# CASE DETAILS PEOPLE'S UNION FOR CIVIL LIBERTIES AND ANR v. THE STATE OF MAHARASHTRA AND ORS

- **Citation:** 2023 INSC 833
- **Court:** Supreme Court of India
- **Decided:** 2023-09-13
- **Case number:** Criminal Appeal No. 1255 of 1999
- **Bench:** Dr. Dhananjaya Y. Chandrachud
- **Source:** https://unisonlegal.in/judgment/supreme-court-of-india/case-details-people-s-union-for-civil-liberties-and-anr-v-the-state-of-36474
- **Pages:** 11

## Headnote

Issue for consideration: Matter pertains to the modalities to be followed
by the police in conducting media briefi ngs during criminal investigation.
Media - Media briefi ngs/reporting by police personnel - Propriety
and procedure:
Held: Media reporting in criminal matters involves degree of public
interest associated with the fundamental right u/Art. 19(1)(a) - Guidelines for
conducting media briefi ngs were prepared by the Union Ministry of Home
Aff airs over a decade ago - Since then with the upsurge in the reporting
of crime, the print media, the electronic and social media have evolved
signifi cantly - There should be a Standard Operating Procedure which
balances out the considerations - There is a need to have a uniform policy
- Nature of the disclosure cannot be uniform since it must depend upon the
nature of the crime and the profi le of the stake holders, including victims,
witnesses and the accused themselves - Disclosure should not result in a
media trial - Media trials are liable to result in a derailment of justice by
impacting upon the evidence adduced and its assessment by the adjudicating
authorities - In view thereof, the Union Ministry of Home Aff airs to prepare
a comprehensive manual/guidelines on media briefi ngs by police personnel,
within the stipulated period - Issuance of direction to all the Directors
General of Police to give their suggestions to the Union Ministry of Home
Aff airs and the views of National Human Rights Commission would also
be considered.[Paras 6, 17,18,19 and 20]
370
371
LIST OF CITATIONS AND OTHER REFERENCES
People's Union for Civil Liberties v State of Maharashtra (2014) 10
SCC 635: [2014] 12 SCR 54; A K Gopalan v Noordeen (1969) 2 SCC 734;
Sahara India Real Estate Corporation Limited v Securities and Exchange
Board of India (2012) 10 SCC 603: [2012] 12 SCR 256 - referred to.
OTHER CASE DETAILS INCLUDING IMPUGNED
ORDER AND APPEARANCES
CRIMINAL APPELLATE/ORIGINAL/INHERENT JURISDICTION
: Criminal Appeal No.1255 of 1999.
From the Judgment and Order dated 22.02.1999-25.02.1999 of the
High Court of Judicature at Bombay in Criminal Writ Petition No.1146 of
1997.
With
Criminal Appeal Nos.1256, 1367 of 1999, Contempt Petition (Civil)
No.47 of 2011 In Writ Petition (C) No.316 Of 2008, Tc (C) No.27 of 2011
And Writ Petition (Civil) No.316 Of 2008
Appearances:
Gopal Sankaranarayanan, Sr. Adv. (AC)
Arunabh Choudhury, Sr. Adv., Dhiraj, Ashutosh Dubey, Mrs.
Anshu Vachher, Akshat Vachher, Ms. Abhiti Vachher, P. N. Puri, Prashant
Bhushan, Aditya Sharma, Ms. Apurba Pattanayak, M/s. Parekh & Co., Ms.
Sumita Hazarika, Ms. Ruchi Kohli, Ms. Shobha Gupta, Aditya Ranjan,
Ms. Jessy Kurian, Ms. Tarjana Rai, Aaditya Aniruddha Pande, Siddharth
Dharmadhikari, Bharat Bagla, Sourav Singh, Aditya Krishna, T A
Khan, Wasim Quadri, Chinmayee Chandra, Mrs. Swarupama Chaturvedi,
Arvind Kumar Sharma, Ms. Diksha Rai, Ms. Ragani Pandey, Ms. Pragya
Baghel, Jayant Mohan, D. S. Mahra, Anil K. Chopra, Anil Shrivastav,
P. V. Yogeswaran, Guntur Prabhakar, Dr. Monika Gusain, Ms. Suvarna
Singh, Sanjay Kumar Visen, Amit Anand Tiwari, Ms. Devyani Gupta,
Ms. Tanvi Anand, M/s. Corporate Law Group, Samir Ali Khan, D. Mahesh
Babu, Jatinder Kumar Bhatia, Krishnam Mishra, Param Kumar Mishra,
T. Mahipal, Gopal Singh, M. R. Shamshad, Manish Kumar, Ms. Shaswati
PEOPLE'S UNION FOR CIVIL LIBERTIES v. THE STATE OF
MAHARASHTRA
372
SUPREME COURT REPORTS
[2023] 12 S.C.R.
