INFORMATION TECHNOLOGY LAW PROJECT

CYBER OBSCENITY

Submitted by
Pavitra Shivhare
Roll Number: 44
B.A. LL.B. (Hons.)
Batch: 2014-19
Of Law School,
Banaras Hindu University, Varanasi
In
November, 2016
Under the guidance of
Prof. G.P. Sahoo

ACKNOWLEDGMENT
I am using this opportunity to express gratitude to everyone who supported me
throughout the course of this project. I am thankful for their aspiring guidance.
I express warm thanks to Prof. G.P. Sahoo, his guidance for the completion of this
project as I believe it would not have been possible without his support.
I would like to thanks my professor and the people who provided me with the
facility required and conductive conditions for my Information Technology Project

Thank You,
Pavitra Shivhare
Roll No. 44

Cyber Obscenity
Introduction:
Cyberspace, driven by Information Technology world, has profoundly changed lives of masses,
bringing out immense transformation in the living style of the people. The term Cyberspace is
coined to mean and include the whole gamut of Information Technology in general and
Computers and network of computers i.e. internet.The Internet, as one of the crucial facets of
Cyberspace, has often been condemned over the availability of pornography. The growth of the
Internet has created an entirely new medium for the dissemination of messages, images, and
pictures including pornographic ones. Not only has the content been criticized, but also its nature
of being easily available for users of all ages. The worldwide nature of such material as well as
the ability to download images makes the system virtually impossible to censor.
Cyberspace- prone to porn:
The Internet has enabled new forms of human interactions through instant messaging, Internet
forums, and social networking. These digital extensions give the ordinary user extraordinary
capabilities. But these extensions also enable the carrying out of illegal activities. The worldwide
nature of such material as well as the ability to download images makes the system virtually
impossible to censor.Traditional mediums of obscenity included films, prints and text books,
public andprivate shows and circulation of material, etc., which are comparatively easier to
regulate when compared to electronic mediums such as picture, short animated movies, sound
files and videos. Moreover internet also makes it possible to discuss Sex (literature, queries,
consultations, chat groups, etc.), see live sex video footage, etc.

Conceptual framework of Obscenity:

It is very difficult to define the term obscenity or pornography and thereby to regulate it.
Ideological and cultural differences are the main factors behind this lack of uniformity along
with the problem of identification. Thus the objective here is to identify a definition of obscenity
that preserves the power of legislature to uphold public welfare without impeding a citizens
right to freedom of speech and expression.Even though the word obscene is not defined in the
Indian Penal Code, 1860 (IPC), it does talk about selling of obscene material, distribution, etc. as
an offence.The courts have also had an occasion to distinguish obscenity from art and literature
stating that it is necessary to decide whether the obscene information is lascivious and may
deprave minds who find pleasure in such things.
Moving further, even though the Information Technology Act, 2000 (IT Act) has not provided
3

any definition of the term obscenity, it makes certain acts, in relation to obscenity in electronic
form, as punishable. The only difference is that IT Act, 2000 regulates obscenity on electronic
format. If one observes abovementioned provisions i.e. Section 292 of Indian Penal Code, 1860
and Section 67 of IT Act, 2000, the criterion given for purpose of identifying an obscene content
or material which is to be regulated and punished can be determined
In this context it is also pertinent to refer Section 2 (c) of the Indecent Representation of Women
(Prohibition) Act, 1986 defines indecent representation as:
"Indecent representation of women" means the depiction in any manner of the figure of a
woman, her form or body or any part thereof in such a way as to have the effect of being
indecent, or derogatory to, or denigrating, women, or is likely to deprave, corrupt or injure the
public morality or morals.

Thus, aforementioned provisions and criterion provided herein are the guidelines given by
legislature to judiciary and enforcement machinery to identify and prohibit obscenity, online or
offline. What is lacking is uniformity and common definition in order to recognize what amounts
to an obscene content, work or material in a given case.
3

Information Technology Act, Section 67 (2000), Whoever publishes or transmits or causes to be published or
transmitted in the electronic form.
4
Indecent Representation of Women (Prohibition) Act, Section 2 (c) (1986).

