SEC.124A, IPC,1860: A DOGMATIC ATTEMPT TO …iclrq.in/editions/jul/3.3.pdfIndian Constitutional Law Review | Edition III (July 2017) Published by Agradoot Web Technologies LLP 24 SEC.124A,

Indian Constitutional Law Review | Edition III (July 2017)

Published by Agradoot Web Technologies LLP 24

SEC.124A, IPC,1860: A DOGMATIC ATTEMPT TO CURB

DISSENT

Akshay Sharma & Lavanya Pathak

Students, National University of Study and Research in Law, Ranchi

ABSTRACT

The right to freedom of speech and expression is often regarded as a right that not only is the backbone of

a democratic state but a tool that professes and promotes ideality and contentment in a political arrangement.

It is a means to be open to dissenting opinions, respect individual thought and also promote welfare in the

state. This paper aims to conclude that sedition law, that is section 124 of the IPC, is a catastrophic tool that

shatters such values that are highly regarded in a country like ours by infringing right to freedom of speech

and expression.

This paper studies the origin of sedition law and explains how it holds little or no relevance in today’s times

used in its strict sense without any reasonability. The paper explains how this law is ultra vires as it violates

Article 19 (1) (a) of the constitution and the basic structure doctrine which propagates that a law affecting

the Fundamental Right may be held bad for sheer uncertainty. The paper throws light on the vagueness and

ambiguity of the said law and This leads to the various ways in which the sedation law is used by the

government for political censorship as it infringes the Right of person to express his feelings against the

government and has been repeatedly being misused by many governments to curb its opponents.

Governments have blatantly used S. 124A to stifle the voice of dissent and to further their political goals

which is absolutely in contradiction to the principles of a democratic government. The paper concludes that

it is ultra vires and is continuously used by the government to silence the dissenting voices and thus, must

be done away with.

INTRODUCTION

The Constitution of India has a noble and grand vision as contained in the Preamble44and it has

been said that "The Preamble to the Constitution is the lodestar and guides those who find

44 State of Bihar v. Kameshwar Singh, AIR 1952 SC 252



themselves in a grey area while dealing with its provisions45.” The Preamble of the Constitution

serves two purposes –

(1) it indicates the source from which the Constitution derives its authority viz., the people of

India;

(2) it states the objects which the Constitution seeks to establish and promote.46

Moreover, in Kesavananda Bharati v. State of Kerala 47 it was held that the Preamble to the

Constitution is an integral part of the basic structure of the Constitution48.One of the main objects

of preamble is ‘Liberty’49 which it provides to the citizens of the country. So the main ideal of

Constitution is to grant Freedom or Liberty, which can be further substantiated by Article 19 of

Indian Constitution, which provides a comprehensive list of freedoms provided to Individuals. But

on the other hand, the Offence of Sedition under 124-A takes away the freedom or is aimed at

curtailing the freedom. The S. 124A,50 of the Indian Penal Code, 1860 is in violation of Art.

19(1)(a), of the Constitution of India, 1950 and since by the virtue of Art.13(b), State cannot make

a law against the Fundamental Rights enumerated in Part III of the Constitution, the sedition law

is ultra vires of the Constitution of India.

ORIGIN OF SEDITION LAW

The S. 124A, IPC was introduced by the British colonial government in 1870 when it felt the need

for a specific section to deal with the offence. It was one of the many draconian laws enacted to

45 Steel Authority of India Ltd v. National Union Water Front Workers, AIR 1995 SC 3527 (3535) 46 Golak Nath v. State of Punjab, AIR 1967 SC 1643 47 AIR 1973 SC 1461 48 M Nagaraj v. UOI, AIR 2006 SC 3127 49Ibid 50 Section 124A , IPC: Whoever, by words, either spoken or written, or by signs, or by visible representation, or

otherwise, brings or attempts to bring into hatred or contempt, or excites or attempts to excite disaffection towards, [***] the Government established by law in India, [***] shall be punished with imprisonment for life, to which fine

may be added, or with imprisonment which may extend to three years, to which fine may be added, or with fine.

Explanation 1.--The expression "disaffection" includes disloyalty and all feelings of enmity.

Explanation 2.--Comments expressing disapprobation of the measures of the Government with a view to obtaining

their alteration by lawful means, without exciting or attempting to excite hatred, contempt or disaffection, do not

constitute an offence under this section.