Parhi, Ravi Shanker Jha, Ranjan Mukherjee, Ms. Sharmila Upadhyay,
Sarvjit Pratap Singh, M/s. Coac, Ms. G. Indira, Abhisth Kumar, Ashok
Kumar Singh, Ms. Hemantika Wahi, Shuvodeep Roy, Deepayan Dutta,
Chanchal Kumar Ganguli, Praveen Agrawal, Mukesh Kumar Maroria, M.
Shoeb Alam, M/s. Karanjawala & Co. Ms. Tulika Mukherjee, Sudarshan
Rajan, Sunny Choudhary, V. K. Verma, Rajat Srivastav, T.C. Kaushik,
Tarun Verma, Rajat Arora, Shibashish Misra, Hrishikesh Baruah, Saumitra
Srivastava, Ms. Radhika Gupta, Ms. Ruchira Goel, Rajiv Kumar Sinha,
Raj Kumar, Kapil Sahni

## Text

[2023] 12 S.C.R. 370 : 2023 INSC 833
CASE DETAILS
PEOPLE'S UNION FOR CIVIL LIBERTIES AND ANR.
v.
THE STATE OF MAHARASHTRA AND ORS.
(Criminal Appeal No. 1255 of 1999)
SEPTEMBER 13, 2023
[DR. DHANANJAYA Y. CHANDRACHUD, CJI,
PAMIDIGHANTAM SRI NARASIMHA AND
MANOJ MISRA, JJ.]
HEADNOTES
Issue for consideration: Matter pertains to the modalities to be followed
by the police in conducting media briefi ngs during criminal investigation.
Media - Media briefi ngs/reporting by police personnel - Propriety
and procedure:
Held: Media reporting in criminal matters involves degree of public
interest associated with the fundamental right u/Art. 19(1)(a) - Guidelines for
conducting media briefi ngs were prepared by the Union Ministry of Home
Aff airs over a decade ago - Since then with the upsurge in the reporting
of crime, the print media, the electronic and social media have evolved
signifi cantly - There should be a Standard Operating Procedure which
balances out the considerations - There is a need to have a uniform policy
- Nature of the disclosure cannot be uniform since it must depend upon the
nature of the crime and the profi le of the stake holders, including victims,
witnesses and the accused themselves - Disclosure should not result in a
media trial - Media trials are liable to result in a derailment of justice by
impacting upon the evidence adduced and its assessment by the adjudicating
authorities - In view thereof, the Union Ministry of Home Aff airs to prepare
a comprehensive manual/guidelines on media briefi ngs by police personnel,
within the stipulated period - Issuance of direction to all the Directors
General of Police to give their suggestions to the Union Ministry of Home
Aff airs and the views of National Human Rights Commission would also
be considered.[Paras 6, 17,18,19 and 20]
370
371
LIST OF CITATIONS AND OTHER REFERENCES
People's Union for Civil Liberties v State of Maharashtra (2014) 10
SCC 635: [2014] 12 SCR 54; A K Gopalan v Noordeen (1969) 2 SCC 734;
Sahara India Real Estate Corporation Limited v Securities and Exchange
Board of India (2012) 10 SCC 603: [2012] 12 SCR 256 - referred to.
OTHER CASE DETAILS INCLUDING IMPUGNED
ORDER AND APPEARANCES
CRIMINAL APPELLATE/ORIGINAL/INHERENT JURISDICTION
: Criminal Appeal No.1255 of 1999.
From the Judgment and Order dated 22.02.1999-25.02.1999 of the
High Court of Judicature at Bombay in Criminal Writ Petition No.1146 of
1997.
With
Criminal Appeal Nos.1256, 1367 of 1999, Contempt Petition (Civil)
No.47 of 2011 In Writ Petition (C) No.316 Of 2008, Tc (C) No.27 of 2011
And Writ Petition (Civil) No.316 Of 2008
Appearances:
Gopal Sankaranarayanan, Sr. Adv. (AC)
Arunabh Choudhury, Sr. Adv., Dhiraj, Ashutosh Dubey, Mrs.
