RELIGIOUS CENSORSHIP IN INDIA

RESEARCH REPORT SUBMITTED IN PARTIAL FULFILLMENT OF THE

COURSE TELECOMMUNICATION, PRESS AND MEDIA LAW FOR
OBTAINING THE DEGREE B.B.A LL.B (Hons.) DURING THE ACADEMIC
YEAR 2021-22.

SUBMITTED BY: - NIHARIKA BHATI

ROLL NO. – 1839
9th SEMESTER
SUBMITTED TO: - MS.SADAF FAHIM
(FACULTY OF TELECOMMUNICATION, PRESS AND MEDIA LAW )

SEPTEMBER, 2021
CHANAKYA NATIONAL LAW UNIVERSITY
NYAYANAGAR, MITHAPUR, PATNA
800001
 TABLE OF CONTENTS

Table of Contents.............................................................................................................................2
Declaration.......................................................................................................................................3
Acknowledgement...........................................................................................................................4
Research Methodology....................................................................................................................5
1. Introduction..............................................................................................................................6
2. Legal Background For Censorship In India.............................................................................8
3. Religious Censorship In India................................................................................................10
 Constitutional Basis for Religious Censorship...................................................................10
 Under Criminal Law...........................................................................................................11
 Regulations Governing Films and Television.....................................................................12
4. Instances Of Religious Censorship.........................................................................................13
5. Conclusion..............................................................................................................................15
Bibliography..................................................................................................................................16
 DECLARATION

I hereby declare that the work reported in the BB.A.LL.B. Project Report entitled “Religious
Censorship in India” submitted at Chanakya National Law University, Patna is an authentic
record of my work carried out under the supervision of Ms. Sadaf Fahim Ma’am. I have not
submitted this work elsewhere for any other degree or diploma. I am fully responsible for the
contents of my Project Report.

(Signature of the Candidate)

Niharika Bhati
Chanakya National Law University, Patna
 ACKNOWLEDGEMENT

I take this opportunity to express my profound gratitude and deep regards to my guide Ms. Sadaf
Fahim Ma’am for her exemplary guidance, monitoring and constant encouragement throughout
the course of this thesis. The blessing, help and guidance given by her time to time shall carry
me a long way in the journey of life on which I am about to embark.
I am obliged to staff members of Chanakya National Law University, for the valuable
information provided by them in their respective fields. I am grateful for their cooperation
during the period of my assignment.
Lastly, I thank almighty, my parents, brother, sisters and friends for their constant
encouragement without which this assignment would not be possible.

Thank you!
 RESEARCH METHODOLOGY

Method of Research:
For the purpose of research, the researcher has used the Doctrinal Method of Research. The
Research is entirely a Library-based Research, where the researcher has made use of books, law
journals, magazines, law reports, legislations, internet websites, etc., for the purpose of research.

Aims and Objectives:

The Researcher aims to study in detail the legal frame work of Censorship in India with a special
emphasis on Religious Censorship on Freedom of Speech and Expression and its consequences.

Hypothesis:
While they exist harmoniously on paper, free expression and religion often conflict in practice,
and free speech is often trampled in the name of protecting religious sensibilities. As a result, the
increasing menace of religious sensitivities is curbing the freedom of expression and crushing the
creativity in the Nation.

Research Questions:
The researcher seeks to answer the following answers in this project:
1. What is the validity of Censorship in India?
2. Why is there a continuous tussle between Freedom of Expression and Religion in India?
3. What is the impact of Religious Censorship on Freedom of Speech and Expression?

Method of Writing:
The method of writing followed in the course of this research paper is primarily analytical.

Scope and Limitations of the Study:

Though the researcher will try her level best not to leave any stone unturned in doing this project
work to highlight various aspects relating to the topic, but the topic is so dynamic field of law,
the researcher will sight with some of unavoidable limitations. The limitations encountered by
the researcher were the paucity of time.
 1. INTRODUCTION

