Media is the fourth pillar of every democracy in the world. It is not gives voice to voiceless but power to powerless. In a democratic country like India, media plays a cardinal role in uplifting the concerns of general public, asking critical questions from the government, fixing transparency and accountability and so on.

News pertaining to the critical issues like employment, women safety, economy, education, health constitutes the content which every citizen of this country should consume for the smooth running of the democracy. Sometimes government tries to hide their mishandling or malfunctioning of the crises from the citizens, it is the media which bring everything in front of the general public through their unbiased reporting.

Now a days due to the exuberant increase in the crime rate and several critical news goes unnoticed by the general public and media through its unbiased reporting brings that news in the mainstream. But sometimes media tends forgets its responsibilities and resort to malpractices. To create sensationalism, they start spreading misinformation (fake news) and astray the public. They are often found doing biased reporting, (showing the arguments of one side).

They connive with the powerful people and political parties and advocate their propaganda to befool the public. They also hide several important issues from the public by engaging the public in nonsense debates and raising absurd questions. The research paper attempts to scrutinize the quality of news disseminated to the general public, Freedom of free speech and expression, press freedom, manipulation of news and how it affects the working of a democracy. This paper attempts to give a holistic view of quality of news before and after rise of misinformation.

Introduction
Publication of genuine facts is the quality content which every individual should consume. It can be done through various forms such as print (oldest form), television, radio, and the internet(newest form) Evolution of media finds its origin back in the ancient times where the imperial powers or kings use to dominate and oppress the poor people. The French Revolution witnessed the rise of newspapers because of the economic, social and financial crises through which the poor people were suffering.

The newspapers depicted the day to day events of France which proved to be an important step in enlightening the masses. Dissent, equality and fraternity were the popular ideas which were widely published during that time. During the British Raj, where there were no radio and television, it became imperative for the wise people to disseminate information to the general public through newspapers.

Many newspapers were started by the influential people and freedom fighters to report the oppression of Britishers upon the poor people of India. In 1881, Lokmanya Bal Gangadhar Tilak, one of the prominent freedom fighter of our country started a Marathi newspaper called Kesari, to inform about the freedom movements and to gain support from the masses[1].

In 1780, James Augustus Hicky started a two-sheet newspaper called The Bengal Gazette, which depicted the private lives of officials of the company.[2] Other prominent newspapers which were stated during the struggle of the independence were Sambad Kaumudi founded by Raja Ram Mohan Roy in 1821, Bhahiskrit Bharat founded by B.R Ambetkar in 1927, National Herald started by Jawaharlal Nehru in 1938 and so on. [3]

This research paper aims to find out cardinal and conducive news dissemination by media houses which nurtured the Indian democracy, how media gets involves in propagating misinformation ,the emergence of misinformation, how media gets involved , misinformation in India, legal provisions for curbing misinformation and news dissemination v news manipulation. It focusses upon the critical questions like news manipulation, irresponsibleness shown by the media and media becoming a medium for spreading propaganda and hate speech.

Research methodology
This paper is of comparative nature and the research is based on secondary sources. The scholar shall be comparing the situation of news prior to the emergence of misinformation and aftermath. Secondary sources of information like newspapers, cases, and websites are used for the research.

Review of literature
After the oppressive British Raj, the founding fathers of our constitution imparted us six guarantees in the form of fundamental rights. One of which is Freedom of free speech and expression enshrined in Article 19 (1) (A) in the constitution of India. This fundamental right guarantees us free speech and expression which includes right to know, right to hold demonstration/ strikes, right to reply, press freedom etc.

Press freedom is not categorically mentioned in the constitution of India but it flows from article 19 (1) (a) and that's why we don't have any separate right/ article for freedom of press. This was the contention of Dr. B.R Ambetkar during the constituent assembly debates. This was adopted from the first amendment of the US constitution. [4]

In Express Newspaper V UOI [5] it was held by the apex court that, the freedom of press is hidden within the horizon of article 19 (1) (A) of the Indian constitution. In the case of Bennett Coleman v UOI,[6] the cardinal role of media in nurturing the Indian democracy and its living constitution was depicted. The petitioners were involved in the publishing the newspapers.

