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Kate Burns - of , the Rule of and Political Debate RoLIA Economic and Business

www.ruleoflaw.org.au Legal Update Conference on 02/08/2013. on Conference Update Legal

of Australia (RoLIA). She also lectures in legal at the the at ethics legal in lectures also She (RoLIA). Australia of in experience extensive has She Wales. South New of University she where sector university and the in practice legal cases test interest public significant of number a in instructed criminal of areas the in as well as issues human involving protection. child and law the at speech as a delivered was paper This NSW Educators Commission, has described has Commission, freedom Rights Human protected must be that fragile flower speech “a as of is This where new each generation”. by vigorously part. your play yourselves as such educators of speechfreedomof The sources complex the explain to is me, to it seems difficulty, The speech take in of freedom of the protections that form they legal sources its of terms In . to Australia political of freedom the implied runthe full gamut: law common in the , communication half incorporated international and , which then be need to law, domestic Australian into federal statutory and of the in light interpreted in itself that Explaining those freedoms. on limitations General federal Attorney Former becan a challenge. Institute Law of Rule the of Officer is Chief Burns *Kate The is fortunate that journalists of that of that journalists that fortunate is of The law rule the constant despite work, their hard continue calibre proceedings. contempt and of threat those support needs to the rule law of Conversely, Although opinion. and speech, expression of freedoms of bill entrenched constitutionally a have do not we speech, of freedom guarantees that in Australia rights speechof freedom made that often is the comment and of defamation, the after over left is what is here racial vilification, , , , a name to immunity, interest public and a have least at do have we taken their cut, have few, speech. of freedom the need for about debate robust described has Simpson Shane , Entertainment our with “providing as defamation of the laws apparatus unsatisfactory highly complex, expensive, an their defend can its of which some by of their freedom exercise have others after reputation the of President Triggs, Gillian Professor And speech.” by then members of the NSW Parliament and their and the Parliament NSW of then members by office. with came that the power abusing associates,

Kate Burns* Kate RoLIA and Debate Political

he relationship between , between of freedom relationship he a is the rule law and of opinion and expression prompt . that the judicial system is independent, impartial, impartial, independent, is system the judicial that and a fair provides and transparent and open that the law and its administration is subject to to subject is administration its and the law that and the people, by free criticism and open that the law is made by representatives of the of representatives by made is the law that way, transparent and open in an people

Freedom of Speech, the Rule of Law Law of Rule the Speech, of Freedom 1 describe a ten year history of massive committed committed fraud massive describe history of year a ten Fortunately for the public, acute journalists had had journalists acute the public, for Fortunately that the reports critiqued and digested already respectively. Shortly after they were released, ICAC’s ICAC’s released, were they after Shortly respectively. traffic. of the volume with crashed website of investigative journalists. The three reports that reports that The three journalists. investigative of 40 pages the 174, 44 and inquiry to from ran resulted Australia’s richest men. The inquiry demonstrating inquiry The men. demonstrating richest Australia’s prompted was corruption government of the extent number by a investigations of painstaking years after inquiry into the activities of the Obeid , the Obeid the activities of family, inquiry into of a number and MacDonald Ian Minister former application in the system. application ICAC of the the findings had we this week Just speech, the observe making so can people critique and and their interpretation and laws of application and For the rule of law to function we need freedom of need of freedom function we to the rule law of For • • • collegial one: one supports the other. It is fundamental fundamental is It the other. supports one collegial one: the rule law:to of

Introduction T Michael Lavarch, now executive dean in the Law provisions, the said, require an informed Faculty at the Queensland University of Technology, choice to be made by the people which, in turn, means has a more positive, if macabre, , describing it as there must be free access to political information. “an amalgam of a high-level constitutional skeleton and of flesh supplied by parliaments in various The context for the first case, Nationwide News Pty Ltd laws, particularly anti-discrimination , v Wills was an article in The Australian in November and maintained by our through common 1989 headed “Advance Australia Fascist” which law traditions and decision-making under statutory criticised the integrity and independence of the then provisions”. federal Industrial Relations Commission. Nationwide News, as the publishers of The Australian, was But then even the expression of freedom of speech prosecuted under the Industrial Relations Act for the in its purest form in Article 19 of the International offence of “bringing the Commission into disrepute”. Covenant on Civil and Political Rights is tempered with various provisos. They state that it is limited Nationwide challenged the validity of that offence on by restrictions in law for the respect of the rights or the basis that it was contrary to an implied freedom in reputations of others; and for the protection of national the Constitution to criticise governmental institutions security; or of public order or of public health or subject to reasonable legal constraints. The High Freedom of Speech, the Rule of Law and Political Debate Political and Law of Rule the Speech, of Freedom morals. So there is no easy way out. Visually I think of Court agreed. According to Brennan: freedom of speech as having a strong core insofar as it “To sustain a representative embodying relates to but more malleable the principles prescribed by the Constitution, freedom