Explanation 3.--Comments expressing disapprobation of the administrative or other action of the Government

without exciting or attempting to excite hatred, contempt or disaffection, do not constitute an offence under this

section



stifle any voices of dissent at that time.51It is settled that while deciding the legality of an enactment

the Court should take into the consideration the history of the legislation.52It is necessary to look

into the origin of the word “Disaffection” for the deciding the Constitutionality of S. 124A, IPC.

The provision was formulated as to be used by the British government to suppress the act of

rebellion.

STRACHEY’S LAW (INTRODUCTION OF WORD “DISAFFECTION”)

During the trial of Balgangadar Tilak in 1897,53 Justice James Strachey held that;

“the term ‘feelings of disaffection' meant ‘hatred', ‘enmity', ‘dislike', ‘hostility', ‘contempt'

and every form of the ill will to the government. He equated disaffection to disloyalty, and held

that the ‘explanation' that followed the main section which made allowance for acts of

disapprobation, would not apply to "any writing which consists not merely of comments upon

government measures, but of attacks upon the government itself, its existence, it's essential

characteristics, its motives, or its feelings towards people."

In 1898, S. 124A was amended to reflect Strachey’s interpretation. The British included the terms

‘hatred’ and ‘contempt’ along with disaffection. Disaffection was also stated to include ‘disloyalty

and all feelings of enmity’.

MAHATMA GANDHI AND THE SEDITION LAW

Mahatma Gandhi, the Father of the Nation gave a statement regarding sedition law that:

“S. 124 A under which I am happily charged is perhaps the prince among the political

sections of the IPC designed to suppress the liberty of the citizen. Affection cannot be

manufactured or regulated by the law. If one has no affection for a person, one should be free to

give the fullest expression to his disaffection, so long as he does not contemplate, promote or incite

to violence.”54

51 Sedition and death of free speech in India, NLSIU, Bangalore, 2011 52 Bengal Immunity Company Limited v. State of Bihar, (1955) 2 SCR 603; R.M.D.Chamarbaugbala v. Union of

India, (1955) SCR 930 53 Q.E. v. BalGangadharTilak, ILR 22 Bom 12 54 Op. cit. A.G. Noorani at 235



CONSTITUENT ASSEMBLY HESITATION TOWARDS SEDITION LAW

Constituent Assembly Debates condemn the very existence of ‘sedition as a crime' in a democratic

society: - Further it is Evident from Constitutional Assembly Debates that it was never the intention

of Constitutional makers, to use sedition as a tool for curtailing freedom. The drafting committee

members like K.M. Munshi55 and Mahboob Ali Bahadur56 and many others were against this law.

Deletion of the word ‘sedition’ from the draft of Art. 19(2) portray the intention of the Constituent

Assembly. During the Debates the framers of the Constitution specifically relied on the advocacy

of replacement of one Government as the only bulwarkagainst democracy and hence the exclusion

of sedition. The Constitution must be interpreted to give effect to the intention of the Constituent

Assembly.57

THE DOCTRINE OF PRESUMPTION IN FAVOUR OF CONSTITUTIONALITY IS

NOT APPLICABLE TO PRE-CONSTITUTIONAL LEGISLATIONS

India Penal Code is a pre-constitutional legislation as it came into force on January 1, 1862.58The

Supreme Court has observed that a pre-constitutional legislation has no barrier at the time of its

enactment, and various limitations have now been brought in by the Constitution, therefore

doctrine of presumption in favour of constitutionality does not apply to it.59Reiterating the same

position, a nine-judge Bench had observed that this doctrine ‘is not of infinite application and has

recognized limitations’. This doctrine is not applicable to Sec. 124A and the court is therefore not

‘free to stretch or pervert the language of the enactment in the interests of any legal or

constitutional theory’.60

55Statement of K.M. Munshi, CONSTITUENT ASSEMBLY DEBATES, Vol. VII, 34 (December 01, 1948). 56Statement of Mahboob Ali, CONSTITUENT ASSEMBLY DEBATES, Vol. VII, 28 (December 01, 1948 ). 57Lt. Col. Khajoor Singh v. The UOI and Anr., AIR 1961 SC 532; R. M. D. Chamarbaugwalla v. The UOI, (1957) 1

SCR 930. 58K.D. GAUR, TEXTBOOK ON THE INDIAN PENAL CODE cxxiv (4lh ed., Universal Law Publishing Co. Pvt.