They challenged the validity of two governmental orders encompasses in the Newsprint Policy of 1972-73 namely, Import Control Order of 1955 which imposed restrictions upon the import of the newspapers and Newsprint Order of 1962 which limits the number of pages in a newspaper. Key questions were raised before the Supreme Court was that, whether these governmental orders infringes Article 19 (1) (A) of the Indian constitution?

The court admitted that the contentions raised by the petitioners that these orders of the Newsprint Policy of 1972-73 will have significant effect on free speech and expression The court in this case said that the suggested restrictions imposed upon the import, regulation and acquisition of newsprints are not feasible and the page cap will decline the earnings of the newspaper which will lead to an increase in the price of the newspaper, and owing to this accumulation in price, people will cease to buy the newspapers which will also result in reduced circulation of newspapers.

Therefore the court declared the Newsprint Policy of 1972-73 as ultra vires to the constitution. In 1960, Central government passed an act called Daily Newspaper (price and page) Order, which empowered the Central government to control the number of pages in the newspaper in accordance to the price paid. This government act was challenged in the case of Sakal paper Pvt Ltd v UOI [7]. Court declared this act as null and void because it not only violated Article 19 (1) (A) of the constitution of India but also Article 19 (2).

After independence media has evolved in its own way. Over the time it became a watchdog for the government and a link between the general public and the administration. It started exposing corruption, mishandling and malfunctioning of the government and also raised critical issues which concerns the general public. Through there unbiased reporting and meaningful news, they enlightened the masses and shaped public opinion. After Additional Sessions Judge of Delhi trial court acquitted all nine accused in Jessica Lal murder case owing to the ballistic report and hostile witnesses, it triggered public furor.

Widespread protest were held in the capital city and people demanded justice for Jessica Lal. Then the strong and gutsy media came into action. Loopholes of the trial was exposed by the famous news magazine called Tehelka. Many string operations were conducted upon those who turned hostile during the court proceeding owing to bribery and upon those people to whom threats of dreadful outcomes were given. Voice recording of the main accused was leaked who demanded alcohol from Jessica Lal and upon refusal in fit of rage, he short her dead.

Amidst this, public pressure also build up and a SMS campaign was launched, demanding justice for Jessica Lal. As a result of this, police filed an appeal before the High Court of Delhi[8]. The horrific Nirbhaya Rape case which took place in 16 December 2012, shocked the entire nation and triggered widespread public protest in the capital city. People were protesting in front of India Gate and were demanding justice for Nirbhaya. This case soon became the focus of the media coverage.

This was extensively covered by print, electronic and social media. After the intensive public outcry, media started to build pressure upon the administration and demanded the delivery of justice. This horrific incident changed the mindsets of the people. People in India will no longer willingly accept rape and molestation as 'normal' and demanded changes in the criminal law. The media advocated the voice of the public.

Prominent newspapers like, The Times of India, The Hindu, Hindustan Times, The Indian Express and others constantly published and supported protest movement among the masses through print and electronic version. Social media was utilized to gain support for the protest movement. People started expressing their frustration on the administration through Facebook, Twitter and other social media platforms, owing to which huge crowds of protestors taking to the streets gave an explicit indication that they extend their support to the victim and demand justice for her. [9]

In the above two examples, the news coverage was not only revealing and conclusive but also it shaped public opinion. On one hand the media through its braveness exposed the loopholes of the trial, and on the other hand, it demanded justice for the victim and convinced the Indian society to change the perception of not accepting rape and molestation as 'normal' and demand amendments in the criminal law. In both the cases news presented by the media was legitimate, fact based, revealing, and conclusive. They neither crossed any of their limits showing irresponsibleness nor did they try to create sensationalism. Whatever they did were in accordance to the ethics of journalism.