Kate Burns - Burns Kate on the outside as legislators and courts respond to of public discussion of political and economic matters changing about the line to be drawn in relation is essential”. to the rights or reputations of others, , public order, public health and morals, to adopt the But, there are limits. In the words of Deane conceptual framework of Article 19. and Toohey:

In what follows I will be taking a look at one aspect of “The Constitution’s implication of a freedom of freedom of speech which is fundamental to the rule of communication with and about the government of the law, namely the freedom of political communications Commonwealth is not an implication of an absolute as it has been interpreted in recent High Court and uncontrolled licence to say or write anything at decisions. But to understand those decisions we first all about matters relating to the government of the need to go back to the last century. Commonwealth. It is an implication of freedom under the law of an ordered society”.

Freedom of political communication: the High In the second case, Australian Capital Pty Court cases Ltd v Commonwealth, which concerned legislation restricting the broadcasting of political In the early 1990s, at a time at which debate about the in the period leading up to an , the High merits of a constitutionally entrenched was Court emphatically confirmed that such legislation in full flight, the High Court announced in two 1992 was unconstitutional as it limited the freedom of decisions that, although there is no explicit mention political communication which is essential to the of freedom of speech in the Australian Constitution, system of responsible government provided for in the in fact a freedom of political communication was to Constitution. be implied from sections 7 and 24 of the Constitution. Those sections provide for the Australian Parliament This implied freedom was expanded upon by the High to be comprised of the Senate “directly chosen by the Court a year later in two cases: Theophanous v Herald people of the State” and the House of Representatives & Weekly Times Ltd and Stephens v West Australian which is to be “composed of members directly Newspapers Ltd. Those cases created a new defence chosen by the people of the Commonwealth”. These to defamation actions involving political figures

RoLIAwww.ruleoflaw.org.au 2 Kate Burns - Freedom of Speech, the Rule of Law and Political Debate Coleman Coleman RoLIA concerned two two concerned Vagrants Gaming and Other Other and Gaming Vagrants www.ruleoflaw.org.au (Qld) for handing out leaflets in Townsville Townsville in leaflets out handing for (Qld) . Patrick Coleman was charged and and charged was Coleman Patrick Student . So now we come to the latest instalments on the state the state on instalments the latest to come we So now according political communication of freedom of 27 on published Court the decisions High to in two thisFebruary year. v Australia South of State the for Attorney-General Adelaide of City the of Corporation OffencesAct type coppers” corrupt your know to “Get stating Mall a local identifying Constable and officers bastards”. lying the “slimy of one as Power Brendan obstructing and assaulting of also was convicted He after a and him scuffle between a police officer police criticising that found Having Power. Constable political communication, of the freedom by covered is the High citizens, police over of the wide power given did not it so that Act the Vagrants Court down read because otherwise political communication, to apply to (being contrary law state be invalid an would it political communication of freedom the implied Coleman leave didn’t that But in the Constitution). his with interfere Court free: the High did not entirely obstructing police. and assault for conviction The 2013 Cases privileged communication. Political communication communication Political communication. privileged angry, exaggerated, robust, often is in Australia appealing commonly and comment fact and mixing this country, In self-interest. and fear prejudice, to should politicaldiscourse ideala philosophical that ideas facts, noble objective be based upon only of the reality to way beliefs gives temperate and highly and irrational sometimes and passionate this in field Communications interchange. charged the to, limited not in, but including discourse of hyperbole, brevity, upon emphasis media, place mass expression”. vivid and image entertainment, recognised political for Kirby Justice low The willI this in countrya matter is communication later. a bit to return in decision Court’s theHigh came 2004 In v Power the under convicted Australia, it is unrealistic to expect the genteel conduct conduct expect to unrealistic is the genteel it Australia, of circumstances other to be appropriate may that

