22 January 2026 Legal Updates

Journalistic Freedom Cannot Be Curtailed Merely Because Public Officials Feel Offended: P&H High Court

(a) Case Title:

• Manik Goyal v. State of Punjab & Anr.

(b) Court:

• Punjab and Haryana High Court

(c) Date of Decision:

• 21st January 2026

(d) Bench:

• Justice Vinod S. Bhardwaj

Facts of the Case

The case arose from the publication of a news report by a law student, journalists, and media professionals concerning alleged helicopter movements linked to the Punjab Chief Minister. Following the publication, criminal proceedings were initiated against the authors of the report.

The petitioners approached the Punjab and Haryana High Court seeking protection against further investigation, contending that the criminal action was initiated merely because the news report allegedly offended a public functionary, without any clear disclosure of a cognizable offence.

Issues Raised

• Whether criminal proceedings can be sustained merely because a public official feels offended by a news report?
• Whether subjective feelings of hurt or offence can justify State action restricting journalistic freedom under Article 19(1)(a)?
• Whether continuation of investigation without prima facie offence violates fundamental rights of journalists?

Contentions of the Petitioner

• The news report was a legitimate exercise of journalistic freedom under Article 19(1)(a).
• Criminal proceedings were initiated solely due to hurt sentiments of a public office holder, without any legal basis.
• No prima facie ingredients of any offence were disclosed.
• Continuation of investigation would cause chilling effect on free speech and press freedom.
• State action lacked a direct nexus with any lawful restriction under Article 19(2).

Contentions of the Respondent

• The publication had the potential to mislead the public and create unnecessary controversy.
• Media and social media platforms must adhere to journalistic ethics and responsibility.
• Investigation was necessary to determine whether the publication crossed permissible limits.

Court’s Reasoning & Key Findings

(a) Interpretation of Law

• Criminal law cannot be set in motion based on subjective offence or sensitivity of a public officer.
• The yardstick must always be objective, based on ordinary prudence and reasonableness.

(b) Application of Constitutional Provisions

• Article 19(1)(a) protects the right to report, critique, and satirise public functionaries.
• Restrictions on speech must strictly satisfy Article 19(2) and cannot be based on speculative or remote reactions.
• Article 21 is implicated when unjustified criminal proceedings threaten personal liberty.

(c) Reasonable Person Test

• The Court reiterated that the test is whether a reasonable person of ordinary prudence would see a direct nexus between the publication and the alleged offence.
• If sentiments are artificially inflamed, liability lies with the person reacting, not the author.

(d) Chilling Effect on Press

• Allowing criminal proceedings to continue without prima facie offence would chill journalistic freedom.
• Criticism and satire are integral to democratic accountability.

Final Verdict

• Further investigation was stayed by the High Court.
• The Court held that continuation of criminal process would prejudice the rights of the petitioners.
• No opinion was expressed on the merits of the case, but protection was granted at the present stage.

Prisoners Entitled to Dignified Life: Rajasthan High Court Orders Statewide Jail Inspections Over Inhuman Sanitation Conditions

(a) Case Title:

• People’s Watch Rajasthan v. State of Rajasthan & Ors.

(b) Court:

• Rajasthan High Court

(c) Date of Decision:

• 21st January 2026

(d) Bench: 

• Justice Anoop Kumar Dhand

Facts of the Case

A public interest petition was filed before the Rajasthan High Court highlighting severe lack of sanitation facilities, inadequate water supply, and unhygienic living conditions in jails across Rajasthan. The petitioner pointed out that prisoners were being provided insufficient washing soda and water, contrary to the Rajasthan Prison Rules, 1951.

It was submitted that prisoners were allowed to wash clothes only once a week, even in Rajasthan’s extreme climate, and lacked adequate drinking and washing water. The petition stressed that such conditions violated the right to dignity and basic human rights of prisoners, who remained voiceless due to their incarceration.

Issues Raised

• Whether prisoners are entitled to adequate sanitation, hygiene, and water facilities as part of Article 21?
• Whether failure of the State to ensure hygienic prison conditions violates constitutional and human rights of inmates?
• Whether judicial intervention is warranted to monitor prison administration and inmate welfare?

Contentions of the Petitioner

• Prison conditions in Rajasthan are inhuman and degrading, especially with respect to sanitation and water.
• Existing provisions under the Rajasthan Prison Rules, 1951 are inadequate and poorly implemented.
• Prisoners, though convicts or undertrials, are human beings entitled to dignity under Article 21.
• Administrative apathy and corruption have resulted in denial of basic necessities.
• Judicial monitoring is essential to prevent continued neglect.

Contentions of the Respondent (State)

• The State relied on existing prison rules and administrative arrangements.
• It did not effectively rebut the factual allegations regarding lack of water and sanitation.
• The State sought time to address infrastructural and logistical constraints.

Court’s Reasoning & Key Findings

(a) Interpretation of Law

• Prisoners do not lose their fundamental rights upon incarceration, except to the extent lawfully restricted.
• Personal hygiene and sanitation are core components of the right to life.

(b) Application of Constitutional Provisions

• Article 21 includes the right to live with dignity, which applies equally to prisoners.
• Denial of basic sanitation amounts to dehumanising treatment, prohibited by constitutional principles.

(c) Human Rights Perspective

• The Court emphasized that prisoners are often ignored because they are viewed only as criminals.
• Reformative justice requires restoring self-respect and dignity, not merely punishment.

(d) Administrative Failure

The Court identified key reasons for poor prison conditions:

• Administrative ignorance
• Corruption in prison regulation
• Lack of funding and monitoring
• Despite amended Prison Rules (2022), ground reality remains unchanged.

Final Verdict

1. Grievance Redressal Committees were ordered to be constituted in every district, consisting of:

• District Magistrate & District Judge
• Chief Judicial Magistrate
• District Social Welfare Officer
• Jail Superintendent
• Secretary, District Legal Services Authority (DLSA)

2. Committees were directed to:

• Conduct surprise inspections within three weeks
• Privately interview prisoners
• Submit detailed reports to the Court

3. The State was directed to:

• Formulate a policy ensuring adequate drinking and washing water
• Display notices in jails informing prisoners of their right to submit complaints
• RSLSA was directed to monitor implementation and submit a compliance report.

Legal Principles Established

1. Prisoners’ Rights under Article 21

• Prisoners retain the right to life with dignity, including sanitation, hygiene, and water.

2. Human Dignity Doctrine

• Incarceration does not justify dehumanising or degrading living conditions.

3. Reformative Justice Principle

• Modern criminal justice aims at reformation and reintegration, not mere punishment.

4. Judicial Oversight of Prisons

• Courts can issue structural and monitoring directions where systemic failures exist.

5. Positive Obligation of the State

• The State has a constitutional duty to provide basic necessities to inmates.

6. Access to Grievance Redressal

• Prisoners must be provided institutional mechanisms to voice grievances safely.