Anshu Vachher, Akshat Vachher, Ms. Abhiti Vachher, P. N. Puri, Prashant
Bhushan, Aditya Sharma, Ms. Apurba Pattanayak, M/s. Parekh & Co., Ms.
Sumita Hazarika, Ms. Ruchi Kohli, Ms. Shobha Gupta, Aditya Ranjan,
Ms. Jessy Kurian, Ms. Tarjana Rai, Aaditya Aniruddha Pande, Siddharth
Dharmadhikari, Bharat Bagla, Sourav Singh, Aditya Krishna, T A
Khan, Wasim Quadri, Chinmayee Chandra, Mrs. Swarupama Chaturvedi,
Arvind Kumar Sharma, Ms. Diksha Rai, Ms. Ragani Pandey, Ms. Pragya
Baghel, Jayant Mohan, D. S. Mahra, Anil K. Chopra, Anil Shrivastav,
P. V. Yogeswaran, Guntur Prabhakar, Dr. Monika Gusain, Ms. Suvarna
Singh, Sanjay Kumar Visen, Amit Anand Tiwari, Ms. Devyani Gupta,
Ms. Tanvi Anand, M/s. Corporate Law Group, Samir Ali Khan, D. Mahesh
Babu, Jatinder Kumar Bhatia, Krishnam Mishra, Param Kumar Mishra,
T. Mahipal, Gopal Singh, M. R. Shamshad, Manish Kumar, Ms. Shaswati
PEOPLE'S UNION FOR CIVIL LIBERTIES v. THE STATE OF
MAHARASHTRA
372
SUPREME COURT REPORTS
[2023] 12 S.C.R.
Parhi, Ravi Shanker Jha, Ranjan Mukherjee, Ms. Sharmila Upadhyay,
Sarvjit Pratap Singh, M/s. Coac, Ms. G. Indira, Abhisth Kumar, Ashok
Kumar Singh, Ms. Hemantika Wahi, Shuvodeep Roy, Deepayan Dutta,
Chanchal Kumar Ganguli, Praveen Agrawal, Mukesh Kumar Maroria, M.
Shoeb Alam, M/s. Karanjawala & Co. Ms. Tulika Mukherjee, Sudarshan
Rajan, Sunny Choudhary, V. K. Verma, Rajat Srivastav, T.C. Kaushik,
Tarun Verma, Rajat Arora, Shibashish Misra, Hrishikesh Baruah, Saumitra
Srivastava, Ms. Radhika Gupta, Ms. Ruchira Goel, Rajiv Kumar Sinha,
Raj Kumar, Kapil Sahni, Sabarish Subramanian, Vishnu Unnikrishnan, C
Kranthi Kumar, Naman Dwivedi, Danish Saifi , Ms. Vanshaja Shukla, Ms.
Rachana Gandhi, Saurabh Trivedi, Ashutosh Kumar Sharma, Aravindh S.,
Abbas, Pukhrambam Ramesh Kumar, Karun Shrama, Abhinav Mukerji,
Raghvendra Kumar, Anand Kumar Dubey, Jainendra Ojha, Simanta Kumar,
Pradeep Misra, Daleep Dhyani, Manoj Kumar Sharma, Suraj Singh,
Bhuwan Chandra, Ashok Panigrahi, Merusagar Samantaray, Ms. Swarupama
Chaturvedi, Subhasish Mohanty, Ms. Jaspreet Gogia, Ms. K. Enatoli Sema,
G. Prakash, M. Yogesh Kanna, Ms. Pragati Neekhra, Arvind H. S., M/s
Arputham Aruna & Co. V.K. Sharma, V.N. Raghupathy, M.K. Maroria,
Krishnanand Pandey, Advs. for the appearing parties.
Petitioner-in-person
JUDGMENT / ORDER OF THE SUPREME COURT
ORDER
1. This batch of cases raises two signifi cant issues:
(i)
The procedure to be followed by the police in investigating police
encounters; and
(ii) The propriety and procedure of media briefings by police
personnel.
2. The fi rst issue, governing police encounters, has since been dealt
with in the judgment of this Court dated 23 September 2014 in People's
Union for Civil Liberties v State of Maharashtra1.