Ltd. 2009). 59New Delhi Municipal Committee v. Suite of Punjab, AIR 1997 SC 2847. 60In Re, The Central Provinces and Berar Act No. XIV of 1938, (1939) F.C.R. 18 at 37; Diamond Sugar Mills Ltd.

v. The State of Uttar Pradesh (1961) 3 SCR 242; Gulabbhai v. UOI, (1967) I SCR 602.



S. 124A, IPC INFRINGES ART. 19(1)(A) OF THE CONSTITUTION

S. 124A, IPC infringes Art. 19(1)(a) of the Constitution of India. 61Art. 19 of the Constitution

guarantees six basics freedom to the citizen of India, 62 and Art.19(1)(a) does not confer the

freedom of speech of expression but the right of freedom of speech and expression. 63 an

unconstitutional abridgment can be caused not only by prohibition but also by inhibiting the

exercise of fundamental rights64 which can have a deterrent effect or chilling effect, which the

Court should declare unconstitutional.65The vague definition of sedition under sec. 124A and the

wide ancillary powers of detention deter the legitimate exercise of freedom of speech and

expression. The chilling effect inhibits the legitimate exercise of fundamental rights. The mere

threat of sanction can deter the exercise almost as potently as the actual application of the

sanctions.66Fundamental Rights or freedom contained in Art. 19(1) are those great and basic rights,

which are recognized as the natural rights of every citizen.67

ART.19 (1) (A) GIVES THE RIGHT TO FORM OPINION ON ANY ISSUE

In the case of Anand Patwardhan v. Union of India,68 the Bombay high Court held that;

“Everyone has the Fundamental Right to form his opinion on any issue of general concern

and he can form and inform by any legitimate means only.”69

The right to discuss Public affairs includes the right to criticize the government, including its policy

and the conduct of its armed forces.70 A fair criticism of law and executive action by an elected

representative comes under freedom of speech and expression and need not to be throttled.71

61Tara Singh Gopichand v. State, (1951) Punj. 193 62 Shamdasani v. Central bank of India, AIR 1952 SC 59 63DharamDutt v. Union of India, AIR 2004 SC 1295 64Durga Das Basu, Commentary On The Constitution Of India 2417 (8th cd., Lexis Nexis Butterworths Wadhwa

2007). 65 Lamont v. Postmaster General, 381 U.S. 301 (1965). 66Cantwell v. Connecticut, 310 U.S. 296,311 (1940); Gooding v. Wilson, 405 U.S. 518(1972). 67 State of West Bengal v. SubodhGopal Bose, AIR 1954 SC 92 68 AnandPatwardan v. Union of India, AIR 1997 Bom 25 69Anirudh Prasad Yadav v. Union of India, 2004 AIHC 1842 (All) 70 Schacht v. U.S. (1970) 398 71Baldev Singh Gandhi v. State of Punjab, (2002) 3 SCC 667



In the case of Narain Das v. State of M.P.,72this Hon’ble Supreme Court held that;

“If one is allowed to say that the policy of the government is good, another is with equal

freedom entitled to say that it is bad. Different views are allowed to be expressed by proponents

and opponents not because they are correct or valid but because there is a freedom in this country

for expressing even different views on any issue”

In a free country, public discussion is not only a matter of right but also a political duty, for; the

greatest menace to freedom is an inert people.73 The free political discussion is essential for the

proper functioning of a democratic government.74

ART.19 (1)(A) IS NECESSARY FOR A DEMOCRATIC COUNTRY

Certain rights including the right to freedom of speech and expression represented the basic values

of a civilized society and the Constitution makers declared that they shall be given a place of pride

in the Constitution and elevated to the status of Fundamental Rights.75Freedom of speech and

expression is, “a Supreme condition of mental and moral progress.”76 The right of freedom of

speech and expression has been described as the “touchstone of the personal liberty” 77

It has been observed by this Hon’ble Supreme Court in the case of S. Rangarajan v. P. Jagjivan

Ram,78that:

“Free speech is the foundation of a democratic society. A free exchange of ideas,

dissemination of information of information without restraints, dissemination of knowledge, airing

of different viewpoints, debating and forming one's own views and expressing them, are the basic

ideas of free society.”79

72 Naraindas v. State of M.P., (1974) 4 SCC 788 (816) 73 Whitney v. California, (1927) 274 US 357 (375-78) 74BrijBhushan v. State of Delhi, AIR 1950 SC 129 75Maneka Gandhi v. Union of India, (1978) 1 SCC 248 76 Bury, History of freedom and thought, (1913), p.239 77Palko v. Connecticut, 302 US 319 (1937) 78 S. Rangarajan v. P. Jagjivan Ram, (1989) 2 SCC 574 79Union of India v. Motion picture Association, AIR 1999 SC 2334



Freedom of speech is the bulwark of democratic government. This freedom is essential for the

proper functioning of the democratic process. The freedom of speech and expression is regarded

as the first condition of liberty. It occupies a preferred position in the hierarchy of liberties giving

succor and protection to all other liberties, it has been truly said and that it is the mother of all other

liberties.80

S. 124A, IPC VIOLATES BASIC STRUCTURE DOCTRINE

In the case of His Holiness Keshvananda Bharti v. State of Kerala,81the Hon’ble Supreme Court

held that the dignity of the individual is secured by the various freedoms and basic rights in Part

III, the mandate to build a welfare state contained in Part IV, liberty of thought, expression, belief,

faith and worship,82 which forms the part of the basic structure and thus no law can violate the

Basic Structure Doctrine. Therefore, S. 124A, IPC is in violation of the Basic Structure Doctrine.

S. 124A, IPC IS VAGUE AND AMBIGUOUS

The use of the word disaffection makes the S. 124A, IPC unconstitutional. In the case of Emperor

v. Tilak,83 the Court said that the word ‘disaffection’ is a very wide term and it was interpreted by

the Privy Council to mean mere absence of affection or bad feeling towards the government. A

law affecting the Fundamental Right may be held bad for sheer vagueness and uncertainty.84 But

in the case of Niharendu v. Emperor,85 the Federal Court held that:

"Mere criticism or even ridicule of the government is no offence unless it is calculated "to

undermine respect for the government in such a way as to make people cease to obey it and obey

the law so that only anarchy can follow public disorder is the gist of the offence"

80 Jain MP, Constitutional law of India (vol.1, chapter XXIV, Page no. 1152) 81 His Holiness KeshvanandaBharti v. State of Kerala, (1973) 4 SCC 225 82 View of Justice Shelat, Grover JJ, Hegde and Mukherjea JJ, Justice Jagmohan Reddy, id 83 Emperor v. Tilak, (1897) 22 Bom 112; on appeal 22 Bom 528 (PC) 84 KA Abbas v. Union of India, AIR 1973 SC 123 85 Niharendu v. Emperor, (1942) 46 CWN (FR) 9



CONFLICTING INTERPRETATION OF S. 124A, IPC

The Privy Council in the case of Sadashiv v. Emperor,86 overruled the Niharendu87 judgment. And

after the independence in many cases88Court held the S. 124A is unconstitutional and in the case

of Ram Nandan v. State,89the Allahabad High Court held that:

“If it is sought to save the section so as to penalize utterances which are violent or which

would normally lead to a breach of the peace, suitable amendments of the section would be

necessary”

But all these decisions has been overruled by the Supreme Court in the case of Kedarnath Singh

v. State of Bihar,90and upheld S. 124A of the Indian Penal Code by construing it narrowly and

stating that the offence would only be complete if the words complained of have a tendency of

creating public disorder by violence. It was added that merely creating disaffection or creating

feelings of enmity in certain people was not good enough or else it would violate the Fundamental

Right of free speech under Art. 19(1)(a) but on the other hand also state that hat if these essential

ingredients were not read into the meaning of sedition, S. 124A would be rendered

unconstitutional. It was held:

“If, on the other hand, we were to hold that even without any tendency to disorder or

intention to create disturbance of law and order, by the use of words written or spoke which merely

create disaffection or feelings of enmity against the Government, the offence of sedition is

complete, then such an interpretation of the sections would make then unconstitutional in view of

Art. 19(1) (a) read with clause (2).”