Judicial take on obscenity:

5

U.S. Supreme Court in Miller vs. California set out a test for obscenity, which deems a work
obscene if:
The average person, applying contemporary community standards would find that the work,
taken as a whole, appeals to the prurient interest.
6

Under Common Law, for the first time in R. vs. Hicklin, court supplied with test of obscenity. It
has provided by Lord Cockburn that:
Whether the tendency of the material charged as obscene is to deprave and corrupt those
whose minds are open to such immoral influences and into whose hands a publication of this
sort may fall
In a landmark judgment, decided by Bombay High Court in RanjitUdeshi and Ors. Vs. The
7

State, a test has been laid down to identify what material, work or content shall amount to being
obscene by interpreting the word obscene as that, which is offensive to modesty or decency,
lewd, filthy and repulsive.
8

Further in ChandrakantKalyandasKakodkarvs. State of Maharashtra the Supreme Court held:

What is obscenity has not been defined either in section 292 of IPC or in any of the statutes
prohibiting and penalizing, mailing importing, exporting, publishing and selling of obscene
matters. It is the duty of court to consider the obscene passages are so likely to deprave and
corrupt those whose minds are open to influences of this sort and into whose hands the book is
likely to fall and in doing so one must not overlook the influence of the book on the social
morality of our contemporary society.

413 US 15 1973.
1868 LR 3 QB 360,371.
7
AIR 1962 Bom 268.
8
AIR 1970 SC 1390.
6

Moreover, the Supreme Court in Samaresh Bose vs. AmalMitra has wisely noted that, The
concept of obscenity would differ from country to country depending on the standards of morals
of contemporary society.
Recognizing loopholes in the likely audience test laid down in Chandra Kant Kalyan case,
the Supreme Court in Ajay Goswamivs. Union of India

11

10

opined that earlier test of a

community based standard has become redundant in the present age of technology while
holding that prohibition on selling or publishing obscene material is a reasonable restriction
imposed on the freedom of speech and expression provided under Article 19 of the Constitution
-of India. This judgment evolved a Responsible Reader Test which was appreciated and
recognized as the best one by the legal luminaries in the area of Cyber and Criminal law, since
the approach of court in this case was logical as internet has diminished all geographical
boundaries and community standards are rapidly becoming global rather than territory specific.

12

On examining available literature on the matter, it was seen that some authors have meticulously
explained this very act/term of Cyber obscenity by providing some illustrations. Accordingly, it
is mentioned that, what is considered simply sexually explicit but not obscene in USA may well
be considered obscene in India.

13

Obscenity in electronic form& Information Technology Act, 2000/2008:

As discussed earlier, obscenity on the Internet is available in different formats, which is why in
order to cover online obscenity the IT Act has incorporated code of obscenity in Section 67 as
well as in subsequent amendments. So by virtue of this Section any person who creates and
maintains pornographic websites is committing an offence and in some cases cyber caf owners
and managers may also be liable if they knowingly allow their customers to access pornographic

(1985) 4 SCC 289.

AIR 1970 SC 1390.
11
(2007) 1 SCC 143.
12
KARNIKA SETH, COMPUTERS, INTERNET AND NEW TECHNOLOGY LAWS, 382 (1st ed., 2012).
13
ROHAS NAGPAL, COMMENTARY ON INFORMATION TECHNOLOGY ACT (273& 274).
10

14

websites. There is still a problem of ascertaining guilt as most of the pornographic websites are
hosted in countries where cyber pornography and cyber space donot have a resolute ambit.
A plain reading of the relevant section of IT Act reveals that obscenity on internet or in
electronic form following three elements:
acts which publishes transmits, causes to be published
any material, video files, audio files, text files, images, animations and even CDs, Web
sites, Computer, Cell Phones etc.
which is lascivious, appeals to prurient interest, and tends to deprave or corrupt of minds
of the persons.
15

IT Act after certain amendments in 2008 covers all aspects of offences related to cyber
obscenity and provides punishment for:
Violation of privacy (coupled with cyber obscenity)
Publishing or Transmitting obscene material in electronic form
Publishing or transmitting of material containing sexually explicit act, etc. in electronic
form (Section 67 A)
Child pornography (Section 67 B).
Section 67 of the old Act is amended to reduce the term of imprisonment for publishing or
transmitting obscene material in electronic form to 3 years from 5 years and increase the fine
thereof from Indian Rs.100, 000 to Indian Rs.500, 000.
Let us now discuss the gist of Section 67 and its extended version

16

of code of obscenity as

amended by Information Technology (Amendment) Act, 2008/2009. Code of obscenity in

Information Technology Act as discussed above, basically, reflected in its four forms. Those are:
Obscenity in electronic form with respect to any material, or object.
14
ROHAS
15

NAGPAL, INTRODUCTION TO CYBER CRIME: INVESTIGATION 40, (1st ed., 2009).