1
 (2014) 10 SCC 635
373
3. The second issue pertains to the modalities to be followed by the
police in conducting media briefi ngs where a criminal investigation for an
alleged off ence is in progress. The issue assumes signifi cance, particularly, in
the context of the manner in which media reportage takes place, particularly
in crimes involving a degree of public interest.
4. Having regard to the ramifi cations of the issues involved, the Court
appointed Mr Gopal Sankaranarayanan, senior counsel, as Amicus Curiae.
5. A questionnaire was circulated by the Amicus Curiae in order to
elicit information from the States and Union Territories. Several States,
including the States of Bihar, Goa, Haryana, Jharkhand, Rajasthan, Tamil
Nadu and Uttarakhand have responded, besides the Administrations of
Andaman and Nicobar Islands, Chandigarh and Puducherry. Observations
have been submitted by the People's Union for Civil Liberties, one of the
appellants in the batch of cases. Other States, including the States of Assam,
Chhattisgarh, Himachal Pradesh and Madhya Pradesh have served copies
of the replies fi led by them in a connected petition2.
6. Media reporting on matters involving the commission of crimes
involves several aspects bearing on public interest. At a basic level, the
fundamental right to free speech and expression is directly implicated. This
engages the right of the media to disseminate news, views and information
and the right of the viewing public or readers of printed news. There can be
no gainsaying the fact that both the media in pursuance of its fundamental
right to the freedom of speech and expression as well as the consumers of
news, information and ideas have a right to disseminate and to receive fair
and unbiased information. Criminal off ences and investigation into them
by the law enforcement machinery involves signifi cant elements of public
interest bearing upon the right to be informed and the right to know.
7. At the same time, there are competing considerations which are also
of immense signifi cance. At one level, the accused whose conduct is under
investigation is entitled to a fair and unbiased investigation by the police.
Unfair reporting by the media has the potential to aff ect public opinion and
impinge upon the presumption of innocence which is one of the cardinal
2
 Surat Singh v Union of India (Writ Petition (C) No 316 of 2008)
PEOPLE'S UNION FOR CIVIL LIBERTIES v. THE STATE OF
MAHARASHTRA
374
SUPREME COURT REPORTS
[2023] 12 S.C.R.
principles of criminal jurisprudence. At the stage of the investigation and
even trial, every accused is entitled to the presumption of innocence. Media
reportage in a manner which implicates the culpability of the person who is
under investigation is liable to seriously impinge upon the reputation and
personal dignity of the individual under investigation. Biased reporting
also gives rise to public suspicion that the person under investigation
has committed the off ence though the complicity of the accused is yet to
be investigated and, if a charge-sheet is submitted to be subjected to the
administration of criminal justice in accordance with law.
8. At another level, media reportage also impinges upon the right of
victims or, as the case may be, survivors of crimes. In a given case, the
victim may be a minor. In some cases, the nature of the crime may involve
the privacy of the victim, in cases such as those involving gender violence.
The publication of photographs and visuals of the bodies of deceased victims
of crime aff ects the very notion of preserving the dignity in death.
9. While a disclosure by the media of relevant details involves public
interest associated with the fundamental right under Article 19(1)(a) of the
Constitution, equally, the rights of the accused and of the victims or, as the
case may be, survivors of crimes have a direct bearing on the fundamental
right to life and personal liberty which is protected by Article 21.
10. At this stage, it would be material to note the provisions of the
Explanation to Section 3 of the Contempt of Courts Act 1971, which reads
as follows:
"Explanation.-For the purposes of this section, a judicial proceeding-
(a) is said to be pending-
(A) in the case of a civil proceeding, when it is instituted by
the fi ling of a plaint or otherwise,
(B) in the case of a criminal proceeding under the Code of
Criminal Procedure, 1898 (5 of 1898)1., or any other law-
(i) where it relates to the commission of an off ence, when the
charge-sheet or challan is fi led, or when the court issues
summons or warrant, as the case may be, against the
accused, and
375
(ii) in any other case, when the court takes cognizance of the matter
to which the proceeding relates, and in the case of a civil or
criminal proceeding, shall be deemed to continue to be pending
until it is heard and fi nally decided, that is to say, in a case where
an appeal or revision is competent, until the appeal or revision
is heard and fi nally decided or, where no appeal or revision is
preferred, until the period of limitation prescribed for such appeal
or revision has expired;
(b) which has been heard and fi nally decided shall not be deemed
to be pending merely by reason of the fact that proceedings for
the execution of the decree, order or sentence passed therein are
pending."
