India exemplifies the global democratic recession. India’s recent downgrade to a hybrid regime is a major influence on the world’s autocratization. And the modality of India’s democratic decline reveals how democracies die today: not through a dramatic coup or midnight arrests of opposition leaders, but instead, it moves through the fully legal harassment of the opposition, intimidation of media, and centralization of executive power. By equating government criticism with disloyalty to the nation, the government of Narendra Modi is diminishing the very idea that opposition is legitimate. India today is no longer the world’s largest democracy.
This is one of five essays in a special package on the state of India’s democracy.
No country is a better exemplar of our global democratic recession than India. Most unlikely at its founding, India’s democracy confounded legions of naysayers by growing more stable over its first seven decades. India’s democratic deepening happened in formal ways, through the consolidation of civilian rule over the military as well as decades of vibrant multiparty competition, and informal ways, through the strengthening of norms around Electoral Commission independence and the increasing participation of women and other social groups in formal political life.
India has also witnessed two significant democratic declines: the 21-month period from June 1975 to March 1977 known as the Emergency and a contemporary decline beginning with Narendra Modi’s election in 2014. During Modi’s tenure, key democratic institutions have remained formally in place while the norms and practices underpinning democracy have substantially deteriorated. This informal democratic decline in contemporary India stands in stark contrast to the Emergency, when Indira Gandhi formally eliminated nearly all democratic institutions—banning elections, arresting political opposition, eviscerating civil liberties, muzzling independent media, and passing three constitutional amendments that undermined the power of the country’s courts.
Yet democracy watchdogs agree that today India resides somewhere in a nether region between full democracy and full autocracy. While democracy-watching organizations categorize democracies differently, they all classify India today as a “hybrid regime”—that is, neither a full democracy nor a full autocracy. And this is new. In 2021, Freedom House dropped India’s rating from Free to Partly Free (the only remaining category is Not Free). That same year, the Varieties of Democracy (V-Dem) project relegated India to the status of “electoral autocracy” on its scale of closed autocracy, electoral autocracy, electoral democracy, or liberal democracy. And the Economist Intelligence Unit moved India into the “flawed democracy” category on its scale of full democracy, flawed democracy, hybrid regime, and authoritarian regime. India’s democratic downgrading moved 1.4 billion of the world’s 8 billion people into the category of autocratizing countries. Its drop from Free to Partly Free fully halved the share of the world living in a Free country.1 Wherever you draw the conceptual lines between the land of democracy, the sea of autocracy, and the marshlands marking the hybrid regions, our democratic world is considerably less populous without India among its ranks. The question of whether India is a democracy today is not just pivotal to our analysis of the country’s political future but to our understanding of democratic trends more broadly. India, this year the world’s most populous country, is where the global battle for democracy is being fought.
Some disagree that India has substantively deteriorated into hybrid-regime territory. Unsurprisingly, the Indian government has reacted with accusations of Western bias, calling India’s democratic downgrade “misleading, incorrect and misplaced.”2 In August 2022, the Economic Advisory Council to India’s prime minister released a working paper calling out inconsistencies in democracy rankings. Yet there is reason why regime assessments, like a central bank’s interest rates, are best made by independent organizations. Notably, democracy watchdogs have not been shy about critiquing the quality of Western democracies.
But a minority of independent voices also resist India’s recategorization as a hybrid regime. In the article “Why India’s Democracy Is Not Dying,” Akhilish Pillalamarri writes that “cultural and social trends [in India today] are not necessarily evidence of democratic backsliding, but are rather evidence of social norms in India that are illiberal toward speech, individual expression, and criticism.”3 So has India really departed the shores of democracy? And if so, is India’s transition into a hybrid regime reversible? The answer to both questions is yes.
What’s in a Name?