In India, Freedom of speech and expression is guaranteed under Article 19(1)(a) of the
Constitution of India. Article 19(1)(a) says that all citizens shall have the right to freedom of
speech and expression. Freedom of Speech and expression means the right to express one’s own
convictions and opinions freely by words of mouth, writing, printing, pictures or any other mode.
In modern time it is widely accepted that the right to freedom of speech is the essence of free
society and it must be safeguarded at all time. The first principle of a free society is an
untrammeled flow of words in an open forum. Democracy is based essentially on free debate and
open discussion.1 Therefore Liberty to express opinions and ideas without hindrance, and
especially without fear of punishment plays significant role in the development of that particular
society and ultimately for that state. This is why it is said that freedom of speech is the mother of
all other liberties.
This right is not an absolute. Under Article 19(2) of the Constitution of India, the State may
make a law imposing “reasonable restrictions” on the exercise of the right to freedom of speech
and expression “in the interest of” the public on the following grounds:
 Sovereignty and Integrity of India
 Security of State
 Public Order
 Friendly relations with foreign states
 Decency or Morality
 Contempt of Court
 Defamation
 Incitement to an Offence
However in the 21st Century, religion and freedom have been seen as two contradictory terms. In
relation to religion, the freedom of expression has been tested in recent times. Every statement or
expression in any form of media with the slightest potential to insult or annoy any religious
group becomes highly contentious. Consequently, media portrayals about religion and religious
identities are often cautiously carried out whether that is in any genre; news, advertising or
cinema. The immediate reaction then, is to try and censor such expressions, either with the aid of
1
Maneka Gandhi v. Union of India
the law, or by social pressure. We have various examples as illustrations while taking about
India’s history of outrageous responses and intolerant behavior against ‘controversial’ cinematic
projections of religions. The Film PK was accused of "hurting Hindu sentiments" by various
religious outfits who sought to ban the movie. Given the film's sensitive theme, some religious
groups protested against PK and even vandalized some cinemas. We also saw the ugly face of an
intolerant India with protests and violence in several parts of the country against the medieval
epic Padmavati. All these events have opened the debate about how growing intolerance
continues to endanger free speech.
In a pluralistic society like ours, religion has a profound impact upon the political bodies.
Concern of religious sensitivities has made a profound impact upon the working of the political
bodies in India. India is known to be the largest democracy in the world. But, it is also known to
be a ‘Liberal Democracy’. Freedom of Expression is considered to be the cardinal principle of
the Indian Constitution. The tenets of secularism and freedom are enshrined as fundamental
rights under the Constitution.2 But, religious intolerance destroys the very tenets of the
constitution.
It could be very well understood from the fact that only 37% Indians believe it is very important
to have a free media without government or state censorship. In contrast, freedom of religion, at
78%, is the top priority for Indians among free media, freedom of speech and a fair judiciary.3
Constitutional makers had envisioned the need to promulgate the necessary provisions to uphold
religious freedom and freedom of speech. Article 19(1)(a) of the Constitution provides “Freedom
of Speech and Expression”, whereas Article 25-28 of the Constitution provides “Freedom of
Religion”. The makers, however, have restricted these provisions with certain provisions in order
to check the misuse. But, in recent times, the use of these provisions under the constitutional
framework has been jeopardized. This excessive and un-necessary religious censorship is
ultimately crushing the Creativity.

2
Diya Vaishnav and Nihal Deo, THE PERIL OF HATE SPEECH IN INDIA, Criminal Law Blog, NLUJ , available
at https://criminallawstudiesnluj.wordpress.com/2020/02/03/the-peril-of-hate-speech-in-india/.
3
Saira Aslam, “INDIANS HOLD RELIGIOUS FREEDOM DEARER THAN FREE MEDIA, SPEECH OR
JUDICIARY: PEW SURVEY”, The Hindu, Available at: https://www.thehindu.com/news/national/indians-
holdreligious-freedom-dearer-than-free-media-speech-or-judiciary-pew-survey/article30944515.ece.
 2. LEGAL BACKGROUND FOR CENSORSHIP IN INDIA