11. The manner in which the Explanation has been incorporated
may expose a person to a charge of contempt for reporting on a criminal
proceeding only after the charge-sheet has been fi led or, as the case may
be, cognizance taken or summons/warrant issued. The two hundredth
Report of the Law Commission chaired by Justice M Jagannadha Rao, a
former Judge of this Court, noted the background of the provision as it arose
upon the report of the Bhargava Committee under the auspices of a Joint
Committee of Parliament. The Amicus Curiae has adverted to the fact that
the report of the Bhargava Committee did not take notice of the decision
in A K Gopalan v Noordeen3 which treated the arrest of an accused as
the point of commencement for taking cognizance of criminal contempt.
The Law Commission in these circumstances made recommendations for
remedying the situation.
12. The ambit of these proceedings is confi ned to the pre-trial stage
where the investigation has been initiated and is continuing. The Amicus
Curiae submitted that any disclosure by the police about an investigation
must be cognizant of the fact that the information as disclosed impacts
not only upon the victim of the crime and the accused, but on the rule of
law. In its decision in Sahara India Real Estate Corporation Limited
v Securities and Exchange Board of India4, this Court underscored the
3
 (1969) 2 SCC 734
4
 (2012) 10 SCC 603
PEOPLE'S UNION FOR CIVIL LIBERTIES v. THE STATE OF
MAHARASHTRA
376
SUPREME COURT REPORTS
[2023] 12 S.C.R.
need to maintain the balance between the right of the accused under Article
21 and the right of the media/public under Article 19(1)(a).
13. During the course of the submissions, the issues which have
been raised by the Amicus Curiae in the written note of submissions
are as follows:
"1. Who can brief the media?
2.
At what stage is the briefi ng done?
3.
How much information is to be shared at each stage?
4.
What information cannot be shared?
5.
Is the information to be shared or conveyed verbally or in writing?
6.
What safeguards to be followed (no names of victims, no
photos of accused who have to stand Test Identifi cation Parade,
no opinions/judgments, no disclosure of line of investigation
or technical knowhow, no information in National Security
issues)
7.
Whether copies of Press Releases are maintained by the police
department?
8.
Disciplinary action against officers who do not abide by
instructions."
14. A painstaking exercise has been conducted by the Amicus Curiae
in preparing a compilation containing:
(i)
The Media Relations Handbook of the Los Angeles Police
Department;
(ii) The Press Relations Notice of the New York Police Department;
(iii) The Communication's Advisory of the Association of Chief
Police Offi cers, UK;
(iv) The Standard Operating Procedure issued by the Metropolitan
Police, London in regard to Media Relations in June 2012;
(v) The Dorset Police's Media Relations Guidelines;
377
(vi) The instructions prepared by the Central Bureau of Investigation
more specifi cally in paragraphs 24.9 to 24.31 of the CBI Manual
titled "Policy Division"; and
(vii) The Offi ce Memorandum dated 1 April 2010 issued by the Union
Ministry of Home Aff airs which contains an advisory on the
media policy of the police.
15. At this stage, it would be material to note that among the statutory
provisions, the following have a broad bearing on the issues which are raised
in the course of the proceedings:
•
Section 228-A of the Indian Penal Code, 1860
•
Section 327 of the Criminal Procedure Code, 1973
•
Section 74 of the Juvenile Justice Act, 2015 (earlier Section 21 of
the Juvenile Justice Act, 2000)
•
Sections 8(1)(g) & (h) and 8(2) of the Right to Information Act,
2005
16. The Amicus Curiae has prepared the following suggestions on
the basis of which appropriate guidelines can be formulated for conducting
media briefi ngs:
"1. Each district or town ought to have a Media Briefi ng Cell (MBC)
for interactions with the media. Such interaction / Press Releases
must be in writing and with the authorization of a senior police
offi cer. Press Briefs must be prepared on each case, which will
be the basis of any media briefi ngs.
2.
The briefi ng of the press can be done at any stage after an FIR has
been registered, an arrest eff ected or a raid conducted. However,
at the earliest stages, very little information must be parted with,
as facts would need full and complete confi rmation.
3.
Notwithstanding anything else, the primary concern of the
police ought to be the fair administration of justice without
compromising on individual rights of privacy or of presumption
of innocence.