To evaluate India’s democratic downgrading, it is first necessary to define democracy, both because adjudicating the debate over India’s democratic decline rests on conceptual clarity and because democracy undoubtedly connotes normative legitimacy. Democracy is a concept that instantiates a system of government that is “of the people, by the people, and for the people,” to quote Abraham Lincoln. Clarity on the non-normative dimensions of democracy that operationalize this idea points us toward the criteria we can use to assess the state of India’s democracy.
Scholars mostly agree that five institutions are central to a country’s designation as democratic. Of these five institutions, elections for the chief executive and legislature are the first and most important. The second institutional pillar of democracy is thus the presence of genuine political competition. Countries where individuals have the right to vote in elections, but where incumbents make it difficult for the opposition to organize are not generally considered democracies. Democracy also requires governmental autonomy from other forces—such as a colonial ruler or powerful military elites—that can halt or wholly subvert democratic elections; this autonomy is the third institutional pillar.
Two more institutions are also conceptually crucial to democracy because they enable both citizens and independent branches of government to evaluate the government’s performance: civil liberties (both de jure and de facto), the fourth pillar, and executive checks, the fifth pillar. Many prominent scholars have correctly argued that definitions of democracy which do not include basic civil liberties are inadequate.4 An independent press that enables the formation of critical public opinion is increasingly understood as being part of this civil-liberties pillar. The final institutional pillar of democracy, executive checks, is what prevents an elected head of government from declaring l’état, c’est moi. Democracy is a set of institutions that embed a practice of government accountability. This accountability takes two forms: vertical accountability between the people and the highest levels of elected government, typically elections and alternative political forces; and horizontal accountability between the executive and independent institutions, typically independent legislatures and courts that can constrain an elected executive from trampling on civil liberties.
Two important points follow from this five-pillar conceptualization of democracy that are germane to our assessment of India’s contemporary democratic decline. The first is that the scholarly definition of democracy has rightly expanded over time. In the past half-century, as authoritarian leaders have learned to adopt the window-dressing of democracy while quashing those institutions essential to its functioning, democracy watchdogs have wisely adapted by seeking to better assess whether government institutions embody accountability and whether institutional rights exist not just in law but in practice.
One specific way in which scholarly conceptions of democracy have expanded is a newfound understanding of the importance of institutional norms in buttressing democracy. As Nancy Bermeo prophetically wrote in these pages in 2016, we are living in an age of democratic backsliding characterized by the decline of overt democratic breakdown. Coup d’états are being replaced by promissory coups (presenting “the ouster of an elected government as a defense of democratic legality”); executive coups are being replaced by executive aggrandizement (“elected executives weaken checks on executive power one by one, undertaking a series of institutional changes that hamper the power of opposition forces to challenge executive preferences”); and election-day vote fraud is being replaced by preelection strategic manipulation (reflecting “a range of actions aimed at tilting the electoral playing field in favor of incumbents”). In other words, democratic decline is assuming the form of an incremental undermining of democratic institutions wherein “troubled democracies are now more likely to erode than shatter.”5
And the clearest signs of such democratic erosion are that elected leaders question the legitimacy of all opposition and use every available legal tool to undermine it. Drawing on a broad range of historical cases, Steven Levitsky and Daniel Ziblatt argue that unwritten rules and norms of behavior toward political opposition are the key to preventing such democratic deterioration. They argue that the two most important norms are opposition tolerance, meaning that political opponents are not treated as enemies but simply as political rivals, and forbearance, that is, limited use of the legal methods to steamroll opposition, such as executive orders, vetoes, and filibusters.6 Contemporary democratic backsliders tend not to transform overnight to autocracies. Instead, democracies slowly die when opposition is no longer tolerated and when elected politicians use the full might of the law to quash rather than compromise with political opposition.