In a wider sense, the term “censorship” means a curb or a restriction on a person’s right to
express his ideas in any form, on the ground that such expression would be harmful. 4 In India
censorship remains fundamentally an instrument of intervention by the state, defined and
administered by the parameters of law. The part of state is to govern through enactment and
implementation of public policy.
Censorship is an amalgamation of various interrelated concepts amongst which the most
prominent being free speech, it is the ability to express or articulate one’s ideas freely without
any limitation or interference. This meaning has over the years been given a broad interpretation
and now includes speeches, music, movies, artistic works etc. These are the various types of
censorship which are exercised in a society or a country and one of its major goals is to ensure
the suppression of free speech on the grounds that such expression is offensive or harmful to the
public.
Unlike the First Amendment to the US Constitution, this unequivocally declares: “Congress shall
make no law abridging the freedom of speech or of the press”; the constitutional guarantee of
free speech in India is somewhat restricted. Article 19(1) (a) of the Constitution of India
promises right to free speech and expression to all the citizens.5 However, ‘reasonable restriction’
can be imposed on the enjoyment of this freedom by the State on certain grounds, i.e., 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 offense. Additionally, freedoms under Article 19 of the Constitution can be
suspended during the Emergency.6
The Constitution does not specifically speak about any medium of communication. The
jurisprudence that has developed through case laws in this respect has encompassed the press,
motion pictures, advertisements etc. within its fold. So far censorship of films in India is
concerned; the power of legislation is vested with the Parliament under Entry 60 of the Union
List 77 of the Schedule VII of the Constitution. The States are also empowered to make laws on
cinemas under Entry 33 of the Sate List but subject to the provision of the central legislation.
4
CK Razdan (ed), Bare Breasts and Bare Bottoms: Anatomy of Film Censorship in India (Jaico Publishing House
1975)
5
Art 19(2), Constitution of India, 1950.
6
Art 19(2), Constitution of India, 1950.
The prime legislation governing censorship is the Cinematograph Act, 1952, and the
Cinematograph (Certification) Rules, 1983. It was enacted to provide for the certification of
cinematograph films for exhibition and for regulating their exhibition by the Central Board for
Film Certification. After examination of a film, the Board either sanctions the film for restricted
or unrestricted public exhibition; or directs to carry out necessary modifications; or refuse to
sanction the film for public exhibition. Section 5- B (1) provides the grounds for the restriction
for public exhibition which is in consonance with Article 19(2) of the Constitution.
The constitutionality of censorship under the 1952 Act along with the Rules was challenged in
the case of K.A. Abbas v. Union of India7. The Supreme Court upheld the constitutionality
within the ambit of Article 19(2) of the Constitution and added that films have to be treated
separately from other forms of art and expression. Simultaneously, it cautioned that it should be
“in the interests of society”.8 “If the regulations venture into something which goes beyond this
legitimate opening to restrictions, they can be questioned on the ground that a legitimate power is
being abused.”
On the contrary, the Apex Court zealously protected the freedom of expression in Rangarajan v.
P.Jagjivan Ram.9 The Supreme Court overturned the Madras High Court judgment which had
revoked a U certificate awarded to the film Ore Oru Gramathille. This film which was based on
the critical aspect of the government’s reservation policy which was seen by the High Court as
portraying a theme which could cause widespread unrest and law and order problem in the state.
It upheld, ‘The democracy is a Government by the people via open discussion. The democratic
form of government itself demands its citizens an active and intelligent participation in the
affairs of the community. The public discussion with people participation is a basic feature and a
rational process of democracy which distinguishes it from all other forms of government. The
democracy can neither work nor prosper unless people go out to share their views. The truth is
that public discussion on issues relating to administration has positive value.’

7
K.A. Abbas v. UOI, A.I.R. 1971 S.C. 481.
8
Id.
9
Rangarajan v. P Jagjivan Ram, (1989) 2 S.C.C. 574.
 3. RELIGIOUS CENSORSHIP IN INDIA

Since ages, censorship on the basis of religion has been practiced by various societies and
religion. Religious censorship is a form of censorship where freedom of expression is regulated
or limited using religious authority or on the grounds of the religious teachings, beliefs, and
thoughts. Religious censorship is defined as the act of suppressing views that are contrary of
those of an organized religion. It is usually performed on the grounds of blasphemy, heresy,
sacrilege or impiety10 implying that the censored work being viewed as obscene, challenging a
dogma, or violating a religious taboo.

 Constitutional Basis for Religious Censorship

Article 19 (1) (a) of the Indian Constitution is the source of a very important right with respect to
the media. However, it is made subject to permissible restrictions detailed under Article 19 (2).
The grounds under which restrictions may be placed are exhaustive and restrictions cannot be
placed under any other ground.11
As far the aspect of religious censorship is considered, religion or even hurting the religious
sentiments of others is not included under the grounds for imposing restrictions on the freedom
of speech and that being so, religion cannot be a valid ground for curbing the freedom of speech.
Generally, any sort of action taken to prevent any form of expression in the media that threatens
to hurt the religious sentiments of a group is purported to be taken in order to maintain public
order.12 It is understood that such expressions that hurt the religious sentiments of a group tend to
incite that group to violence, thus disturbing public order.
The religious freedom of a person is guaranteed under Article 25. It guarantees all persons the
right to freely practice, profess and propagate religion, subject to public order, morality, health
and the other provisions of Part III of the Constitution.
A comprehensive reading of Article 19(1) (a) and Article 25 is that in professing, practicing or
propagating a religion, a person may make use of his right to freedom of speech and expression,
but that the same would be subject to certain reasonable restrictions that the State may impose.