However, more than fifty years after Kedarnath91 judgment, the provision under S. 124A is being

allowed to be put to use irrespective of whether or not the alleged act or words are, in fact, seditious

acts, or words constituting a “tendency to cause public disorder or incitement to violence”

86 Sadashiv v. Emperor, (1947) 74 IA 89 87Supraat note 43 88RomeshThappar v. State of Madra, AIR 1950 SC 124; Tara Singh v. State, AIR 1951 Punj 27 89 Ram Nandan v. State, AIR 1959 All 101 (121) 90 Kedarnath Singh v. State of Bihar, AIR 1962 SC 955 91Supraat note 48



In the recent matter of Shreya Singhal v. Union of India,92 while rendering S. 66A of the

Information Technology Act unconstitutional held that:

“Speech howsoever offensive, annoying or inconvenient cannot be prosecuted unless its

utterance has, at the least, a proximate connection with any incitement to disrupt public order.”

And yet, S 124A continues to be used to stifle free expression; expression whichis not intended to

incite disorder, but merely to encourage critique and toprecipitate the free flow of ideas. One

example is that of a Srinagar lecturer whowas arrested for including the question in an exam; “Are

stone throwers the realheroes?”93

S. 124A, IPC AMOUNTS TO POLITICAL CENSORSHIP

S. 124A, IPC infringes the Right of person to express his feelings against the government and has

been repeatedly being misused by many governments to curb its opponents. And in the case of

Ashvini Dhar v. State of Bihar,94 the Patna High Court held that;

"In a democratic country, those who hold a position in government and who are responsible for

the public administration must always be open to criticism. Any attempt to stifle or fetter such

criticism amounts to political censorship of the most insidious and objectionable kind"95

MERE CRITICISM OF GOVERNMENT DOES NOT AMOUNT TO SEDITION

Mere criticism of government policies96 and expressing views against a particular party97 are not

punishable and does not comes within the ambit of 19(2). In short, freedom of expression means

freedom not only for the thought we cherish but also for the thought that we hate.98 Discussion and

advocacy are the core of freedom of speech and expression99 and even if they cause annoyance,

92 ShreyaSinghal v. Union of India, (2013) 12 SCC 73 93 Priscilla Jebaraj, “Binayak Sen Among Six People Charged with Sedition in 2010” The Hindu, 01/01/2011. 94 AshviniDhar v. State of Bihar, AIR 2006 Pat 101 95 R. Rajgopal v. Jayalalitha, (2006) 2 LW 377 (Mad--HC) 96 Jawali v. State of Mysore, AIR 1966 SC 1387. 97 Ahmed v. State, AIR 1951 All 459; Sarju v. State, AIR 1956 All 589. 98Narain Das v. State of M.P., (1947) 4 SCC 788. 99 Abraham v. United States, 250 US 616.



inconvenience or grossly offend,100 etc., they cannot be curbed by law.101 Free criticism is the

foundation of free Government,102for, it is only through free debate and free exchange of ideas,103

that the Government remains responsive to the will of the people and peaceful change is

effected.104The State cannot prevent open discussion and open expression, however hateful to its

policies.105 Everyone has a fundamental right to form his own opinion on any issue of general

concern. Dissent is the quintessence of democracy.106

S. 124A, IPC USED AS A POLITICAL TOOL TO CURB DISSENT

In carrying out arrests and slapping charges, the police and the governments have rarely, if ever,

respected this restriction. Successive governments have blatantly used S. 124A to stifle the voice

of dissent and to further their political goals. It is submitted that according to the National Crime

Records Bureau (NCRB) Report, 2014,107 as many as 47 sedition cases were reported in 2014

alone, across nine Indian states. Many of these cases did not involve violence or incitement to

violence, which is a pre-requisite for a sedition charge. It is submitted that as per the NCRB

figures,108 total of 58 persons were arrested in connection with these cases, but the government

has managed only one conviction.

In an English case of “R v. Collins”109it was observed by the House of Lords that “Seditious

intention is an essence of the offence”. Hence we can say that to be prosecuted for the crime of

Sedition a person must have some intention to overthrow the government by violent means.110 But

this is not the practice in relation to this section as can be deduced by a series of cases. In all these

cases the offence of sedition was slapped on the dissenting voices against the government. None

of these cases have in support any argument which can affirm that any of the accused had any