Emergence of fakeness

The emergence of fakeness of news can be traced from the inception of the printing press. Nazi Germany under the leadership of Adolf Hitler, launched its propaganda to defame the Jews. The propaganda often spread misleading information about the Jews. His ministry was so skilled that they effectively gained support from the masses and made Jews as Germany's enemy. German propagandist persuaded German soldiers to believe that Jews are the threat to their homeland that they will one day take over their country. This feeling accelerated their anger towards Jews and wanted their total annihilation.[10]

Legitimate and conclusive news always been a part of Indian media, but a trend of spreading misinformation has emerged in past few years. To create sensationalism and to increase TRP, media houses often disseminate misinformation to the general public, make baseless scurrilous allegations upon rival politicians, celebrities, and businessman etc. Sometimes in order to win elections, media houses disseminate misinformation against their rival candidates and make hate speeches to communalize the election atmosphere. Media houses are also found reporting prejudicially, helping the ruling government to advocate its propaganda, brainwash the innocent public and target minority groups. These all activities gave rise to misinformation popularly known as misinformation.

How Media gets involved?

Media became a medium for the propagation of misinformation in a country there here is a strong parliament, president, prime minster/chancellor, such situations are bound to be happened. The first step of taking off a country is to bring media under control and give them the orders of only praising the supreme leader.

The supreme leader became almost unlimited in a country with weak or without opposition, where elections are conducted on the regular basis but they are not free and fair, where media is reporting but reporting biasness, where politician of the opposition party are targeted or is booked in bogus cases etc. such countries are highly susceptible by the attack of misinformation. Let's fathom this with an example of Russia.

The constitution of Russia declares Russia as a democratic state with a republican form of government where president is the head of the state. [11]The Russian president Vladimir Putin had amended the Russian constitution in such a way that he will remain in power for next fourteen years .i.e., till 2036. He is all set break the record of Joseph Stalin who was the longest serving president of Russia. Ideally, Putin would have been barred by the previous 1993 constitution if this amendment would have not taken place. [12]

The health of democracy in Russia is deteriorating, Democracy is breathing with much difficulties. It was alleged by the leader of the opposition Alexei Navalny that Russian government poisoned him with a deadly chemical because he expressed his displeasure over Putin coming to power. However the government refused such allegations. Most of the media channels are directly or indirectly controlled by the government, in fact the two biggest Russian news agencies are under the clout.

Now the news channels are showing the 'macho man 'image of the president, showing his martial skills, his love for animals and labelling every success or failure of the government as a masterstroke. [13] Few media houses are left who work independently in digital media but they are also under attack. Sometimes bogus terrorism charges are levelled or sometimes it is sedition. Heavy crackdown on dissent with the help of police which results in police brutality.[14] Strict laws are enacted to control people in internet.

Such a law was enacted in 2014. [15] Human rights group called it a 'draconian law'. NHO's, were also targeted.[16] In 2005 it started. Every NGO was required to submit their project details before the government registration office and because of the ambiguity in the law office will tell the NGO's which project is in the interest of the nation and which not. Even the judiciary was not spared.

In every drowning democracy judiciary is the last hope of the citizens but this organ was also compromised in Russia. The situation of the country is sending strong signals of electoral autocracy to the entire world. Everyone was targeted by the government. If media had raised critical questions from the very beginning then this situation would have been avoided. The citizenry is brainwashed by the puppet media and the misinformation spread in all directions.

The media all times shows Russians that how president is working so hard for the welfare of its citizens while managing the hostility from USA and its allies. Every week a program is aired off which act as a guide and constructs a world in which the government wants the people to live in. [17] Maybe these are the causes that how gradually all the constitutional institutions were compromised and the citizens forgot to ask critical questions from the government. But how could they do this, they were living in a utopian world!

