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Aroon Purie vs. State of NCT of Delhi & Ors.

Criminal Appeal · 2022 INSC 1142Decided 31 Oct 2022
Criminal Appeal Nos. 1853-1856 of 2022
Uday Umesh Lalit · Bela M. Trivedi · S. Ravindra Bhat

Background

India Today magazine published a 2007 article ("Mission Misconduct") reporting that an Indian Foreign Service officer posted in the UK had been recalled over sexual harassment and corruption allegations. The officer later filed a private criminal complaint alleging defamation against the magazine's Editor-in-Chief (Aroon Purie), the article's author (Saurabh Shukla), and several Ministry of External Affairs officials who had handled the underlying disciplinary matter. A magistrate summoned several of the accused, and the Delhi High Court declined to quash the summoning order, prompting these appeals to the Supreme Court.

Decision Breakdown

The Supreme Court held that while the statutory presumption of responsibility under Section 7 of the Press and Registration of Books Act applies to an "Editor," it does not automatically extend to a Chief Editor/Editor-in-Chief: such a person can only be prosecuted if the complaint contains specific, sufficient allegations of their actual knowledge and involvement. Finding no such specific allegations against Aroon Purie, the Court quashed the complaint and summoning order against him. It similarly quashed proceedings against the public servants, holding their conduct (reporting matters to superiors) was protected under the "public good" exception to defamation. However, the Court declined to quash proceedings against the article's author, Saurabh Shukla, holding that whether his conduct was journalistically justified was a factual question to be examined only at trial.

Lesson Learnt

A publication's top editor cannot automatically be held criminally liable for defamatory content merely by virtue of their position: a complainant must specifically allege the editor's actual knowledge and control over the particular content; but the reporter/author who actually wrote the piece does not get the benefit of early quashal and must generally face trial to establish any defence.

Official source (sci.gov.in)View Judgment (PDF)

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