सं Samvidhan

Bharatiya Nyaya Sanhita, 2023

Section 72

Disclosure of identity of victim of certain offences, etc

Why this exists

This provision continues the protection first introduced into Indian law through Section 228A of the Indian Penal Code, added in 1983 after public outrage over the Supreme Court's Mathura rape case judgment, which had exposed how victims of sexual violence faced social stigma, harassment, and re-traumatisation when their identities became public. Parliament wanted to shield survivors from the shame and danger of being publicly named in media reports, and to encourage victims to come forward without fear of social exposure. The Bharatiya Nyaya Sanhita, 2023 carries this protection forward and updates the cross-referenced offence sections to match the new code.

How courts read it

Under the predecessor provision (Section 228A IPC), the Supreme Court in State of Punjab v. Gurmit Singh (1996) stressed that the identity of rape victims must not be disclosed, even in judgments, and courts should refer to them anonymously or by initials. Later, in Nipun Saxena v. Union of India (2018), the Supreme Court laid down detailed guidelines requiring courts, police, and media to protect the identity of victims of sexual offences, especially children, restricting even courts from disclosing names in orders and mandating that FIRs relating to such offences not be uploaded publicly with identifying details. These rulings shaped how the exceptions (police investigation, victim's own consent, or next of kin's consent through a recognised institution) are understood and applied strictly.

Common misconceptions
  • Myth: The law only stops newspapers from naming victims; social media posts don't count.
    Fact: The law applies broadly to any 'printing or publishing' of identifying information, which courts have interpreted to include digital and social media disclosures, not just traditional print press.
  • Myth: A journalist can publish a rape victim's name if the family agrees informally.
    Fact: The law requires specific written authorisation, and if the victim is dead, a child, or of unsound mind, that consent must go only to the head of a government-recognised welfare organisation — not directly to media or others.
  • Myth: This law prevents courts from ever mentioning the victim's details.
    Fact: Courts and police may use victim details internally for investigation and trial, but public disclosure identifying the victim is restricted; the Supreme Court has directed courts to use non-identifying references (like initials) even in judgments.