Misinformation in India

Misinformation is not new to India. It emerged long ago before becoming rampant somewhere post 2014. In 2004, information was spread about the now Congress president Sonia Gandhi that she was a bar dancer before entering the Indian politics. However at multiple occasions it was cleared that she worked at bars not as a bar dancer but was doing a part time job. The facts were distorted in such a way as to portray Sonia Gandhi as a bar dancer. [18] So many photographs of Sonia Gandhi are photo shopped to make her appear as a bar dancer. [19] Even on her birthday derogatory hashtags are made to lower her dignity. [20]

Basically, a character assassination is done. These types of activities not only reveals the misogynistic mindset of politicians but also has the potential of destroying a person's life and dignity. In 2016, we have seen the same in the form of Nano GPS Chip (NGC) attached to new notes at the time of demonetization, but became a trend post 2019. [21] Dissemination of manipulated media became a new normal in new India. Whatever news comes to the general public they accept it on the face of it without thinking critically or rationally.

Brainwashed people are more vulnerable to this new trend of misinformation and manipulated media because they have completely lost their sense of rationality and are now the blind followers of a political party, political leader, celebrity etc. In India social media platforms like WhatsApp, Twitter and Facebook have emerged as a medium for spreading misinformation, hate speech and bigotry comments.

WhatsApp, mockingly known as WhatsApp University is a platform most susceptible to misinformation and people who are consuming the content of WhatsApp forwards are more likely to get brainwashed. Misinformation spread through these platforms is a concerning threat to our society. This builds up an atmosphere of terror, hatred and violence which causes riots and lynching in every nook and corner of this country. Defamatory comments targeted to one religion, sect, and religious practice often ends up with hatred and violence.

There are age old fault lines between Hindus and Muslims. Propagators of misinformation widens these fault lines to create communal tensions between the two communities which creates an atmosphere of hate. Propagators of misinformation also keep the general public way from the foundational issues of their concern like of fuel prices, woman safety, education, health etc. and convince the masses that everything is under control. It is often seen that the ruling government does this through their IT cell to hide their malfunctioning and mishandling of the issues.

It is also seen that government does so to save its reputation , to show to the general public that they are also the ' victim' of that crises or tries to falsely link a person /religion to the cries by unrelated old stories. Misinformation is also propagated to increase the fan following. Film stars, businessperson, political parties and political leaders often use these tactics by publishing manipulated Media and false surveys. During election season, misinformation and manipulated media are at its zenith.

Scurrilous comments are made by the contesting candidate against his / her rival candidate, bigotry comments and slogans are raised against a religion to create communal tensions between communities and so on. We have witnesses this in the recent Bihar and West Bengal assembly elections, were social media was flooded with misinformation and manipulated media by the contesting and rival candidates.

In 2013, a fake video was circulated in the town of Muzzafarnagar, where in two youths belonging to the majority community(Hindu) were brutally killed after they reportedly killed a youth belonging to the minority community (Muslim). This video fueled communal tensions between Hindus and Muslims, resulting in riots in the town of Muzzafarnagar, UP. Police said that this video is most likely to be short in Pakistan which is available in the internet for last two years. Approximately fifty people died in these deadly riots which erupted on 7th September 2013. [22]

A religious congregation was organized amidst the pandemic by a Muslim sect known as Tablighi Jammat in Delhi's Nizamuddin area which was attended by at least 16,500 people who were found to be infected by corona virus. This congregation became the focal point for the media coverage. [23]

Various misleading, unrelated and manipulative information was spread to dishonor the congregation and the Muslim community. Conspiracy theories and misreporting were at apostle. Social media was flooded with the misleading information and manipulative media that only talked about the Jammatis and hold them responsible for the spread of corona virus. The people associated with this congregation were called as 'super spreaders' and were blatantly censured for the super spread of the corona virus.

Highly intolerant words like 'Corona Jihad' and 'Tablighi Virus' were used by the media houses to dishonor the congregation and the Muslim community. Newspapers like Amar Ujala, reported a false claim that the Jamaatis asked for non-vegetarian food.