10
Amit Singh, CONFLICT BETWEEN FREEDOM OF EXPRESSION AND RELIGION IN INDIA—A CASE
STUDY, Social Sciences Articles, 2018.
11
Sakal Papers v. Union of India, AIR 1962 SC 305; O. K. Ghosh v. E. Joseph, AIR 1963 SC 812.
12
https://international.thenewslens.com/article/142531
  Under Criminal Law
The Indian Penal Code controls the expression of the media on the grounds of religion such as
the promoting enmity between different groups on grounds of religion, race, place of birth,
residence, language, etc is punitive13(sec 153A IPC). Deliberate and malicious acts intended to
outrage religious feelings of any class by insulting its religion or religious beliefs is also covered
under its ambit.(SEC 295A)14 Section 298 criminalizes any expression made with deliberate
intent to hurt the religious feelings of any person. Section 505 makes the making, publishing or
circulating of any statement or rumour an offence, which is likely to incite any class or group of
persons to commit any offence against other class or group of persons, or promotes or is likely to
promote feelings of enmity, hatred or ill-will between different religious, racial, language or
regional groups or castes or communities. These provisions of law aim to prevent hurt to the
religious sentiments of one group by another. However, these provisions, though originally
enacted to uphold the secular fabric of the nation and preserve public order, can also be used to
place unreasonable or unwarranted checks on the right of expression.15 Censorship of the written
media on religious grounds is generally carried out by invoking these provisions of the Indian
Penal Code.
In Babu Rao Patel v. State (Delhi Administration)16 the appellant was the editor, printer and
publisher of ‘Mother India”. He published two articles titled “A Tale of Two Communalisms”
and “Lingering Disgrace of History”. It was contended that the first article was a political thesis
while the second was merely a protest against the naming of roads in Delhi in honour of
Mughals, based on historical truths. The Court pointed out that while the first article did begin as
a political thesis, it went on to make several uncharitable allegations against the Muslim
community. He was prosecuted under sec 153A. The Court held that both the articles promotes
feelings of enmity, hatred and ill-will between the Hindu and Muslim communities on grounds of
community and this could not be done in the guise of political thesis or historical truth.
The exhibition of the serial named ‘Tamas’ was questioned on the grounds of public order in
Ramesh vs Union of India17. The said serial dealt with the period immediately preceding the

13
Sec 153A, Indian Penal Code, 1860.
14
Sec 295A, Indian Penal Code, 1860
15
Harini Sudarshan, RELIGION AND CENSORSHIP IN THE INDIAN MEDIA: LEGAL AND EXTRA-LEGAL,
NALSAR Media Law Journal, Vol I.
16
Babu Rao Patel vs State, AIR 1980 SC 763, para 7.
17
Ramesh v. Union of India, AIR 1988 SC 775.
partition of India and portrayed the tension between Hindus and Muslims and Muslims and
Sikhs. It was therefore, alleged to be violative of Art 25 of the Constitution and punitive under
Sec 153A, IPC and sec 5B, Cinematography Act. However, the High Court Judges who had
viewed the film found it to be one with a good message for the public. They had viewed it from
the perspective of an average person and found that it was not likely to incite the commission of
any offence or cause public disorder.

 Regulations Governing Films and Television

Under sec 5B of The Cinematograph Act, 1952 imposes certain restrictions on exhibition of
films.18 This provision mainly repeats the grounds for imposition of reasonable restrictions
detailed under Article 19(2). Under sec 13 The Central Government may suspend the screening
of a film in any Union Territory if of the opinion that it will lead to a breach of peace. 19 Religion
being such a sensitive issue in India, this provision could easily be invoked to effect religious
censorship of films where the same could be justified on the ground that not doing so would lead
to a breach of peace.
In reference to television, the Cable Television Networks (Regulation) Act, 1995 and the
Programme and Advertising Codes places restrictions on the matter aired by operators of cable
television.20 Under Section 19 of the Act, an authorized officer may prohibit the transmitting or
retransmitting of any programme or channel which is either not in conformity with the
Programme Code or the Advertising Code, or is likely to promote “…on grounds of religion,
race, language, caste or community or any other ground whatsoever, disharmony or feelings of
enmity, hatred or ill-will between different religious, racial, linguistic or regional groups or
castes or communities or which is likely to disturb the public tranquility.’