100Devidas Ramachandra Tuijapurkar v. State of Maharashtra, (2015) 6 SCC 1. 101Prakash Jha Productions v. UOI, (2011) 8 SCC 372. 102 Schneider v. Irvinton, (1939) 308 US 147. 103S. Khushboo v. Kanniammal, (2010) 5 SCC 600; Whitney California, 274 US 357 (1927) 104 Terminillio v. Chicago, (1949) 337 US 1; Stromberg v. Griffs, (1931) 283 US 359. 105 Arvind P Datar, Commentary On The Constitution Of India 582 (2nd edn., 2010). 106S Rangarajan and Ors. v. P Jagjivan Ram and Ors., (1989) 2 SCC 574; Ozair Hussain v. UOI, AIR 2003 Del 103. 107http://ncrb.nic.in/StatPublications/CII/CII2014/Table%2021.1.pdf 108Id 109 (1839) 9 C&P 456. 110Kedar Nath Singh v. State of Bihar, AIR 1962 SC 955; Indra Das v. State of Assam, (2011) 3 SCC 380; Arup

Bhuyan v. State of Assam, AIR 2011 SC 957.



seditious intention to overthrow the Government by any violent means. But in all these cases the

tool of Sedition was just used to put a gag in the mouth of any dissenting voice against the

government. In Balwant Singh Case, 111 Arundhati Roy case, 112 Binayak Sen Case, 113 Aseem

Trivedi Case114this tool was used to suppress the voices and the misuse crossed limits when in

Hardik Patel Case, 115The Gujarat government booked a Patel leader under sedition for sending

messages containing “offensive language against the Prime Minister, the State Chief Minister and

Amit Shah, the President of BJP”.

S.124A, IPC IS INCONSISTENT WITH INTERNATIONAL LAW

International law gives utmost importance to the doctrines of free speech and expression and also

guarantees the enforcement of Rights which is evident in several international instruments such as

Article 19,of Universal Declaration of Human Rights, 1948 (UDHR), Article 19,of the

International Covenant on Civil and Political Rights, 1966 (ICCPR) In 1979, India ratified the

International Covenant on Civil and Political Rights (ICCPR), Article 10,of the European

Convention on Human Rights Act, 2003 (ECHR), Article 9 of the African Charter on Human and

Peoples Rights, 1979 (ACHR), and Article 13 of the American Convention on Human Rights,

1978, which is also known as the pact of San Jose.

CONCLUSION

Hence, S. 124A, IPC infringes Art.19(1)(a) of the Constitution of India and is very vague and can

cover anything said against the government like in the instant matter using the words, “Fight with

the Government” amounts to sedition though it is a settled principle that use of word “fight” will

not amount to Sedition.116 S. 124A has been for the last 50 years was only being used to put the

opponents behind and has been misinterpreted by the law enforcement agencies and also

inconsistent with the international convention. It is required that there should be minimum

111 Balwant Singh v. State of Punjab, 1995 3 SCC 214. 112In Re: Arundhati Roy, Contempt Petition (Crl.) 10 of 2010. 113Vinayak Binayak Sen v. State of Chhattisgarh, 2011 SCC Online Chh 30. 114Sanskar Marathe v. State of Maharashtra, 2015 Cri LJ 3561. 115Hardik Bharatbhai Patel V. State of Gujarat, MANU/GJ/1070/2016 116Balwant Singh v. State of Punjab, 1995 (1) SCR 411



interference with the rights, but Section 124-A encroaches excessively on the freedoms granted in

19(1)(a).

Certainly, the repressive implementation of 124A casts a long shadow. Today, the law still stands

(though as we shall see with a modified interpretation at common law.) The recent wave of cases

against writers, editors, politicians, lawyers, human rights activists, political activists and public

intellectuals is demonstrative of the broad application of the statute. Many of those arrested have

been high profile and respected figures, locally and nationally, such as Binayak Sen, who is the

subject of a case study below. Secondly, there are alternatives to the Section 124-A. Again even if

the section is declared unconstitutional, the main objective parts of section 124-A will be saved by

Section 5, of the Seditious Meetings Act, 1911 and Section 2(o) & Section 13 the Unlawful

Activities (Prevention) Act, 1967, which aims at curtailing offenses against the state. Hence the

Petitioner submits that Sec. 124A does not pass the test, thus Unconstitutional.

The above examples demonstrate that Article 19(1)(a) continues to be held hostage by Section

124-A. and the tool of sedition is continuously used by the government to silence the dissenting

voices.

Documents

SEC.124A, IPC,1860: A DOGMATIC ATTEMPT TO …iclrq.in/editions/jul/3.3.pdfIndian Constitutional Law Review | Edition III (July 2017) Published by Agradoot Web Technologies LLP 24 SEC.124A,