Upon refusal, they threw way the food and defecated in open at the quarantine center in UP's Saharanpur. An old video was aired by India TV, a news channel that claims that the Maulana is advocating to spit on people to infect them with corona virus. A footage was played in a highly disrespectful manner with obnoxious music. Pakistan was also dragged into this. [24]

A news channel called News18 India, claimed that, it was Pakistan's conspiracy to spread corona virus in India. The channel said that the information was supplied to them by the 'intelligence sources' that the congregation was organized at the behest of Pakistan. Amidst this, several old video clips were widely circulated through WhatsApp to defame the Muslim community.

An old video clip claiming that a fruit vendor in the state of Madhya Pradesh is licking his fingers while handling the fruit went viral, an old video was shared claiming that Muslim owned restaurants are spitting in food. Another video which went viral on social media where the Muslim men in Hazrat Nizamuddin mosque in Delhi were deliberately sneezing in open to spread the virus and so on.

These misleading information not only crated hatred towards the Muslim community but also tainted India's reputation in the world. A video of parliamentary proceeding in Pakistan was shared by news channels like Times Now and India TV and other social media handles, where they falsely claimed that the parliamentarians are sloganeering 'Modi Modi'.

This misleading information was deliberately spread through masses to increase the fan following of Narendra Modi, and to tell the country the influence of Narendra Modi and that even the Pakistani parliamentarians wants a leader like him. [25]

In June 2020, the terrible news of the death of a pregnant elephant in Kerala, also fell into the trap of misinformation. Several media outlets like, Times Now, Hindustan Times, Financial Express, ANI, Republic, NDTV, India Today and DNA reportedly changed the place of incident from Palakkad to Malappuram (a Muslim dominated district in the state of Kerala) and reported that, in Malappuram, the pregnant elephant was deliberately fed with a pineapple laden with explosives to communalize the issue.

Consequently, social media was flooded with bigoted comments and targeted the Muslim community. [26] The farmers' protest and the Lakhimpur Kheri incident and the associated misinformation are some of the recent examples that are still fresh in our memories. In farmer's protest, the participating farmers' are labelled as "Khalistani" and "tuke tuke gang" where as in Lakhimpur Kheri incident they are accused of stone pelting.

Cost of Fakeness

There are countless repercussions of propagating misinformation or fake news. An individual will cease to think rationally and sensibly after the consumption of misinformation. People will accept everything on its face value and will stop thinking critically. They can be easily brainwashed and can be made fool at any time by anyone. This behavior won't shape public opinion. People will state giving illogical arguments to every legitimate and concerning issue.

Recently a local BJP leader was asked about the skyrocketing fuel prices. The leader said that it's good that people will now use cycles and will stay fit. This shows that even the local leaders are brainwashed and are not having concrete answer to the question. The escalating intolerance and communal tensions owing to misinformation or fake news is of serious concern.

We witnessed the same in Tabligi Jamaat issue. As the news of this congregation broke out, everyone started slamming the Jammatis and were targeting the Muslim community. Propagators targeted the community by using highly bigoted terms. Social media was flooded with manipulative media and hateful comments.

This shows that we are highly intolerant against the minority Muslim community. This behavior of ours send a signal to the entire international community about the growing intolerance in India, thanks to our media. Building false narratives against Muslim community is one of the causes of Islamophobia in India. [27] These misinformation keeps an individual away from the ground realities.

Recently the PM Modi visited the Unites States and after his return, a tweet went viral that the New York Times has published a giant photograph of PM Modi on its front page saying him the last good hope on earth. Certainly, this was not the reality. Propagating misinformation not only tarnishes country's image but the image of an individual as well. Take the tragic suicide case of Sushant Singh Rajput. He and his girlfriend Rhea Chakravati were targeted by the media and countless misinformation were propagated.

Images of Sushant's dead body were released by the media. Various scurrilous comments were made against his girlfriend. It is quite evident that there are various implications of propagating misinformation whose cost the nation is bearing. The entire international community is watching the circus going on in our country and that is why various MNC's are reluctant to invest in India. Spreading misinformation extensively not only creates a rift between communities, but is also tarnishing India's image globally.