Lange Lange reputation , concerning an an , concerning which dealt with untrue allegations made made allegations untrue with which dealt 3 of an opponent. In the nature of political campaigns in political campaigns of the nature In opponent. an of at least electorally. Often, if not invariably, this invariably, not if Often, electorally. least at the harm to attempts purpose will involve “The purpose of those who support candidates for for “Thepurpose candidates of thosesupport who their opponents, harm to necessarily is such including travel “junkets” at public expense. During public at “junkets” travel including Kirby in the case, Justice his of the course observation that: the true,made if disturbing Roberts v Bass Roberts Parliament, Australian the South of a member against Just how offensive political communication can be can communication political offensive how Just Court the High thein case 2002 of by considered was particular law? If it is not, then the law will then the be law invalid not, is it particular If law? the Constitution. to contrary as to serve a legitimate end which is compatible with with compatible which is end serveto a legitimate responsible and representative of the maintenance the of the objectives account taking into government, about government or political matters? And, if it if it And, political matters? or government about adapted and appropriate reasonably does, the law is whether a law is contrary to the implied freedom of of freedom the implied to contrary is whether a law does first, asking involves It political communication. of communication freedom burden effectively the law In its unanimous judgement, the Court came up the Court up came judgement, unanimous its In assess to test” the “Lange as known now is what with The Lange test The Lange those whothem. staff executive government including the public service, the public including government executive and government” of agencies and the “institutions and legislative power, rather than a positive right. But, But, right. a positive than rather power, legislative and widened the it the right, of the nature while limited it the all of include to government responsible scope of was an ongoing one, not limited to election periods, to limited not one, ongoing an was executive restrain to operates that one a negative is it then Prime Minister of New Zealand, David Lange. Zealand, Lange. David New of Minister then Prime event) (a rare Court unanimously the High held it, In political communication while of the freedom that v Broadcasting Australian Commission the on program Corners Four allegedly defamatory In 1997, this expansive approach to freedom of speech of freedom to approach 1997, this expansive In in Court decision the High its in in by reined was freedom to state laws and state political matters. In In political matters. state and laws state to freedom game. fair made it politicians effect, and extended the protection offered by the implied by implied the offered the protection extended and preacher brothers of the “Street Church”, Caleb and The more difficult decision, handed down on the same Samuel Corneloup, who expounded their gospel in day, is Monis v The Queenand Droudis v The Queen. Rundle Mall in Adelaide. They were convicted and Mr Monis wrote letters to the of soldiers fined for breaching a by-law made by the City Council killed on active service in . Beginning on which prohibited people from haranguing, canvassing a sympathetic note, the letters turned into a personal or preaching on a road without a permit or distributing attack on the deceased soldier. He was charged with printed matter on any road to passers-by. The same a provision of the Criminal Code (Cth) that prohibits by-law also prohibited using roads to repair vehicles, using the postal service in a way that reasonable collect donations, leading or driving livestock and persons would find offensive and convicted and his erecting structures such as fences, hoardings, ladders accomplice, Ms Droudis was charged with aiding and trestles. and abetting him. In response they challenged that provision of the Code on the ground that it infringed A challenge to their conviction eventually made its the freedom of political communication. way to the High Court. Applying the Lange test, the majority of the Court found that while the by-law All of the High Court found that the provision did burden the freedom of communication, its object did have that effect. The issue then was, under was the prevention of obstruction of roads, which the Lange test, whether it served a legitimate and Freedom of Speech, the Rule of Law and Political Debate Political and Law of Rule the Speech, of Freedom was conducive to the safe use of those roads. This, proportionate purpose. On that issue the Court was according to the majority was a legitimate object which split. In a joint judgment, Justices Crennan, Kiefel and is compatible with the maintenance of representative Bell found that that the provision had a protective

Kate Burns - Burns Kate and responsible government and the prohibition was purpose which was to prohibit the misuse of postal proportionate to that object. services to:

The critical point to note about the facts of this case “effect an intrusion of seriously offensive material into and the law in question is that it was not intended to a person’s home or workplace and that this purpose interfere with political communication; its purpose was not incompatible with the maintenance of the was quite different. It was intended to promote road constitutionally prescribed system of government”. safety and it did so in a measured way. In making this point, the Court picked up on a distinction it had They pointed out that in the United Kingdom, the previously made in its 2011 decision in Hogan v Hinch United States and New Zealand there are analogous concerning broadcaster Derryn Hinch’s assertion that offences protecting citizens from the receipt of suppression orders which can be made under the material through the post that is grossly offensive, Serious Sex Offenders Monitoring Act (Vic) to protect obscene or offensive, notwithstanding that those the identity of sex offenders are an invalid restriction also have a positive, constitutionally on the freedom of political communication. There entrenched, personal right of freedom of speech. the Court found that the purpose of the law was the The other three judges disagreed that the purpose of protection of the community by the effective operation the provision was “legitimate”. They were troubled of released sex offenders, which was a reasonably by the open-ended nature of the term “offensive” appropriate law adapted to serve a legitimate end. and the vague nature of its purpose. Was it to protect So it would be fair to say that if there is a law that the “integrity of the post” and, if so what does that is intended to promote the health or wellbeing of “integrity” mean? Or to protect an intrusion upon the the community, for example, the prevention of litter feelings of the recipient? Or to promote “civility of or the protection of children, but which also has the discourse”, in which case, per Coleman v Power, the consequence of restricting political communication, case about the Townsville Mall, that is not a legitimate then the High Court is unlikely to find it an object or end. unconstitutional limitation on freedom of speech According to Justice Hayne “the elimination of provided it is proportionate to its aim. communications giving offence, even serious offence, without more is not a legitimate object or end”. RoLIAwww.ruleoflaw.org.au 4 Kate Burns - Freedom of Speech, the Rule of Law and Political Debate Racial Racial RoLIA . www.ruleoflaw.org.au “shall declare an offence punishable by law all by law punishable offence an declare “shall or ideas based racial of superiority on dissemination as well as racial to discrimination, hatred, acts against such to incitement or all violence acts of or colour another of persons of group race or any assistance any of also ethnicthe provision and origin, thereof”. the financing activities, including racist to Having explored the breadth of the freedom of of the freedom of the breadth explored Having solidly beingthe most politicalcommunication, say to speech, I want of aspect freedom of founded on limitations many of the one about words final some publicity. of a lot received has speech that of freedom in and racial vilification, prohibiting the laws is It in the federal it of particular the prohibition 1975 Act Discrimination on racial discrimination prohibition The ratifiers the early of one was credit, its to Australia, of the Elimination on Convention the International of Racial This of Convention Discrimination. AllForms the after Nations the United of beenhad a priority War. the Second World of racially motivated states, ratifying that states the Convention Article 4 of law: called in international are countries as process starting with being charged or convicted of of convicted or being charged with starting process or action, a defamation dealingor with offence an kind. behaviour the offensive of charges political of freedom and in the rule law exercise of An think to students be ask could to communication express in which they might ways critically about the or political debate politicians, about their opinions expression that prohibit that the laws and , the to further, lead a step may that And opinion. of executive in the political and transparency need for happen not did so blatently the that kind of processes as Just Inquiry. ICAC the led recent to that in the events to been found have the24 Constitution sectionsand 7 political communication, of freedom of a right imply day one up end may those students of one perhaps a right also implies it Court in the High that arguing decision- government about information accurate to accountability. and making add). But, getting to the High Court to establish your your Court the establish High to to getting But, add). be to long a going is political communication of right , Justice Hayne Hayne , Justice Roberts v Bass Roberts 5 of political debate in this country (sadly, some might might some in this country (sadly, political