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Issues: Interpretation of the term "paper" under Section 3 of the Press and Registration of Books Act, 1867
Analysis: 1. The petitioner was convicted under Section 12 of the Press and Registration of Books Act for not printing the name of the printer on a poster, raising the question of whether the poster qualifies as a "paper" under Section 3 of the Act. 2. The prosecution argued that the poster, although meeting other requirements, should have included the name of the printer as per Section 3. The petitioner contended that the poster did not qualify as a "paper" under Section 3, thus challenging the conviction. 3. The Act lacked a specific definition of the term "paper," leading to conflicting interpretations. Previous cases, such as Rameshwar Parshad v. Emperor and Dattatrya Malhar v. Emperor, discussed the scope of the term "paper" and its relation to newspapers within the Act. 4. The court analyzed the legislative intent behind the Act, considering the title, preamble, and relevant sections to determine the scope of the term "paper" in Section 3. The court emphasized the need for clarity in defining "paper printed" to avoid ambiguity and ensure consistent application of the law. 5. The court rejected the broad interpretation of the term "paper printed" proposed by the prosecution, which would encompass any printed material on paper, including everyday items like invitations or visiting cards. The court agreed with previous judgments that "paper" in Section 3 should be construed in a manner consistent with newspapers or periodicals containing news. 6. In the absence of a clear definition of "paper printed" in the Act, the court held that the poster in question did not fall within the scope of Section 3 as it did not resemble a newspaper, book, or pamphlet in content or form. Therefore, the petitioner's conviction under Section 12 was overturned, emphasizing the need for legislative clarity in defining terms to prevent legal uncertainties. This detailed analysis of the judgment highlights the key issues surrounding the interpretation of the term "paper" under the Press and Registration of Books Act, 1867, and the court's rationale for overturning the petitioner's conviction based on the lack of a precise definition within the legislation.
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