International media houses are taking cognizance about the rising intolerance in the country
Which makes it worse for investment by MNC's or for setting up a unit in India. India's position has begun to slip in various International indices, be it press freedom report, democracy index or the latest hunger index report in which India slipped to 101st position and the situation of hunger in India is termed as 'alarming'. [28] These are some of the serious concerns upon which India should introspect.

Curbing Misinformation in India

As of now, we don't have any specific legislation against misinformation in India. Press freedom flows from Article 19 (1) (A) of the Constitution of India guarantees freedom of speech and expression. Therefore the menace of misinformation or fake news can be curb through indirect means which are as following:

1. Press Council of India, a regulatory body, which can admonish, censure or warn the news agency, newspaper, the journalist or the editor or can disapprove the conduct of the journalist or the editor if it finds that the new agency or the newspaper has violated journalistic ethics.
    
2. News Broadcasters Association (NBA) represents the private television news and current affairs broadcasters. The self-regulatory body probes complaints against electronic media.
    
3. Indian Broadcast Foundation (IBF) also looks into the complaints against contents presented by news channels.
    
4. Broadcasting Content Complaint Council (BCCC) accepts complaints against Television broadcasters for objectionable Television content and misinformation.
5. Indian Penal Code (IPC) has certain sections which can be invoked to curb this menace of misinformation: Sections 153 (wantonly giving provocation with intent to cause riot) and 295 (Injuring or defiling place of worship with intent to insult the religion of any class) can be cited to guard against misinformation.
    
6. Civil or Criminal Case for Defamation is another resort against misinformation for individuals and groups hurt by the misinformation. IPC Section 499 (defamation) and 500
    
7. Information Technology Act, 2000- Section 66 of IT act says, if any person, dishonestly or fraudulently, does any act referred to in section 43 (damage to computer, computer system), he shall be punishable with imprisonment for a term, which may extend to three years or with fine, which may extend to five lakh rupees or with both. [29]

News dissemination v news manipulation

News dissemination is defined as the process where the information is collected, selected, is transformed into meaningful news and then it is spread to the audience. Here the news which is spread is genuine, fact-checked, legitimate and pertinent to the common citizenry. News manipulation is defined as an artistic way of twisting the facts in order to manipulate the common citizenry. News manipulation is a new type of news dissemination which is very prevalent in India.


These days this way of news dissemination not only disseminates the misinformation and manipulated media, but also the hidden agenda of manipulating the common citizenry is fulfilled. The sad part is that, both of them go side by side and therefore it becomes very difficult to detect misinformation and genuine news.

Suggestions:
Misinformation or manipulated news or fake news is not new to us, in fact it all started from the inception of the printing press. But at those times there use to be kings/queens/dictators who were having absolute powers and therefore they do things according to their whims and fancies. But today were more than half of the countries are democracies, [30] media should be made independent and responsible. There are countless damages that can be caused owing to the propagation of misinformation or manipulated media and this should be curbed to improve the tranquility in the society.

Few small things can give us a relief from the misinformation by using credible sources of information like wire, scroll and the print, fact checking websites like alt news can be used. Before believing in any news, verify the news through multiple sources, verify the publisher and think wisely before you believe and share. Don't trust blinding upon the WhatsApp forwards as almost every information spread is either manipulated or fake .enlighten your friends and family members to stop consuming the news from the mainstream media also popularly known as Godi media.

These steps can be taken from an individual's side. Steps which government can take is making media accountable for every biased reporting made by them. People should be discouraged from posting news and media whose authenticity is unknown, political parties and leaders should not make any scurrilous remark against anybody without any concrete evidences, any person who violates the social media guidelines must be prosecuted , malicious prosecution should not be initiated against journalist and concerned citizens who raises critical questions and media house should not publish or air any news content which not fact checked and religiously sensitive. Social media through its reach can start a campaign of making people aware about fake news.

Celebrities can be employed for the same. With their charisma they can influence the masses. Long story short, the menace of misinformation in the country must be solved by hook or by crook, otherwise this menace will one day eat up the entire nation.

