Question

In which of the following cases the Supreme Court of India held, “… even if the press is present, if individual members of the public are refused admission, the proceedings cannot be considered to go on in open courts”?

• A. State of Maharashtra v. Dr. Praful B. Desai, (2003) 4 SCC 601.
• B. A.M Mathur v. Pramod Kumar Gupta, (1990) 2 SCC 533.
• C. Mohammed Shahabuddin v. State of Bihar, (2010) 4 SCC 653.
• D. Dr. Raghubir Saran v. State of Bihar, (1964) 2 SCR 336.
• A. Swapnil Tripathi v. Supreme Court of India, (2018) 10 SCC 639.
• B. Swapnil Tripathi v. Supreme Court of India, (2018) 10 SCC 639.
• C. M.K. Ranjitsinh v. Union of India, 2021 SCC OnLine SC 326.
• D. Aparna Bhat v. State of Madhya Pradesh, 2021 SCC OnLine SC 230.
• A. It is pertinent that the public be informed regarding the working of courts of justice.
• B. Public trial in open court is detrimental to healthy, objective and fair administration of justice.
• C. Trial held subject to the public scrutiny and gaze is conducive to judicial caprice or vagaries.
• D. Publicity is the very soul of justice as it keeps the Judge himself while trying under trial.
• A. Fair administration of justice is a means to ensure public trial, not an end.
• B. In case of a conflict between fair administration of justice and public trial, public trial may have to be regulated in the interest of administration of justice.
• C. Open court principle is not an inflexible and universal rule.
• D. Exceptions to rule of open courts ensure that justice is never defeated.
• A. Section 237(1)
• B. Section 353(1)
• C. Section 327(1)
• D. Section 274(1)
• A. Technological dexterity.
• B. Lack of knowledge gained during court proceedings.
• C. Lack of awareness about court proceedings.
• D. Both (A) and (B).

Answer 1

The Correct Option is C

The correct option is (C) : Mohammed Shahabuddin v. State of Bihar, (2010) 4 SCC 653.

Answer 2

The excerpt discusses the open-court principle and its narrow exceptions. The question asks in which case the Supreme Court held that proceedings cannot be considered open if individual members of the public are refused admission, even when the press is present.

1. Option A: State of Maharashtra v. Dr. Praful B. Desai concerns the admissibility of evidence recorded through video conferencing, not the specific proposition about public admission distinct from press presence.
2. Option B: A.M. Mathur v. Pramod Kumar Gupta concerns judicial restraint and propriety in exercising contempt jurisdiction, not the open-court/public-admission principle described in the excerpt.
3. Option C: Mohammed Shahabuddin v. State of Bihar contains the specific proposition that the presence of the press alone does not satisfy the requirement of an open court if ordinary members of the public are excluded - the press being present is not a substitute for public access itself.
4. Option D: Dr. Raghubir Saran v. State of Bihar deals with the scope for holding in-camera trials, but does not contain this precise formulation distinguishing press presence from public admission.

Only option (C) contains the specific holding that excluding individual members of the public defeats the open-court requirement even if the press is allowed in.

Hence, the correct answer is (C) Mohammed Shahabuddin v. State of Bihar, (2010) 4 SCC 653.

Answer 3

The correct option is (D) : Aparna Bhat v. State of Madhya Pradesh, 2021 SCC OnLine SC 230.

Answer 4

The question asks in which case the Supreme Court, while treating live-streaming as an extension of the open-court principle, used the phrase "sunlight is the best disinfectant."

1. Options A and B: Both list Swapnil Tripathi v. Supreme Court of India, (2018) 10 SCC 639. This is the judgment permitting live-streaming of court proceedings in matters of constitutional and national importance, reasoning that transparency through live-streaming furthers public trust and accountability in the justice system. It is in this judgment that the phrase "sunlight is the best disinfectant" was invoked to justify opening court proceedings to wider public view through live transmission.
2. Option C: M.K. Ranjitsinh v. Union of India concerns protection of an endangered species and environmental law, not live-streaming of court proceedings.
3. Option D: Aparna Bhat v. State of Madhya Pradesh concerns bail conditions and judicial sensitisation in cases of sexual offences - it does not address live-streaming of proceedings or the open-court rationale linked to this phrase.

The reasoning and the specific phrase described belong to the live-streaming judgment, not to a case on an unrelated subject such as bail conditions or environmental protection.

Hence, the correct answer is Swapnil Tripathi v. Supreme Court of India, (2018) 10 SCC 639, listed as options (A) and (B).

Answer 5

The correct option is (A) : It is pertinent that the public be informed regarding the working of courts of justice.

Answer 6

The question asks which statement is true regarding the significance of open courts.

