Right to Privacy and Freedom of Press: R. Rajagopal v. State of Tamil Nadu (1994)

The landmark judgment in R. Rajagopal v. State of Tamil Nadu laid the foundation for recognizing the right to privacy as a fundamental right in India. The case arose when Rajagopal, a journalist, sought to publish an autobiography that revealed personal details of a convicted criminal known as Auto Shankar. The Tamil Nadu government issued an injunction to restrain publication, citing concerns over privacy and defamation.

The Supreme Court had to navigate the complex terrain of balancing the freedom of the press (Article 19(1)(a)) with the right to privacy (implied under Article 21). The court ruled that the right to privacy is an essential part of personal liberty, but it is not absolute. Freedom of speech and expression could be restricted if publication invades privacy without legitimate public interest. The judgment emphasized that while the media plays a vital role in democracy by informing the public, it must exercise this freedom responsibly and ethically.

This ruling became a cornerstone for subsequent privacy jurisprudence and helped develop India’s understanding of privacy rights long before the Puttaswamy case. It set guidelines on how media can balance transparency with respect for personal dignity, signaling that not every private detail is fair game for publication.

Mullick & Co. Advocates views this case as a critical milestone in Indian constitutional law that underscores the need to protect individual privacy without undermining the press’s essential democratic function. Our approach reflects this balance, advising clients on privacy rights and media law to safeguard their interests in today’s digital world where the boundaries of privacy are continuously tested.