India’s contemporary democratic decline is a paradigmatic case of these crucial democracy-supporting norms sharply eroding. The formal institutions of India’s democracy (largely reflected in Freedom House’s political-rights category and corresponding to the elections, competition, and autonomy pillars of democracy) have remained relatively stable over the past decade. India’s civil-liberties ranking, in contrast, has eroded year on year since 2019, dropping from 42 (out of a possible 60) points in 2010 to 33 in 2023. It is this nine-point drop in Freedom House’s civil-liberties index that has moved India from the category of democracy (those generally score above 70) to the terrain of a hybrid regime (generally scoring between 35 and 70). And, as I detail below, the downgrade is warranted.
A second, related point is that the same regime can become autocratic in decidedly different ways at different points in time. And different regimes can be equally undemocratic, but for different reasons. Democratic recessions need not assume a dramatic form, like military coups or the kind of autogolpe that India witnessed under Indira Gandhi’s Emergency. In 2023, Freedom House classified both Iraq and Mali as Not Free and gave them the exact same score of 29—but for radically different reasons. Mali ranks low on political rights (8 out of 40 possible points) because the country has not yet returned to having regular elections after military coups. But Mali ranks high among full autocracies for civil liberties (21 out of 60 possible points) because its media are relatively independent and it has broad rights to dissent and free speech. By contrast, Iraq scores relatively high among full autocracies on political rights (16 out of 40 possible points) because it holds regular, competitive elections, and its various religious and ethnic groups maintain representation within the political system. Yet Iraq does less well on civil liberties (13 out of 60 possible points) because of frequently documented cases of militias depriving citizens and journalists of liberties. Countries can dip below the democratic threshold by declining sharply in some domains. But they can also dip into hybrid-regime territory by declining only somewhat across a broad range of indicators—and this is what we see in contemporary India.
Stable Rights and Declining Liberties
India’s democracy was never very high-quality. The formal exercise of autonomous, competitive elections with a broad range of civil liberties—while it did translate into a mass poverty-alleviation program and the world’s largest affirmative-action program—always had plenty of shortcomings. But democracy also had a built-in autocorrect feature, which allowed incumbents to be turned out of power. That autocorrect feature is endangered today in mostly informal ways. In terms of Freedom House’s political-rights score (encompassing the pillars of elections, competition, and autonomy), India’s average for the nine years before Modi came to power was the same as for the nine years since 2014. Incumbent turnover remains electorally possible but improbable because the Modi government has substantially eroded the de facto protection of civil liberties and executive constraints—the fourth and fifth pillars of democracy. It is the drop in India’s civil-liberties rating that accounts for its contemporary democratic decline.
The legal right to dissent, historically only erratically protected in Indian courts, remains legally in place while the practical possibility of vocal dissent free from overwhelming harassment has virtually disappeared. To be sure, India’s media, while generally vibrant and free, were sometimes censored before Modi’s Bharatiya Janata Party (BJP) government came to power in 2014. But today, while the media remain legally free to dissent, widespread harassment of independent journalism and concentrating ownership structures have meant that journalists and individuals practice a high degree of self-censorship. Checks on executive power, while formally in place, are rapidly falling away.
Radically constrained civil liberties. Since 2016, civil liberties have been curtailed, to some extent legally and to a significant extent practically. CIVICUS, an international organization that tracks global civil liberties in 197 countries, now classifies India as “repressed” on its declining scale of open, narrowed, obstructed, repressed, and closed. The downgrade from “obstructed,” which happened in 2019, meant that India’s civic space was, according to the organization’s website, one where “civil society members who criticise power holders risk surveillance, harassment, intimidation, imprisonment, injury and death.” Among its neighbors, India is now in the same ratings category as Pakistan and Bangladesh, and in a lower category than Nepal and Sri Lanka.