Information Technology (Amendment) Act, 2008.
16
As opposed to original version of obscenity in the Information Technology Act, 2000.

Obscenity in electronic form with respect to any act or conduct

Obscenity in electronic form featuring or portraying child

17

therein

For the more efficient reading and understanding of the Code of obscenity as featured in the
Information Technology Act, 2000, let us now unleash the ingredients of the provisions in
Information Technology Act, in this context:
18

Section 67 :
Element of offence: Mere publication of any material amounts to impugned act under this
provision. Publication here stands for making available to the public at large in the specified
modes as envisaged by Information Technology Act. Publication as defined by the Whartons
19

Law Lexicon , is the act of publishing anything ; offering it to the public notice, or rending it
accessible to public scrutiny. The word publish has not been defined under the Act. However,
the Supreme Court held in the case of Bennett Coleman & Co. v. Union of India

20

that publish

means dissemination and circulation.

In the context of Information Technology Act, this does mean making available to the public at
large through certain specified mediums in virtual world driven by internet. Those could be:
Social Networking sites;
Emails or email services;
Blogs
Websites or contents on website.
These are the major areas with the help of which or through which obscene content can be
published.
Wrong or act: Transmission, Publication or causes to be transmitted or published
17

In this context as per Explanation added to Section 67B of Information Technology Act, 2000, Children
means a person who has not completed age of 18 years.
18
Information Technology Act, 2000/2008
19
Universal Law Publishing Co., 15th Ed., 2009, at page1394
20

AIR 1986 Bom 321

Condition: Impugned object or material must be obscene or must qualify test of being termed as
obscene one.
21

Tool or Subject-matter: It must be in electronic form . Transmission or publication of such

material is possible by or with the help of Computer, Communication Device or any other
Electronic Device through which electronic communication is possible, including Mobile Phones
or Hand-held phone or Cellular phones which falls in the definition of either computer or
communication device.
Test to be satisfied u/Section 67: The provision which prescribes a test to be satisfied, in order to
prosecute or level charges against or in order to convict an accused, is that the material must be
lascivious or appeals to the prurient interest or if its effect is such as to tend to deprave and
corrupt persons who are likely, having regard to all relevant circumstances, to read, see or hear
the matter contained or embodied in it..
This is test is the reiteration of previous judicial decisions delivered on the basis of Section 292
of the Indian Penal Code (as discussed above) and also the criteria or test given in Section 292 of
Indian Penal Code itself. Abovementioned test is also based on some international authorities
discussed above, wherein Judiciary tried to spell out what amounts to obscenity in general.
Punishment: Under this provision if any person found to be guilty, then he/she shall be punished
on first conviction with imprisonment of either description for a term which may extend to three
years and with fine which may extend to five lakh rupees and in the event of second or
subsequent conviction with imprisonment of either description for a term which may extend to
five years and also with fine which may extend ton ten lakh rupees.
22

Section 67A : Material containing sexually explicit act or conduct

Element of an offence: Mere publication or transmission.

21

Section 2 (r) defines Electronic form as any information generated, sent, received or stored in media,
magnetic, optical, computer memory, micro film, computer generated micro fiche or similar device.
22
Inserted by Information Technology (Amendment) Act, 2008

Wrong/s or act/s prohibited: Publication or transmission or causing to publish or transmit in

electronic form any material which contains sexually explicit act or conduct.
Now it is in this context one can make distinction between obscenity and pornography.
Section 67A by incorporating words Sexually act or conduct contemplated mischiefs of
Pornography which can be found in sexually explicit act or conduct. The Oxford Dictionary

23

defines Pornography as printed or visual material containing explicit description or display of

sexual organs or activity intended to stimulate sexual excitement. So one thing is clear here that
in order to identify pornographic material or act or conduct in electronic form, one need to pass
the test of obscenity. Impugned wrong defined under Section 67A, per se is an offence or
wrong unlike Section 67 wherein it is necessary to pass the test of material being called as
obscene one. The only requirement under Section 67A is, the material or act or conduct, has to
be sexually explicit and as such it must entice sexual excitement. Further Law Lexicon