1. Option A: This states that it is important for the public to be informed about how courts function. This aligns with the core rationale for the open-court principle - public knowledge of judicial proceedings sustains confidence in, and scrutiny of, the justice delivery system, and is a foundational justification repeatedly recognised by courts.
2. Option B: This claims public trial is detrimental to fair and objective administration of justice - this is the opposite of the settled rationale, which treats openness as a safeguard for fairness, not a threat to it.
3. Option C: This claims public scrutiny is conducive to judicial caprice, again reversing the accepted rationale - public gaze is understood to discourage arbitrary or capricious conduct by keeping proceedings accountable, not to encourage it.
4. Option D: This frames publicity as the entire and complete essence of justice by itself. While transparency does discipline judicial conduct, phrasing it as the singular, all-encompassing "soul" of justice overstates the principle beyond the more precise and defensible formulation in option A, which simply affirms the public's entitlement to be informed of how courts function.

Testing each option, only A is phrased as a precise, defensible statement of the open-court rationale, while B and C directly invert it and D overstates it.

Hence, the correct answer is (A) It is pertinent that the public be informed regarding the working of courts of justice.

Answer 7

The correct option is (C) : Open court principle is not an inflexible and universal rule.

Answer 8

This question asks which statement about the open court principle does not hold up, so each claim needs to be weighed against how courts actually apply the rule of public trial.

1. Option A: Courts have consistently held that public trial is the means by which fair administration of justice is secured, not a goal pursued for its own sake. Stating it as "fair administration of justice is a means to ensure public trial" keeps the same relationship between the two ideas, so this statement stands as an accurate description of why open courts matter.
2. Option B: Whenever open trial genuinely threatens a fair outcome, for instance where witness safety, victim dignity, or the integrity of the proceeding itself would be compromised, the public element is scaled back rather than the fairness of the proceeding. This is a correct account of how the two interests are reconciled.
3. Option C: This is the outlier. Presenting the rule of open courts as simply "not inflexible and universal", without any qualification, glosses over the fact that Indian courts treat public trial as the default and near-universal position under Article 145(4), Section 327 Cr.P.C., and Article 21, departing from it only in tightly defined, exceptional situations such as in-camera proceedings in sexual offence or matrimonial matters. Left unqualified, the statement understates how firmly the rule operates in practice, which is why it is the one that does not hold up.
4. Option D: The narrow exceptions carved out of the open court rule exist precisely so that intimidation, humiliation, or loss of candour in testimony does not defeat the underlying pursuit of justice, so this statement correctly captures the rationale for those exceptions.

Since A, B, and D each correctly state the relationship between open trial and fair administration of justice, option C is the statement that is not true.

Therefore, the correct answer is Open court principle is not an inflexible and universal rule.

Answer 9

The correct option is (C) : Section 327(1)

Answer 10

The question asks which provision of the Code of Criminal Procedure, 1973 lays down the general rule that a criminal court is deemed to be an open court.

1. Section 237(1): This provision deals with the procedure where a previous conviction is charged and denied, not with the openness of the courtroom, so it does not fit.
2. Section 353(1): This provision concerns the mode of delivering judgment, requiring it to be pronounced in open court, which presupposes the open court rule rather than creating it.
3. Section 327(1): This is the provision that expressly states the place where a criminal court sits for inquiry or trial shall be deemed an open court, to which the public generally has access, subject to the reasonable limits of the courtroom. This is exactly the general rule the question is asking about.
4. Section 274(1): This provision deals with the recording of evidence in cases other than warrant cases and summons cases, not with open courts.

Only Section 327(1) actually creates the general rule of open courts; the others govern unrelated procedural stages.

Therefore, the correct answer is Section 327(1).

Answer 11

The correct option is (C) : Lack of awareness about court proceedings.

Answer 12

The question is about what, among the public at large, gets in the way of the open court principle actually working as intended.

1. Option A: Technological dexterity, meaning familiarity with digital tools, is a positive capability rather than an obstacle. Its presence would if anything help access, not hinder it, so this cannot be the obstacle being described.
2. Option B: A shortfall in the knowledge a person might otherwise gain by attending or following proceedings is really a symptom of the same underlying problem rather than an independent obstacle, and it does not directly describe why members of the public are kept away from proceedings in the first place.
3. Option C: Most people simply do not know when, where, or how court proceedings are conducted, what their rights of access are, or how to make sense of what happens inside a courtroom. This lack of awareness is the practical barrier that keeps the open court principle from translating into genuine public engagement, even where courtrooms are technically open.
4. Option D: Since Option A describes a capability rather than a barrier, treating it as an obstacle alongside B is not sound, so combining the two overstates the answer.

The real, standalone obstacle is the public's lack of awareness about how court proceedings work and how to access them.

Therefore, the correct answer is Lack of awareness about court proceedings.