18
Sec 5B, Cinematograph Act, 1952.
19
Sec 13, Cinematograph Act, 1952.
20
Rules 6 and 7, Cable Television Network Rules, 1994
 4. INSTANCES OF RELIGIOUS CENSORSHIP

In India there have been numerous incidents when Freedom of Speech and Expression was either
curtailed or restricted due to religion. Some of these are mentioned below.
1. A recent example of religion over Freedom of Speech was the change in the name of Akshay
Kumar’s Movie “LAKSHMI BOMB” to “LAKSHMI”. Right-wing organisation Hindu Sena
had earlier written to union minister of information and broadcasting Prakash Javadekar
emphasising how its followers will boycott the movie across the country. Other Hindu
organisations like Hindu Janajagruti Samiti and Akhil Bharatiya Hindu Mahasabha had
alleged that the film promotes love jihad since it is the story of two individuals belonging to
different religious communities. The Rajput Karni Sena had demanded a change in the title
which they felt the makers had deliberately chosen to ‘lower the dignity’ and ‘show
disrespect to the goddess.21
2. Jewellery brand Tanishq had to pull its ad featuring a Hindu woman and her Muslim mother-
in-law off all online platforms after a backlash on social media, which saw #BoycottTanishq
trending on Twitter. The ad for Tanishq’s new collection called Ekatvam – which means
‘oneness’ – showed a Muslim family organising a traditional Hindu baby shower ceremony
for their Hindu daughter-in-law.22
3. "I am Joyita", a Bengali documentary that released on Republic Day, shines a light on the
struggles of India’s first transgender judge from the small town of Islampur in West Bengal.
But behind Joyita’s resilience is the untold story of a filmmaker who was harassed and
targeted by extremists. It showed the transgender activist visiting a temple and mosque in
Bengal and ascribing to humanism as her religion. The film-maker was stopped by
motorcycle-borne goons who threatened to ban his film. They called him a heretic for
showing India as the land of both Ram and Rahim, saying there was no place for transgender
men or women in Hinduism. They blamed him for promoting Islam through a transgender
who deserved no place in the Indian religious and social order.23 Censorship of "I am Joyita"

21
Lata Jha, “Akshay Kumar’s Lakshmi Bomb goes name change after Hindu Group Protest”, Live Mint, Available
at: https://www.livemint.com/news/india/akshay-kumar-s-laxmmi-bomb-undergoes-name-change-after-hindu-
groupsprotest-11603974615808.html
22
Surbhi Gupta, “Tanishq pulls down ad after social media uproar”, Indian Express, Available at:
https://indianexpress.com/article/india/tanishq-pulls-down-ad-after-social-media-uproar-6724045/.
23
Priyadarshni Sen, “The unending Censorship of Faith in Indian Cinema”, Outlook India, Available at:
https://www.outlookindia.com/website/story/opinion-the-unending-censorship-of-faith/346833
 is part of the continuing story of official and unofficial censorship of the arts in India in the
name of religion.
4. In year 2012, a girl posted on her facebook wall against the shutdown in the city on Bal
Thackeray’s funeral and some other girl signed it. The duo was booked under section 295A
and 66A of the Information Technology Act 2000 and was arrested subsequently. This case 24
created a lot of hue & cry and ultimately Supreme Court Struck down Section 66A of the
Information Technology Act 2000.
5. The arrest of Kiku Sharda mimicking Gurmeet Ram Rahim Singh during a comedy show has
rekindled the debate on India’s regressive speech laws. Kiku was booked under section 295 A
of the Indian Penal Code i.e. for outraging religious feelings of any class by insulting its
religion or religious belief.25 Though he said his intention was not to hurt the religious
feelings of any class but just to entertain people.
6. In 2015, the Central Board of Film Certification banned the release of Unfreedom, a film
based on a lesbian relationship on the premise that it would ignite “unnatural passions.” But
the director claimed the board primarily had a problem with the portrayal of “religious
fundamentalism” and that homosexuality was only “part of the problem.” Earlier, the Tamil
Nadu government had called for a ban on the action thriller Vishwaroopam following protests
by some Muslim organisations who said the film “hurt their sentiments”; Hindu
fundamentalists trashed the sets of Deepa Mehta’s Water set in Varanasi, saying it vilified
Hindu traditions, and Hindu groups alleged that Padmaavat distorted history by depicting the
protagonist of the film—Rajput queen Padmini—in a poor light.26

