Ranjit Udeshi v State of Maharashtra (1964) | Obscenity & Hicklin Test Explained

Case 4 of 30 in Law Easy's Media Law series. Ranjit D. Udeshi v. State of Maharashtra, Supreme Court of India, decided 1964. FACTS Ranjit Udeshi was one of four partners of the Happy Book Stall in Mumbai. In 1959 the partners were found keeping for sale an unexpurgated copy of D. H. Lawrence's novel Lady Chatterley's Lover. They were convicted under Section 292 of the Indian Penal Code and each was fined twenty rupees. WHAT THE COURT HELD A Constitution Bench, in a judgment by Justice Hidayatullah, held that Section 292 is a reasonable restriction in the interest of decency and morality, that the bookseller's knowledge is not an ingredient of the offence, and that the Hicklin test, as followed in India, does not violate Article 19. It added qualifications: sex and nudity in art are not obscene by themselves, and the work must be seen as a whole. The passages were found obscene and the appeal was dismissed. EXAM POINT Historically important, but the Hicklin test is not the present Indian test. Aveek Sarkar later adopted contemporary community standards. The corresponding present provision is Section 294 B.N.S. PREVIOUS CASE: Bennett Coleman and Co. v. Union of India - https://youtu.be/EWCr-7Ew1mM NEXT CASE: K. A. Abbas v. Union of India - https://youtu.be/YI5LA3HH6pk FULL PLAYLIST (all 30 cases in order): https://www.youtube.com/playlist?list=PLY-t71WbMh6k COMPLETE LECTURE (all 30 cases, 1 hour 52 minutes): https://youtu.be/8AFvktrLPM4 Made for LL.B. students and for CLAT PG, UGC NET Law and judiciary exam preparation. Subscribe to Law Easy for the full law course. Notes: https://www.thelaweasy.com #MediaLaw #Obscenity #LawEasy