debate of protect you. But if you target a politician then the a politician target if you But you. protect nature accepted reflecting the lower, much is standard upsetting , targeting members of the public the public of members targeting fashion, upsetting to as borderline is then it politicians than rather will political communication whether of the right And if, like Mr Monis, you use the postal you service Monis, Mr like if, And political and views in a veryyour strong express to then you will be unsuccessful because the right of will of be because thethenright you unsuccessful one. a negative only is political communication pamphlets in Rundle Mall, there is a good public safety safety a good is public there Mall, Rundle in pamphlets behaviour your prohibit to reason legitimate other or chance you will be successful in your argument that that willargument beyou successfulyour in chance police. of the actions condemn to entitled are you their out handing brothers the Corneloup if like But, condemning the actions of police, you fight your your fight you police, of the actions condemning Court, a good is the High to then there conviction that the High Court is determined to protect, within within Court protect, the High determined to is that Patrick student like If, test. the Lange of the limits Mall, in Townsville pamphlets out who gave Coleman communication, now and for the future for students? students? for the future for and now communication, speech of aspect freedom of this one is that clear is It the NSW Court of Criminal Appeal) stands. the NSW Court Criminal Appeal) of political of the freedom for mean doesSo that what upheld because there is a rule that when the outcome when a rule the is outcome because there that upheld (of appeal under thedecision quo, tied,is the The end result of the split in the High in the was Court that split of the result end The the NSW Court by in the matter decision the previous valid was were thecharges that Criminal Appeal of constitutionally prescribed system of government.” of system prescribed constitutionally debate and discourse is and must be continued if be continued must and is discourse and debate the of 24 sectionsin and 7 to referred people” “the part in the their proper play to are Constitution the consequent taking of offence can be eliminated eliminated be can offence taking of the consequent which in political the way radically altering without and cannot be, free from insult and invective. Giving Giving invective. and insult be, free from cannot and of consequences inevitable are taking offence and nor the giving Neither discourse. and political debate free from passion. It is not, and cannot be, free from be, free from cannot and not, is It passion. free from not, is It reason. to as well as the emotions to appeals Constitution. be, cannot and not, is discourse and debate “Political emphasised the “robust” nature of political debate in political debate of nature the “robust” emphasised the under deserves said which he protection Australia Like Justice Kirby in Kirby Like Justice When Australia ratified the Convention and complaint by a group of Aboriginal men in Western undertook to implement it within Australia, it Australia who complained about a newspaper cartoon reserved in relation to Article 4, not committing itself depicting them as government grant grabbing drunks. implementing that provision. As a result, the original As a result, none of the complaints were successful. version of the Racial Discrimination Act, which is Over the years, the only type of complaints that have the means by which the Convention applies within had any consistent measure of success in the courts Australia, did not contain any prohibition of what is have been those concerning anti-Jewish publications now known as racial vilification. After much debate, a and website and holocaust deniers, which reflects the watered down version of Article 4 was finally included II origin of Article 4 of the Convention. in amendments to the Act which came into effect in 1995. Which brings us to Eatock v Bolt, the case about commentator ’s pieces in the Herald Section 18C of the Act now prohibits doing an act Sun questioning the racial heritage of nine, what he that is reasonably likely to offend or humiliate a called, “fair-skinned Aborigines”. In his judgment, person on the ground of their race in a public place Justice Blomberg said that the fair comment defence that is not covered by the exemption in section 18D in s.18D of the Act extended to protect opinions that for artistic works, any genuine academic, artistic or “reasonable people would consider to be abhorrent”, Freedom of Speech, the Rule of Law and Political Debate Political and Law of Rule the Speech, of Freedom scientific purpose or any other genuine purpose in but they do need to be based on factual accuracies. the , or fair and accurate reports in the The case has generated a lot of media and kneejerk public interest or fair comment. Section 18C does not responses about the perils of racial vilification