24

defines

Pornography as: material that depicts erotic behavior and is intended to cause sexual
excitement. So here two conditions are vital: 1) Material must feature behavior or act or
conduct and 2) it must intended to cause sexual excitement. Pornography is, therefore, more
aggravated form of Obscenity, common in both being the quality of offending public decency
and morality.
Condition: Any material (in electronic form) must be sexually explicit act or conduct.
25

Tools or Subject matter: It must be in electronic form . Transmission or publication of such

material is possible by or with the help of Computer, Communication Device or any other
Electronic Device through which electronic communication is possible, including Mobile Phones
or Hand-held phone or Cellular phones which falls in the definition of either computer or
communication device.

23

24

Oxford Dictionary,
Advanced Law Lexicon, LexisNexis Butterworths,
25
Section 2 (r) defines Electronic form as any information generated, sent, received or stored in media,
magnetic, optical, computer memory, micro film, computer generated micro fiche or similar device.

Punishment: Under this provision if any person found to be guilty, then he/she shall be punished
on first conviction with imprisonment of either description for a term which may extent to five
years and with fine which may extend to ten lakh rupees and in the event of second or
subsequent conviction with imprisonment of either description for a term which may extend to
seven years and also with fine which may extend to ten lakh rupees.
26

Section 67B : Material depicting children in sexually explicit act, etc.

Element of an offence: Mere publication or transmission along with strict liability for certain acts
prescribed by the provision.
Wrong/s or act/s prohibited:
Publication or transmission or causing to publish or transmit in electronic form any
material which depict children engaged in sexually explicit act or conduct.
Creation of any text or digital images of in electronic form depicting children in obscene
or indecent or sexually explicit manner;
Whoever collects or seeks or browses, downloads, advertises, promotes, exchanges or
distributes material in electronic form depicting children in obscene or indecent or
sexually explicit manner;
Whoever cultivates, entices or induces children to online relationship with one or more
children for and on sexually explicit act or in a manner that may offend a reasonable adult
on the computer resource;
Whoever facilitates abusing children online,
Whoever records in any electronic form own abuse or that of others pertaining to sexually
explicit act with children.
Now, after having seen the acts or wrongs given in the provision, one may understand the
expanded horizon of this provision which penalizes above mentioned acts, electronic form
pertaining to or depicting children in any of the above mentioned acts, in the form of :
26

Inserted by Information Technology (Amendment) Act, 2008

Obscene or indecent manner

27

Sexually explicit act or conduct

or

28

When it comes to Section 67B of Information Technology Act, 2000, legislature has taken a
special care of online abuse of child in the Cyberspace which is so rampant & easy owing to
certain advantages of Information Technology. Along with publication or transmission of
impugned material, now, as per Information Technology Act, 2000, even browsing and
downloading of material depicting or containing child in an obscene or indecent manner or in
sexually explicit act or conduct is now an offence with severe punishment. Child pornography,
is now a part and parcel of Code of obscenity reflected in the Information Technology Act,
2000, through various wrongs. But then, despite having such an outstanding arrangement dealing
with child pornography, child pornography is rampant and is being committed online with very
ease and with far reaching implications. It is becoming very difficult to put any restriction or ban
on such websites through which such material can be viewed, circulated, distributed and
accessed by everyone, owing borderless nature of technology. Most of the pornographic websites
depicting child is being hosted in foreign countries, making it difficult for Indian Authorities to
tackle, track and put restrictions on those websites and it is equally difficult to ban or filter
pornographic websites as they keep on changing their names, domain address, hosting platform
from time to time making it difficult to filter or to block using technical tools known to
29

Information Technology.

Condition: Sexually explicit act or conduct or obscene or indecent act, material, object, image or
document.
30

Tools or Subject matter: It must be in electronic form . Transmission or publication of such

material is possible by or with the help of Computer, Communication Device or any other
27

This wrong or act is a part of Section 67 of Information Technology Act, 2000

28

This wrong or act is a part of Section 67A of Information Technology Act, 2000
29
30

Press Statement on Child pornography on internet, Ministry of Communication and Information

Technology, Government of India. http://pib.nic.in/newsite/erelease.aspx?relid=74481.
Section 2 (r) defines Electronic form as any information generated, sent, received or stored in media,
magnetic, optical, computer memory, micro film, computer generated micro fiche or similar device.