PEOPLE'S UNION FOR CIVIL LIBERTIES v. THE STATE OF
MAHARASHTRA
378
SUPREME COURT REPORTS
[2023] 12 S.C.R.
4.
Information ought not to be released which would portray the
police as insensitive or vindictive or which would suggest the
pre-judging of an issue.
5.
The location of the offence, especially in the context of
harassment, domestic violence, stalking etc., ought to be avoided
as it would compromise the victim.
6.
In no circumstances may the identity of victims of sexual off ences
and juvenile cases be divulged by the police. The same may
apply to the victims of continuing off ences, i.e. abductions and
kidnapping. The police would also be careful to share details of
ongoing operations or investigative strategy that would alert the
off enders or compromise witnesses confi dential informants.
7.
The Press Briefs will be maintained as permanent records of
the media interactions of the police, with one copy at the Police
Station in question, one at the MBC and one at the District
Headquarters. All such briefs will be provided online as well.
8.
Any breach of the above Guidelines must be strictly dealt with
departmentally, so that any such misadventure may be deterred."
17. The guidelines of the Union Ministry of Home Aff airs were
prepared over a decade ago on 1 April 2010. Since then, with the upsurge
in the reporting of crime not only in the print media, but in the electronic
and social media, it becomes extremely important that there should be
a Standard Operating Procedure which balances out the considerations
which we have noted above. There can be no denying the fact that the
disclosure of an offi cial version of the investigation would ensure against
speculative crime reporting, which may be of a dis-service both to the
public interest involved and the interest of the accused, prospective
witnesses as well as the victims and survivors of crime. There is, in
that sense, a need to have a uniform policy which can be adopted for
nominating nodal offi cers who would be available to share the offi cial
version at the stage of investigation, consistent with the need to ensure
that the disclosure itself does not derail the course of the investigation.
The nature of the disclosure cannot be uniform since it must depend upon
the nature of the crime and the profi le of the stake holders, including
379
victims, witnesses and the accused themselves. The age and gender of
the accused as well as of the victims would have a signifi cant bearing
on the nature of the disclosure to be made. It is equally important to
emphasise that the nature of the disclosure which is made by the police
in the course of media briefi ngs should be objective in nature and should
not consist of a subjective opinion pre-judging the guilt of the accused.
The guidelines must duly factor in the need to ensure that the disclosure
does not result in a media trial so as to allow for the pre-judging of the
guilt of the accused. Media trials are liable to result in a derailment of
justice by impacting upon the evidence which would be adduced and its
assessment by the adjudicating authorities.
18. Bearing in mind the above aspects, we are of the view that the
Union Ministry of Home Aff airs should prepare a comprehensive manual
on media briefi ngs by police personnel. Some of the considerations which
would weigh in balancing various issues of public interest while the framing
of guidelines have been fl agged in the earlier part of this order as well
as in the questionnaire and the guidelines which have been prepared by
the Amicus Curiae. The Amicus Curiae has collated, for the purposes of
formulation, the practices which have been followed by police departments
in other jurisdictions and by the Central Bureau of Investigation and Union
Ministry of Home Aff airs in India.
19. We direct that all the Directors General of Police shall, within a
period of one month from the date of this order, communicate to the Union
Ministry of Home Aff airs their suggestions for the preparation of appropriate
guidelines. Thereafter, the Union Ministry of Home Aff airs shall proceed to
prepare the guidelines after considering the views which have been received
from the Directors General of Police and after consulting other stake holders
including representative segments of the print and electronic media who
may have suggestions on the issue. Organisations representing the print and
electronic media should also be consulted.
20. The National Human Rights Commission which has been
represented by Ms Shobha Gupta, counsel, has also prepared its response
to the questionnaire which was circulated by the Amicus Curiae. The view
point of the National Human Rights Commission shall also be duly taken
into consideration.
PEOPLE'S UNION FOR CIVIL LIBERTIES v. THE STATE OF
MAHARASHTRA
380
SUPREME COURT REPORTS
[2023] 12 S.C.R.
21. This exercise shall be completed by the Union Ministry of Home
Aff airs by 31 December 2023.
22 .The Union Ministry of Home Aff airs shall furnish a copy of the
guidelines to the Amicus Curiae, Mr Gopal Sankaranarayanan, and to Ms
Shobha Gupta, counsel for the National Human Rights Commission.
 23. List the proceedings in the second week of January 2024.
Headnotes prepared by:
Directions issued.
Nidhi Jain