The Modi government has increasingly employed two kinds of laws to silence its critics—colonial-era sedition laws and the Unlawful Activities Prevention Act (UAPA). Authorities have regularly booked individuals under sedition laws for dissent in the form of posters, social-media posts, slogans, personal communications, and in one case, posting celebratory messages for a Pakistani cricket win. Sedition cases rose by 28 percent between 2010 and 2021. Of the sedition cases filed against citizens for criticizing the government, 96 percent were filed after Modi came to power in 2014. One report estimates that over the course of just one year, ten-thousand tribal activists in a single district were charged with sedition for invoking their land rights.7
The Unlawful Activities Prevention Act was amended in 2019 to allow the government to designate individuals as terrorists without a specific link to a terrorist organization. There is no mechanism of judicial redress to challenge this categorization. The law now specifies that it can be used to target individuals committing any act “likely to threaten” or “likely to strike terror in people.” Between 2015 and 2019, there was a 72 percent increase in arrests under the UAPA, with 98 percent of those arrested remaining in jail without bail.8
The frequent invocation of these strengthened laws is substantively new and has significantly chilled dissent. The state has intimidated opposition by broadly labeling criticisms of government policy as contrary to the national interest, or “anti-national,” and by employing an army of volunteers to identify problematic online dissent. BJP politicians have popularized the term “anti-national” in patterns that target individuals, causes, and organizations.9 Academics were first to be targeted, with university administrators and faculty investigated, disciplined, or compelled to step down owing to their perceived political views. But such tactics were quickly broadened to include any high-profile dissenters.
India’s Muslim community, comprising 14 percent of the population, has suffered a particularly marked decline in civil liberties. Acts of anti-Muslim violence, including lynchings or mob killings, have risen sharply. According to IndiaSpend, bovine-related mob-lynching deaths (involving rumors of those handling beef, typically Muslims) have substantially risen as a proportion of violence in India since 2010, with 97 percent of bovine-related attacks between 2010 and 2017 occurring after Modi came to power in 2014. A majority of the victims of public killings are believed to have been Muslim. India’s largest minority now lives in a “widespread climate of fear” according to most independent international organizations reporting on such matters, including Human Rights Watch and the U.S. Commission on Religious Freedom.10 With Parliament’s passage of the Citizenship Amendment Act in 2019, discrimination against Muslims assumed legal form, specifically excluding Muslim refugees from a streamlined citizenship process. Observers believe this Act, together with a planned national register of citizens, will be used in tandem to disenfranchise Muslim voters who lack the paperwork to prove they are citizens. India’s only Muslim-majority state, Jammu and Kashmir, is experiencing a shutdown of its civil liberties that is in every major respect similar to India’s Emergency—a fact reflected in Freedom House’s separate categorization of Indian Kashmir as Not Free.
Constrained individual freedom to dissent is compounded by legal constraints on the freedom of assembly. A 2021 International Center for Not-For-Profit Law report assessing freedom of assembly in India found: “A punitive, security-focused approach has been increasingly deployed, amidst a growing trend of demonizing and criminalizing public protests, including the vilification of assembly organizers.”11
The government has frequently barred access to the internet, the de facto means of coordinating protest. India not only leads the world in government-directed internet shutdowns, with 84 government-directed shutdowns in 2022, but these blackouts are typically imposed before and during protests to impede effective public coordination, often without clear criteria for suspension.12 The report finds that while de jure protections for speech and assembly have eroded only marginally, de facto protections have significantly decreased.
The government’s critics in civil society are frequent targets of administrative harassment. In 2020, the Modi government tightened the Foreign Contribution Regulation Act (FCRA) to choke civil society independence, targeting the logistics of foreign-fund transfers, limiting the nature of spending and the sharing of funds between NGOs, giving the central and state governments the right to suspend NGOs at discretion, and forbidding public servants from joining organizations. Government authorities have systematically used financial audits and tax-related raids on technical but fully legal grounds against a wide range of civil society groups, including Amnesty International, Greenpeace, the Centre for Policy Research, the Ford Foundation, the Lawyers Collective, and Oxfam.13
Over the last decade, Indian media have radically circumscribed their criticism of government due to outright intimidation and structural changes. Since 2014, India has fallen to 161st out of 180 countries in Reporters Without Borders’ World Press Freedom Index, ranking below Afghanistan, Belarus, Hong Kong, Libya, Pakistan, and Turkey. According to the organization, Indian journalists sometimes receive death threats and are frequent targets of social-media hate campaigns driven by troll farms affiliated with the government. Major media networks do not feel free to criticize the Modi government. One study analyzing prime-time television debates on the channel Times Now over three months in 2020 found not a single episode in which a debate criticized the Modi government in any form. A separate study of RepublicTV from 2017 through 2020 found coverage to be “consistently biased in favour of the Modi government and its policies.”14 Modi himself has limited his interactions with the media, holding not a single press conference in the last nine years.
