The case was about an auto driver named Shankar who was accused of murder and was sentenced to the death penalty for the same. When he was serving life imprisonment in prison, he wrote an autobiography book that enumerated the relationship and connections he shared with many senior prison authorities and state officials who had been his partners and were involved in many illegal acts. Before his death, he gave the book to his wife and asked her to ensure that it gets published in the esteemed columns of the magazine of the petitioner named “Nakeeran”.

Later on, having come to know about this, the inspector general of prison sent a letter to the petitioners stating that the information contained in the book is false and defamatory in nature and that publishing the same would amount to acting against their rules. In addition, he also further threatened to take necessary legal action in case it gets published. After realizing that the higher officials would certainly interfere with the publication, so to restrain their actions they filed a suit in order to protect and safeguard their freedom to print under Article 19 (1) of the Indian constitution. However, the petition was dismissed by the high court and later on the matter was brought before the supreme court by bringing a suit with reference to article 32 of the constitution and sought to restrain the respondent from intervening with the publication.

The Supreme Court ruled that a prisoner possesses the full right to publish their autobiography, and a publisher can also publish it without the prisoner's prior consent, especially if the content falls under public records. The Court cited landmark cases like Kharak Singh v. State of U.P. and Gobind v. State of M.P. to establish that the right to privacy is an inherent part of fundamental rights like personal liberty, freedom of movement, and speech. However, it emphasized that this right is not absolute and must be balanced on a case-by-case basis. The Court declared the right to privacy as a fundamental right implicit in Article 21 of the Constitution. Additionally, public officials cannot sue for defamation related to their official duties unless the publication is proven to be false. No laws or provisions allow officials to impose arbitrary restrictions on the press or media.

The court ruled that articles falling under the category of public records can be published without the consent of the concerned individual, such as Shankar. However, the publication of personal information requires explicit consent to avoid violating the individual's right to privacy. The court clarified that the right to privacy is not absolute and its application varies based on specific circumstances. Over time, the legislature has been actively working to establish guidelines to ensure the appropriate application of privacy rights in society. While the state cannot arbitrarily restrict publication, it must provide adequate legal remedies for individuals whose rights are infringed upon.