Whenever two fundamental rights compete, the Court will balance the two to allow the meaningful exercise of both.
the Right to Information Act, 2005. The Act balances the citizen’s right to know under Article 19(1)(a) with the right to fair investigation and right to privacy under Article 21. This careful balancing was explained by this Court in Thalappalam Service Cooperative Bank Ltd. vs. State of Kerala4 . The decision of this Court in R. Rajagopal alias R.R. Gopal vs. State of T.N.5 is another example of reading down the restrictions (in the form of defamation) on the right to free speech under Article 19(2), in its application to public officials and public figures in larger public interest. Again, in People’s Union for Civil Liberties (PUCL) vs. Union of India6 , the right to privacy of the spouse of the candidate contesting the election was declared as subordinate to the citizens’ right to know under Article 19(1)(a). In Jumuna Prasad Mukhariya vs. 4 (2013) 16 SCC 82 5 (1994) 6 SCC 632 6 (2003) 4 SCC 399 12 Lachhi Ram7 , a challenge to Sections 123(5) and 124(5) of the Representation of the People Act, 1951 (as they prevailed at that time) was rejected, on the ground that false personal attacks against the contesting candidate was not violative of the right to free speech. But when it comes to private citizens who are not public functionaries, the right to privacy under Article 21 was held to trump the right to know under Article 19(1)(a). This was in the case of Ram Jethmalani vs. Union of India8 , which concerned the right to privacy of account holders. In Sahara India Real Estate Corporation Limited vs. Securities and Exchange Board of India9 , this Court struck a balance between the right of the media under Article 19(1)(a) with the right to fair trial under Article 21. The argument that free speech under Article 19(1)(a) was a higher right than the right to reputation under Article 21 was rejected by this Court in Subramanian Swamy vs. Union of India, Ministry of Law10in which Section 499 IPC was under challenge. The right to free speech was balanced with the right to pollution free life in Noise Pollution (V.), in Re11 and the right to fair trial of the accused was balanced with the right to fair trial of the victim in Asha Ranjan vs. State of Bihar12 .