Kate Burns - Burns Kate make it an offence to do such an act, it only makes legislation. Without adopting a position about that, it grounds for someone to make a complaint to the the best advice I can give about the case is to repeat Human Rights Commission. Justice Blomberg’s dicta and get the facts right about his judgment by reading it, before expressing an Once such a complaint is made, the Commission is opinion about it. It is a complex legal argument that obliged to investigate it and try and resolve it through is poorly served by being squashed into a screaming a confidential conciliation process. Only if that is not headline. As I have described today, freedom of speech successful, the original complainant is entitled to is a very complex concept with a lot of social and legal take the matter to court. If the court ultimately finds history behind it. that the act in question comes within the definition in section 18C, and is not covered by the exemption Postscript in 18D then it can make orders such as payment of compensation or an apology. Since writing this paper, Neville J of the Federal Circuit Court (formerly the Federal Pursuing a complaint in this way is not for the faint- Court) has handed down his judgment in the matter hearted. And it is fair to say that in the cases that of Banerji v Bowles dated 9 August 2013. The case have gone to court, the exemption for artistic works, concerned a claim by an employee of the Department genuine debate and fair comment have been robustly of Immigration and , Michaela Banerji, interpreted. For example, in a case about a play written by that the freedom of political communication entitled Louis Nowra and produced by the Melbourne Theatre her to express critical views in about Company called Miss Bosnia (Bryl v Anna Kovacevic the Department’s immigration , the company and Louis Nowra and Melbourne Theatre Company), managing security at detention centres, the Minister which arguably offended Bosnians and Herzogovians, and Opposition spokesman on immigration, the the Human Rights Commissioner the matter Prime Minister and the Opposition Leader and staff talked about a “margin of tolerance” that should be of the Department. These views were expressed in exercised”, and that a wide berth should be given to her personal capacity using an anonymous artistic works. This of a margin of tolerance was account. adopted in a subsequent case (Bropho v Human Rights and Commission) concerning a RoLIAwww.ruleoflaw.org.au 6 Kate Burns - Freedom of Speech, the Rule of Law and Political Debate - RoLIA www.ruleoflaw.org.au Nationwide News Pty Ltd v Willis [1992] HCA 46 [1992] HCA Pty v Willis Ltd News Nationwide 57 [2002] HCA v Bass Roberts [1994] HCA Ltd Newspapers Australian v West Stephens HCA [1994] Ltd Times Weekly & Herald v Theophanous tion of the City of Adelaide [2013] HCA 3 [2013] HCA Adelaide of City the of tion Meats Game Lenah v Commission Broadcasting Australian 63 Pty [2001] HCA Ltd Pty v Commonwealth Ltd Television Capital Australian 45 [1992] HCA [2013] FCCA 1052 v Bowles Banerji Commission Opportunity Equal and Rights v Human Bropho [2004] FCAFC 16 Melbourne and Nowra Louis and Kovacevic Bryl v Anna HREOCA [1999] 11 Company Theatre 39 HCA [2004] v Power Coleman [2011] FCA 1103 v Bolt Eatock 4 [2011] HCA v Hinch Hogan [1997] HCA Commission Broadcasting v Australian Lange 25 4 [2013] HCA Queen v the Monis Attorney-General for the State of South Australia v Corpora v Australia South of State the for Attorney-General • • • • • • • • • • • • • • • Case citations • 7 should be heard by a higher court, named the Federal the Federal higher a named court, by be heard should Court Australia. of of an ongoing dispute that may return to the Court, to return may that dispute ongoing an of in which case view J signalled in his Neville it that The matter may not rest there. Neville J’s judgment on judgment NevilleJ’s rest there. not may matter The part are very the was proceedings and brief the point J found that it was defeated by the terms of her her of the terms by defeated was it that J found the Code and Conduct of , of the Guidelines. to that status of a limit on governmental power to to power governmental on a limit of status that to Neville communication, certain of kinds prohibit maintenance of representative government. Having Having government. representative of maintenance political communication of the freedom reduced not a personal right of the kind protected in the United in the United the protected kind of a personal right not of a restriction but German , and States the the purpose supporting of for power legislative Crennan and Kiefel JJ in the City of Adelaide case, he case, he Adelaide of JJ in the City Kiefel and Crennan is political communication of the freedom that stated reference to the Lange test, pointing out that no no that out pointing test, the Lange to reference political of right “unfettered” or “unbridled” such of judgment the joint Quoting exists. communication protected political comment. political comment. protected Neville J with by dismissed was argument That contract of employment, the Code of Conduct and the the Code and Conduct of employment, of contract constitutionally to amounted remarks her Guidelines, Broadcasting Commission v Lenah Game Meats Pty Meats Lenah v Game Commission Broadcasting her notwithstanding that Ms Banerji argued Ltd, Citing the City of Adelaide case, the Lange Case case, the Lange Adelaide of the City Citing in Australian 2001 decision Court’s the High and perceived to be, harsh or extreme in its criticism or or criticism its in extreme or be, harsh to perceived other or parliament of a member the Government, policies. their respective and , Guidelines state that it is inappropriate for employees employees for inappropriate is it that state Guidelines is or is, that comment public unofficial make to and to be apolitical) and the Department’s Guidelines Guidelines the Department’s and be to apolitical) and Those Employees. DIAC Social of by Media Use on Australian Public Service Code of Conduct and Values Service Public Values Code and Australian Conduct of all times behave servants“at to public (whichrequire Australia” of the good reputation upholds that in a way being taken against Ms Banerji for expressing those expressing Banerji Ms for being taken against the employment, of contract her views to contrary The case arose in the context of disciplinary of action in context arose the caseThe Freedom of Speech, the Rule of Law and Political Debate Political and Law of Rule the Speech, of Freedom Kate Burns - Burns Kate

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