
9. Bennett Coleman & Co. v. Union of India, [1973] 2 S.C.R. 757.
10. INDIA CONST. art. 19, cl. 1.
11. Sakal Papers (P) Ltd. v. The Union of India, (1962) 3 S.C.R. 842
12. Shreya Singhal vs. Union Of India (U.O.I) AIR 2015 SC 1523.
13. Para 20, Shreya Singhal vs. Union Of India (U.O.I) AIR 2015 SC 1523.
14. Romesh Thappar v. Madras, (1950) S.C.R. 594.
15. Shreya Singhal vs. Union Of India (U.O.I) AIR 2015 SC 1523.
16. Para 98, Shreya Singhal vs. Union Of India (U.O.I) AIR 2015 SC 1523.
17. Para 93, Shreya Singhal vs. Union Of India (U.O.I) AIR 2015 SC 1523.
18. Romesh Thappar v. Madras, (1950) S.C.R. 594
19. Para 96, Shreya Singhal vs. Union Of India (U.O.I) AIR 2015 SC 1523
20. Zakir Ali Tyagi v. State of UP
21. Ambikesh Mahapatra &Anr vs State of West Bengal &Ors.
22. THE WIRE, https://thewire.in/rights/mamata-banerjee-cartoon-section-66a-it-act, (March 12, 2022).
23. THE INDIAN EXPRESS, https://indianexpress.com/article/india/sc-notices-states-uts-high-courts-section-66a-of-it-act-7434332/, (last visited March, 12, 2022).
24. All about Section 69A of IT Act under which Twitter had withheld several posts & accounts, THE PRINT, https://theprint.in/theprint-essential/all-about-section-69a-of-it-act-under-which-twitter-had-withheld-several-posts-accounts/597367/, (last visited March 12,2022).