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Case explanation · Media Law

Sakal Papers v Union of India (1961) | Newspaper Price & Page Act Explained

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Case 2 of 30 in Law Easy's Media Law series. Sakal Papers (P) Ltd. v. Union of India, Supreme Court of India, decided 1961. FACTS The Newspaper (Price and Page) Act, 1956 and an Order of 1960 fixed the maximum number of pages a newspaper could publish according to its price. The aim was to stop large papers from using low prices and many pages to kill small ones. The company publishing Sakal, a Marathi daily from Pune, its shareholders and two readers challenged the law. WHAT THE COURT HELD Justice J. R. Mudholkar struck down both the Act and the Order. Freedom of the press includes the right to publish and to circulate, so it covers the volume of circulation as well as content. Business can be restricted under Article 19(6), but speech can be restricted only on the grounds in Article 19(2), and preventing unfair competition is not one of them. EXAM POINT Remember: a law aimed at circulation is a law aimed at speech. Always test the direct effect and the correct constitutional ground. PREVIOUS CASE: Express Newspapers (Private) Ltd. v. Union of India - https://youtu.be/RgSDKA6Xw1Q NEXT CASE: Bennett Coleman and Co. v. Union of India - https://youtu.be/EWCr-7Ew1mM 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 #Article19 #LawEasy

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