Electronic Device through which electronic communication is possible, including Mobile Phones
or Hand-held phone or Cellular phones which falls in the definition of either computer or
communication device.
Punishment: Any such person who is convicted under this provision, shall be punished on first
conviction with imprisonment of either description for a term which may extend to five years
and with fine which may extend to ten lakh rupees and in the event of second or subsequent
conviction with imprisonment of either description for a term which may extend to seven years
and also with fine which may extend to ten lakh rupees.
Well, there is one exception added to Section 67, 67A and 67B, which does not apply to or
extend to any book, pamphlet, paper, writing, drawing, painting, representation or figure in
electronic form the publication of which is proved to be justified as being for the public good on
the ground that such book, pamphlet, paper, writing, drawing, painting, representation or figure
is in the interests of science, literature, art or learning or other objects of general concern or
which is kept or used for bona fide heritage or religious purposes. This proviso which is added to
code of obscenity under Information Technology Act, is aims to secure and protect freedom of
speech and expression guaranteed by Constitution of India under Article 19 (1) (a).
In the context of I.T. Act, 2000, there have been famous trials and prosecutions before the court
of law, and courts have had an occasion to deal with the aspects of cyber obscenity in order to
widen its ambit. In the judgment delivered in Avinash Bajaj vs. State of Delhi

31

the Delhi High

court had an occasion to deal with an MMS clip which was listed on Bazee.com for sale through
the website. The question in this case, for the purpose of Section 67, was, whether the website
caused the publication of obscene material. There was a difficulty to book accused under IPC
since Section 292 does not deal with the electronic obscenity. Delhi High Court finally, ordered
that while the case against the petitioner for the offences under Sections 292 and 294 IPC maybe
quashed, his prosecution for the offence under Section 67 read with Section 85, IT Act will
continue.
31
32

32

Held in this case that impugned website has prima facie caused publication of

2005 DRJ 576.

INDIAN KANOON., http://www.indiankanoon.org/doc/309722/

obscene material. Moreover, in M. Saravanan& Dr. L. Prakash&Ors. V. State

33

a doctor

photographed and video recorded several women engaging in obscene activities that he
distributed through internet to make illegal money and the petitioner was prosecuted under
Section 67 of I.T. Act, 2000.
Code of cyber obscenity reflected under Section 67 and in the subsequent amended provisions
contains two crucial words: publication & transmission of obscene information or material in
electronic form. These two words has to be looked from the perspective of extra-territorial
jurisdiction and Internet technologies, keeping in view that obscenity is no longer a local and
static phenomenon and that while interpreting Section 67, the court also has to take in to
consideration the interest of our contemporary society and particularly the influence of the
obscene material in electronic form on it. Any particular work in the form of obscene material
containing special skills should not be misjudged under the guise of contemporary standards so
that discourse in art, labour and skilled work is not discouraged. A proper balance has to be made
out in identifying an electronic obscenity.
Menace of Child pornography in Cyberspace:
Child abuse in the form of child pornography is a burning and emerging issue in the cyber
regulations and requires stringent legal treatment. As discussed above Child pornography is
banned through different acts covered within the ambit of Section 67B of Information
Technology Act, 2000. It is also an offence under Section 292 of Indian Penal Code, 1860. Those
activities are- creating text, digital images, collecting seeking browsing, downloading,
advertising, promoting, exchanging or distributing child pornographic material depicting
children in obscene manner is banned by the said provision. Also any person who entices the
children for and on sexually explicit act or in a manner that may offend a reasonable adult on the
computer resources or abuses children on the internet or records electronically won abuse or that
of others pertaining to sexual explicit act with children is punishable under the Act. Since the
inception of Information Technology Act, 2000 along with its amended version of Act of 2008,
33

MANU/TN/8296/2006 Available at: http://www.manupatrafast.in/pers/Personalized.aspx.

