Case Summary: R. Rajagopal alias R.R. Gopal vs State of Tamil Nadu (1994)
Name of the Court: Supreme Court of India
All Citations of the Case
AIR 1995 SC 264 : (1994) 6 JT 514 : (1995) 1 LW 184 : (1994) 4 SCALE 494 : (1994) 6 SCC 632 : (1994) 4 SCR 353 Supp
[Judgment Source] https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=280375
Facts of the Case
The petitioners, editors of the Tamil magazine 'Nakkheeran', sought protection against interference by Tamil Nadu state authorities regarding the publication of an autobiography allegedly written by a condemned prisoner, Auto Shankar. The publication claimed to expose nexus between the prisoner and various public officials. The prison authorities denied the authenticity and authorship of the autobiography and warned against its publication. The petitioners argued the publication fell under freedom of the press and claimed the authorities’ actions violated their constitutional rights.
Law Points Raised
1. Whether a citizen has the right to prevent unauthorized publication of their life story under the right to privacy.
2. Whether freedom of the press under Article 19(1)(a) permits such publication.
3. Whether the government or public officials can impose prior restraint on publication.
4. Whether prison authorities can act on behalf of a prisoner to prevent publication.
5. The scope of Article 21 in protecting privacy rights.
Acts/Provisions/Articles Referred
• Constitution of India, 1950 — Articles 19(1)(a), 21, 32, 104, 105
• Indian Penal Code, 1860 — Sections 499, 500
Judgements Referred
The judgment discusses past cases interpreting the right to privacy under Article 21 and its intersection with Article 19(1)(a) including Kharak Singh v. State of UP and American cases like Griswold v. Connecticut and Roe v. Wade.
Obiter Dicta
The Court acknowledged that the right to privacy is implicit in Article 21 and covers unauthorised publication of one’s life story, but this right does not extend to public officials performing public duties. The press has a right to publish true accounts of public servants' conduct relevant to public interest.
Ratio Decidendi
A public official cannot claim the right to privacy in matters relating to their official conduct. However, for private individuals, unauthorized publication can be prevented if it invades their privacy unless it is a matter of public record.
Final Ruling
The Supreme Court ruled in favour of the petitioners, holding that the publication of true information about public officials does not violate the right to privacy. The petitioners’ freedom of expression is protected unless the publication is false or defamatory. Government authorities cannot impose prior restraint on the press.
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