Practices such as selective licensing, the acquisition of independent networks by Modi-affiliated businessmen, and harassment of the few remaining independent outlets further undermine media independence. The government must grant a license to broadcast television, for example, and will deny licenses to critical domestic organizations. The government withheld a license from the founder of the news website Quint, Raghav Bahl (working in partnership with Bloomberg), for so long that he closed the company’s television division. Bahl was investigated and charged with money laundering in 2019.
While the sheer number of news organizations in India would seem to indicate a thriving media, scrutiny of the functional ownership structure indicates otherwise. The independent Media Ownership Monitor finds in India “a significant trend toward concentration and ultimately control of content and public opinion.”15 Mukesh Ambani, a businessman with close ties to Modi, directly controls media outlets followed by at least 800 million Indians. Another close Modi associate, Gautam Adani, acquired India’s last major independent television network, NDTV, in December 2022.16 According to analysts, Adani’s acquisition of NDTV “marks the endgame for independent media in India, leaving the country’s biggest television news channels in the hands of billionaires who have strong ties to the Indian government.”17 While there are a handful of smaller, determined sources of independent news left, they have faced tax raids and lawsuits for their reporting since 2013.
The government also targets international news organizations for their criticism, typically portraying critical foreign news reports as part of a plot to hold back India’s global ascendance. The Indian offices of the British Broadcasting Corporation were raided in February 2023, just weeks after the news organization released a documentary critical of the Modi government. Laws used under the Emergency were invoked just months ago to ban both the BBC documentary and any clips from circulating within India. As the raids occurred, BJP spokesman Gaurav Bhatia called the BBC the “most corrupt organisation in the world.”18 When a few of the dozen Indian students I teach organized a private screening of this documentary at Oxford University, the fear among them was palpable. Invitees were asked to refrain from posting on social media and from exchanging WhatsApp messages, since videos have documented police asking individuals to unlock their phones during routine stops.19
The loss of horizontal accountability. Legislative scrutiny of executive action has been waning in real terms during Modi’s government. Committees of India’s primary parliamentary bodies serve as a key check on the executive, closely examining and debating the merits of all bills. Committees scrutinized 71 percent of bills in the 2009–14 parliament before Modi came to power and just 25 percent of bills in the 2014–19 parliament under Modi’s first term. Since 2019, such scrutiny has declined to 13 percent, with not a single legislative bill sent to a committee during the 2020 pandemic. Some of India’s most important laws and political decisions in recent years—the imposition of a national lockdown with four hours’ notice, demonetization, farm laws—were passed without parliamentary consultation and over opposition protest. The Modi government also introduced a raft of legal amendments to weaken whistleblower protection.20
The growing lack of executive accountability to Parliament is exacerbated by an increasingly quiescent judiciary. The Supreme Court is the custodian of India’s constitution and through it, of civil liberties. During the two decades before 2014, the independence of the Supreme Court was seen to grow mightily, earning it the moniker of the “most powerful apex court in the world.”21 This has notably changed, with the central government controversially transferring independent-minded justices and minimizing norms that checked executive power.22 Such moves prompted the four most senior members of India’s Supreme Court to hold an unprecedented press conference in 2018, warning that the chief justice’s unusual assigning of cases could be a sign of political interference. One of those four justices, Jasti Chelameswar, also penned an open letter to the chief justice, admonishing that the “bonhomie between the Judiciary and the Government in any State sounds the death knell to Democracy.”23 The Supreme Court’s rulings on every major political issue that has come before it—the Ayodha temple, the Aadhar biometric ID system, habeas corpus in Kashmir, electoral bonds, the Prevention of Money Laundering Act—have gone in favor of the Modi government. This marks a break from the past. The practical difference between the Supreme Court during the Emergency and today is minimal. Some even argue that, today, an Emergency is simply “undeclared.”24
Can Indian Democracy Be Saved?