there have many instances of child pornography prosecutions. Child pornography is gaining
popularity due to availability of cheap material from all over the world. Article 9 of Cyber Crime
Convention provides punishment for child pornography. It runs as under:

whoever commits intentionally and without right the following conduct producing child
pornography for the purpose of its distribution through a computer system; offering or
making available child pornography through a computer system; Distributing or
transmitting child pornography through computer system; producing child pornography
through a computer system; possessing child pornography in a computer system or on a
computer data storage medium.
The term Child pornography is also defined in the Convention in the same Article 9 which
shall include- pornographic material that visually depicts: a minor engaged in sexually explicit
conduct and a person appearing to be a minor engaged in sexually explicit conduct.
Information Technology Act, 2000 of India as discussed above runs a similar provision
34

prescribing prohibition for certain acts as given in the Cyber Crime Convention . But
unfortunately, India is not party to such a crucial Convention which deals with the offences or
cyber wrongs which are universal and which defies physical boundaries or jurisdiction of
35

countries . As discussed above, most of the websites depicting child pornography and its
contents, which can be viewed, downloaded or distributed and can be located in India, are
beyond the reach of Enforcement machinery since these kind of offences creates cross-border
issues making it difficult to extradite and prosecute accused, to exercise Indian jurisdiction and
also to ban or block those websites or contents in the website depicting child pornography. In the
wake of such state of affair of child pornography, despite having stringent provisions like Section
67B, it would be difficult to track, tackle, and block such contents depicting child pornography,
internationally. In such a scenario, it is high time now that India must sign and ratify Cyber
Crime Convention so as to tackle global nature offences like child pornography. Moreover,
talking about extradition process which is of immense importance in any crime involving
international element is addressed in a meticulous manner so as to extradite Cybercrime
Criminals. Article 24 of the Convention on Cyber Crime focuses on the same thing and makes
offences defined, provided they are defined as an offence in the both the countries who are party
to the convention. Article 24 is indeed a remarkable step towards an international cooperation in
global nature offences like Cybercrimes which knows no territory and defies territorial
boundaries.
36

Sexual abuse of child on internet, as per the reports of INTERPOL , is on rise owing to rapid
37

abuse of Information Technology. According to the report on Crime against Children , the
spread of internet and technology has led to a huge rise in offending. Offenders can distribute
and access child abuse material more easily and can have direct contact with children.

The Bombay High Court Committee on Protecting Children from Online Pornography, suggested
following recommendations in their Report

38

on Protecting Children from Online Pornography:

Blocking of sites;
Preventing minors from accessing unsuitable material from Cyber Cafes;
Preventing the publication or propagation of pornography from Cyber Cafes.

Conclusion:

To conclude, following findings can be observed through the process of this current discourse:

The word obscene is very wide in its ambit and whatever is vulgar and
indecent should not be construed as such. This is also a global and dynamic
phenomenon and cannot be relegated to being local and static. In identifying
Obscenity over internet or cyberspace or on electronic medium, test to be
resorted should be the same although manner of investigation and way of

prosecution could be different.

The World Wide Web and Internet is a very complex network and is vulnerable to
several illegal activities. In the wake of different electronic instruments having
potential to be used as Computer more threats and challenges are being thrown
before the Law. The IRW Act, 1986 and the provisions of IPC, 1860 along with
the IT Act of 2000/2008 are unable to deal with cyber obscenity, due to the
difficulty in identifying obscene content on the Internet Recognition of obscenity
in a so-called obscene material should not be at the cost of the art, literature and
freedom of speech and expression. Blocking websites, regulating and providing
checks & guidelines for intermediaries, (including Internet Service Providers,
Search Engines, Cyber Cafes or any other person or authority) preventing the
publication of or propagation of pornography from certain forums would be the
viable option to regulate the same.

On a priority basis, the Enforcement Mechanism must get well-equipped, well

informed and trained since they are the ones who are directly responsible for the
prevention, detection, investigation and enforcement of prosecutions of or cases
of Cybercrimes including that of Electronic/cyber obscenity or pornography.

BIBLIOGRAPHY
1.
2.
3.
4.
5.
6.
7.

Basu, Justice Palok. , Modern, New Delhi,2006.

Information Technology Act, 2000
www.thehindu.com
www.privacyinternational.com
www.cyberlawtimes.com
www.indiankanoon.org
http://sajms.com/wp-content/uploads/2015/06/Research-paper.pdf

CONTENT

INTRODUCTION

CYBERSPACE: PRONE TO PORN

CONCEPTUAL FRAMEWORK OF OBSCENITY

JUDICIAL TAKE ON OBSCENITY

OBSCENITY IN ELECTRONIC FORM AND INFORMATION TECHNOLOGY ACT

2000/20008

MENACE OF CHILD PORNOGRAPHY IN CYBERSPACE