Conclusion
After discussing so much about misinformation in this paper, one thing is crystal clear that the problem of misinformation is deep rooted and we as society have to cut this root as soon as possible. This problem can be reduced if people were aware. But in the quest of curbing misinformation we should not forget to respect an individual's freedom of speech and expression. We cannot put every person/journalist/media organization behind the bars upon the suspicion that these people are propagating misinformation.

Right to free speech and expression is most abused in recent times, be it the case of CAA protest, issue in JNU and Jamia Milia Islamia, tragic suicide of actor Sushant Singh Rajput, the Tabligi Jammat incident, farmers' protest etc. everywhere news channels, social media was replete with misinformation and the government's reaction in these cases shows us that, even the government does not want to stop the spread of misinformation, because it provides edge to them.

Today people have lost their rationality and their thinking ability because of the fact that they are so engrossed with misinformation and manipulative media that they have forgotten to question the government regarding critical issues. Many people are highly brainwashed that they can't abide a single word against the person to whom they admire the most and the religion which they follow.

Youngsters too are misled by spread of misinformation, that they can be easily brainwashed and manipulated to wage a war against those who are the foes of their motherland or religion. The Hijab controversy is a very good bad example to this The bitter truth of today is that, the people who are the propagators of misinformation, manipulative media and hate speeches are the either religious leaders, political leaders or the elected government.

The sad part is that the administration itself wants the citizenry to sink in the ocean of fakeness, so that they can fulfill their agendas. Agendas like creating a rift between religiously sensitive communities, winning elections, building false narrative against the targeted person, instigating people to commit violence against minorities etc.

It has now became imperative for the government and our policy-makers to fathom the potential damages caused by the violent spread of misinformation which is not only creating a situation of raucous in our country , is promoting hate amongst people but is also pulling off our country from making progress.

People are so engrossed in this nonsense that they don't demand a school, a college, a hospital and women's safety. What they demand is temple, total annihilation of Muslims, declaring the citizens of the country as terrorists and so on. Everyone is responsible for curbing misinformation in India ranging from an ordinary man to the government of India.

Then only we can actually curb his menace and can shape public opinion. Along with this, the need of the hour is a good and strong legislation to stop the menace of misinformation and to punish the violators.

End-Notes:

1. Kesari (newspaper) available at: https://en.wikipedia.org/wiki/Kesari_(newspaper) , visited on 18 Oct 2021
2. History of mass media in India, available at: https://www.nimc-india.com/history-mass-media-india.html , visited on 18 Oct 2021.
3. Important Newspapers during Indian Freedom Struggle, available at: https://byjus.com/free-ias-prep/important-newspapers-during-indian-freedom-struggle/ , visited on 18 Oct 2021
4.  Manmeet Singh ," Freedom of Press – Article 19(1)(a)", Legal Services India .com , http://www.legalservicesindia.com/article/1847/Freedom-of-Press---Article-19(1)(a).html
5. (1985) 2 S.C.R 287
6. 1973 AIR 106, 1973 SCR (2) 757
7. 1962 AIR 305, 1962 SCR (3) 842
8. Gaurav Prakash and Raj Tomar, "Jessica Lal murder case: The epitome of judicial and media activism in India", IP Leaders, (last modified on 5 Aug 2020) https://blog.ipleaders.in/jessica-lal-murder-case-the-epitome-of-judicial-and-media-activism-in-india/
9. Rishikesh Kumar Gautam1 & Sonalee Nargunde, 'The Delhi Gang Rape: The role of Media in Justice', (2014) 1(8) International Journal of Research (19 Oct 2021)
   https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.671.3395
10. Timothy Snyder,' How Hitler Pioneered 'Misinformation ', The New York Times (Oct. 16, 2019) https://www.nytimes.com/2019/10/16/opinion/hitler-speech-1919.html (assessed on 19 Oct 2021)
11. The Wire, Russia," Vladimir Putin Signs Law allowing Him to Rule Till 2036", https://thewire.in/world/russia-vladimir-putin-signs-law-allowing-him-to-rule-till-2036 ( last visited at 20 February 2022)
12. Wikipedia , https://en.wikipedia.org/wiki/Politics_of_Russia ( last visited at 20 February 2022)
13. BBC News , "Russia Navalny: Poisoned opposition leader held after flying home " https://www.bbc.com/news/world-europe-55694598 ( last visited at 20 February 2022)
14. Ilya Klishan ,' Russia's independent media is under attack as Apathy reigns", The Moscow Times, https://www.themoscowtimes.com/2020/04/27/how-censorship-leads-to-emotional-numbness-a70116
15. BBC News , https://www.bbc.com/news/technology-28583669 ( last visited on 20 February 2022)
16. Human Rights Watch , https://www.hrw.org/news/2005/12/27/russia-amended-law-threatens-ngos ( last visited on 20 February 2022)
17. NPR , https://www.npr.org/2021/05/15/996795292/russian-show-fake-news-wages-lone-battle-against-the-kremlins-tv-propaganda ( LAST visited on 20 February 2022)
18. Kumar Ketkar ," BJP's leaders have frequently described Sonia Gandhi as 'barmaid' and 'waitress'" The Print , (28 November, 2017 04:58 pm IST), https://theprint.in/talk-point/bjp-leaders-have-described-sonia-gandhi-as-barmaid/18963/
19. The Free Press Journal , https://www.freepressjournal.in/india/shocking-google-shows-cong-president-sonia-gandhis-pictures-when-you-search-italian-bar-dancer (last visited on 23 February 2022)
20. Devyani Madaik, "#BarDancerDay Tends on Twitter on Sonia Gandhi's birthday. Here's why it is wrong " The Logical Indian (9, Dec, 2020,7:35 PM), https://thelogicalindian.com/trending/bardancerday-trends-on-twitter-on-sonia-gandhis-birthday-heres-why-it-is-wrong-25342
21. Zee news editor (Sudhir Chaudhary) is telling about Nano GPS chip in 2000 notes available at: https://saafbaat.com/economy/demonetisation-tughlaqi-firman/attachment/zee-news-editorsudhir-chaudhary-is-telling-about-nano-gps-chip-in-rs-2000-note-fake-news-8eed4hrkmxm (assessed on 19 Oct 2021)
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25. Archis Chowdary,' Did Pak MPs Chant 'Modi Modi' In Parliament? No, they're chanting 'Voting', Boom (29 Oct 2020 4.40 pm) https://www.boomlive.in/fake-news/did-pak-mps-chant-modi-modi-in-parliament-no-theyre-chanting-voting-10406 (assessed on 20 Oct 2021)
26. Sumit Usha,' Tragic Death of Pregnant Elephant in Kerala Fuels Bigotry, Disinformation', Boom (4 June 2020 1.14PM) https://www.boomlive.in/fake-news/tragic-death-of-pregnant-elephant-in-kerala-fuels-bigotry-disinformation-8373 (assessed on 21Oct 2021)
27. Stuart Chambers,' Islamophobia in western media is based on false premises ', The Conversation (January 22, 2021 4.57am) https://theconversation.com/islamophobia-in-western-media-is-based-on-false-premises-151443 (assessed on 20 Oct 2021)
28. India slips to 101st rank in global hunger index 2021 available at: https://www.thehindubusinessline.com/news/world/india-slips-to-101st-rank-in-global-hunger-index-2021/article37004547.ece , last updated on October 15, 2021
29. The Problem of Misinformation in India: Issues, Concerns and Regulation available at: https://www.drishtiias.com/pdf/1584990847-the-problem-of-fake-news-in-india-issues-concerns-and-regulation.pdf , visited on 21 Oct 2021
30. Drew Desilver,' Despite global concerns about democracy, more than half of countries are democratic' Pew Research Centre (May 14, 2019) https://www.pewresearch.org/fact-tank/2019/05/14/more-than-half-of-countries-are-democratic/ , visited on 26 Oct 2021.