24
Shreya Singhal vs Union of India, AIR 2015 SC 1523.
25
https://indianexpress.com/article/india/india-news-india/comedian-kiku-sharda-of-comedy-nights-with-kapil-
fameheld-for-mimicking-dera-sacha-sauda-chief-gurmeet-ram-rahim-singh/
26
https://www.outlookindia.com/website/story/opinion-the-unending-censorship-of-faith/346833.
 5. CONCLUSION

Despite the fact that courts have taken a judicious stand on several instances, the menace of
religious sensitivities curbing freedom of expression is yet not over. There are many arbitrary and
outmoded provisions prevalent in the statutes that empower religious forces to misuse it with the
support from political bodies. Extremist religious ideologies and violent forces on the right have
overshadowed the idea of a liberal, tolerant society envisioned by India’s founding fathers. A
new Hindu assertiveness and so-called cleansing of Western cultural influences are steadily
gaining ground, whereby intolerant forces, propped up by the political class, are determined to
put rationalists and liberals in their place. In 2017 a Pew Research Center analysis of most
populous countries ranked India as among the worst in the world for religious intolerance.
It is accepted that Religion is a way of life. Everyone has an equal right to choose their own
lifestyle. Thus Religion cannot be completely put on stake; however, what is really required is a
change in mindset amongst people, and for them to understand the value of freedom of speech
and expression, as much as they value religion. There is a need for the society to open their
minds and accept newly emerging ideas without confining their thoughts to a singular aspect of
life, such as religion.
However we also need to understand that we (in India) cannot simultaneously sell ourselves to
the world as a land of pluralism, tolerance and Gandhianism, while promoting intolerance,
communal hatred and minority insecurity within the country. It is time to understand that we
cannot promote ‘Atmanirbhar Bharat’ or ‘Make in India’ abroad while condoning the
propagation of ‘Hate in India’ at home. Because one thing is clear that continuing on this current
path could spell the destruction of India’s pluralistic ethos.
 BIBLIOGRAPHY

STATUTES REFERRED:
 The Constitution of India, 1950
 Indian Penal Code, 186
 Cinematograph Act, 1952
 Cable Television Networks (Regulation) Act, 1995

ARTICLES REFERRED:
 Diya Vaishnav and Nihal Deo, “The Peril of Hate Speech in India”, Criminal Law Blog,
NLUJ
 Amit Singh, “Conflict Between Freedomof Expression and Religion in India—A Case
Study”, Social Sciences Articles, 2018.
 Harini Sudarshan, “Religion and Censorship in the Indian Media”, NALSAR Media Law
Journal, Vol I.
 https://indianexpress.com/article/india/india-news-india/comedian-kiku-sharda-of-
comedynights-with-kapil-fame-held-for-mimicking-dera-sacha-sauda-chief-gurmeet-ram-
rahimsingh/
 Priyadarshni Sen, “The unending Censorship of Faith in Indian Cinema”, Outlook India,
Available at: https://www.outlookindia.com/website/story/opinion-the-unending-
censorshipof-faith/346833
 Surbhi Gupta, “Tanishq pulls down ad after social media uproar”, Indian Express, Available
at: https://indianexpress.com/article/india/tanishq-pulls-down-ad-after-social-media-
uproar6724045/.
 Lata Jha, “Akshay Kumar’s Lakshmi Bomb goes name change after Hindu Group Protest”,
Live Mint, Available at: https://www.livemint.com/news/india/akshay-kumar-s-laxmmibomb-
undergoes-name-change-after-hindu-groups-protest-11603974615808.html
 Saira Aslam, “Indians hold Religious freedom dearer than free media, speech or judiciary:
Pew Survey”, The Hindu, Available at: https://www.thehindu.com/news/national/indians- 16
hold-religious-freedom-dearer-than-free-media-speech-or-judiciary-
pewsurvey/article30944515.ece.
 https://international.thenewslens.com/article/142531.

WEBSITES REFERRED:
 https://www.pewforum.org
 https://www.indexoncensorship.org
 https://www.nytimes.com
 https://www.outlookindia.com/website/story/opinion-the-unending-censorship-
offaith/346833.
 https://international.thenewslens.com/article/142531