It is widely recognized that freedom of speech and expression is 
integral to democracy. There can be no real democracy without citizens 
who are well informed. The media has traditionally played a very 
important role in the working of democracies, through the creation of a 
public sphere where issues of importance to a political community and 
are discussed and debated.

A democratic society depends upon an informed populace making political
choices. In large and complex societies, public participation in 
political processes is already largely limited to occasional expressions 
of opinion and protests, and the periodic selection of representatives 
through the vote. For such weak participation to be effective, the 
public has to know what is going on, and what options they need to 
weigh, debate, and act upon. This is where the media plays a crucial role.

We are of the opinion that the Bill in its current form may have adverse
impacts on democratic processes and the free functioning of media and 
does little to ensure that citizens have access to better and diverse
information. The Bill as it now stands, will give the Government the 
power to censor almost anything it arbitrarily deems undesirable with 
out checks and balances.

The Bill, for instance, gives too overarching a role for the Central
Government, from laying down policy, to nominating/selecting members of 
the BRAI, and the Public Service Broadcasting Council. The identity, as 
well as division of responsibility, and labour between the Central 
Government, the Broadcast Regulatory Authority of India (BRAI) is not clear.

There is no evidence of any intention to set up an independent 
autonomous, professionally competent, regulatory organization in the 
Broadcast sector. According to the provisions of this Bill, the 
regulator will be allegedly autonomous, but it is not clear what powers 
it will have. The Bill gives the Central Government, powers under an 
itemized list of 14 functions which cover what a regulator should be 
doing, that includes terms and conditions of licenses, power to 
prescribe license fees, policy and certification guidelines and so on.

Moreover, in sections 5 and 6 of the Bill, an overreaching power has 
been granted to the Central Government to censor the media during time 
of emergency, or any other 'exceptional circumstances.' This power far 
exceeds the constitutional limitation on the freedom of speech and 
expression. As experience of arbitrary press censorship during the 
Emergency has shown us, such powers are liable to be grossly misused.

The Bill provides for a negligible role for the public and civil society
organisations though the bill is being drafted in the name of the 
public. The Bill provides for a Public Service Broadcasting Council, but 
it is the Government which decides "from time to time" what obligations 
public service broadcasters should follow.

The Bill also cursorily touches upon the topic of cross-media 
restrictions on ownership. It is important to have regulations to 
restrict the concentrations of media ownership and cross-media ownership 
leading to monopolies, but an independent authority, and not the Central 
government should be in-charge. Moreover, the Bill does not really 
address cross-media ownership issues, which generally aim to ensure that 
media companies cannot establish monopolies or achieve market dominance 
across various forms of media - e.g., print/newspapers, radio and 
television. The provisions of the Bill seem to focus exclusively on 
monopoly/dominance within the broadcast sector, particularly vis-à-vis 
content providers and network service providers. It is not even clear 
whether these restrictions apply across television and radio - 
"channels" are mentioned without identifying them further.

The Content Certification Rules, 2007 explores new ground in the
Broadcasting sector by proposing self-regulation. However, the 
provisions contain a number of vague terms that can be easily used to 
restrict freedom of expression on flimsy grounds especially in these 
days of rampant moral policing and the growing tendency of various 
sections of the audience to be shocked and offended.

The Content Code lays down guidelines for what type of programmes are
allowed to be broadcast based on detailed but illogical categorization 
of what type of violence, sex, nudity, horror, and decency can be shown. 
If the provisions of the proposed Content Code are given effect, 
broadcasters will not be able to transmit programmes that violate the 
large number of restrictions laid down in the Code. For instance, the 
Code disallows programmes that show "perverted and socially unacceptable 
practices", programmes that "incite or encourage viewers to obscene 
behaviour", content that "portray women as primarily being driven by 
sexual impulses", programmes that show "prolonged or passionate kissing 
on the lips", content that promotes the use of illegal or narcotic drugs 
and tobacco", and even programmes dealing with exorcism and occult. The 
recent episode when the Union Ministry of Information and Broadcasting 
banned two underwear advertisements for being "indecent' is an indicator 
of the danger of putting in place such guidelines for content of 
television programming.

This submission of Alternative Law forum  seeks to examine the 
implications of the proposed Broadcast Bill and Code, and has 
incorporated changes. These changes seek to protect the freedom of 
speech and expression of the media while at the same time recognizing 
that the media has a responsibility to regulate their content and put in 
place a system to deal with complaints. The changes that we have 
suggested also try to minimize any conflict with already existing laws 
to avoid unnecessary litigation.

See The Reprecentation of ALF at 
http://www.altlawforum.org/ADVOCACY_CAMPAIGNS/Final%20Submission%20to%20MIB.doc


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