Democracy in India, as elsewhere in the world, is not today dying through a military coup or the dramatic, coordinated mass arrests of opponents. Instead, autocrats have learned to talk democratically and walk autocratically, maintaining a legal façade of democracy while harassing opposition and shrinking space for loyal dissent. While India’s formal institutions of democracy are also under pressure—Modi’s most prominent political rivals have recently been disqualified from running in elections—it is primarily the inability of the ordinary citizen to read critical appraisals of government policy, to speak and assemble freely without fear of harassment as well as the absence of substantive checks on executive power that have transitioned India into a hybrid regime.
Although India’s democratic slide is real, it is not irreversible. While hybrid regimes are often stable, elections remain real moments of accountability, so long as the ballots remain secret and elections fairly monitored. Even wholly autocratic regimes with thoroughly honed policies of surveillance are subject to moments of effective protest because the very structures of autocratic power also prevent such regimes from gaining an accurate understanding of citizens’ concerns—what democracies do best. Recent protests against China’s zero-covid strategy, Iran’s morality police, and India’s farm laws have all highlighted the enduring possibilities of mass dissent.
Going forward, India’s surest route to democratic revival lies in the emergence of a genuine opposition party with well-developed organizational roots. The Indian National Congress was once such a party, but its grassroots linkages disappeared in 1969 when Indira Gandhi split the party and cut off grassroots-party infrastructure in her bid to centralize power. Congress’s success in the recent state assembly elections in Karnataka, the southern state that is home to India’s Silicon Valley, underlines the BJP’s ongoing electoral vulnerability and likely owes something to Rahul Gandhi’s grassroots campaign, Bharat Jodo Yatra.25 On a smaller scale, the Aam Aadmi Party is a promising political force that has managed to move beyond its Delhi base. But both parties face a long battle to enduringly develop beyond their charismatic leaders. And as ever, power must be well organized beyond individuals before it can be effectively used. Set against the BJP, whose organizational roots have been growing for nearly a century, this will be a tall order. But not an impossible one.
NOTES
1. Freedom House, Freedom in the World 2022, https://freedomhouse.org/sites/default/files/2022-02/FIW_2022_PDF_Booklet_Digital_Final_Web.pdf.
2. “‘Misleading, Incorrect, Misplaced’: Centre Reacts to India’s Downgrading in Think Tank Report,” The Wire, 5 March 2021, https://thewire.in/government/freedom-house-partly-free-government-reaction.
3. Akhilesh Pillalamarii, “Why India’s Democracy Is Not Dying,” The Diplomat, 14 June 2021, https://thediplomat.com/2021/06/why-indias-democracy-is-not-dying/.
4. Marc F. Plattner, “Globalization and Self-Government,” Journal of Democracy 13 (July 2002), 56–57.
5. Nancy Bermeo, “On Democratic Backsliding,” Journal of Democracy 27 (January 2016): 8–14.
6. Steve Levitksy and Dan Ziblatt, How Democracies Die (New York: Crown 2018).
7. On the cricket sedition charge, see “UP Invokes Sedition Against Kashmiri Students; Families, Activists Urge for Release,” The Wire, October 2021, https://thewire.in/rights/up-invokes-sedition-against-kashmiri-students-families-activists-urge-for-release; on the rise in cases, see Kunal Purohit, “Our New Database Reveals Rise in Sedition Cases in the Modi Era,” Article 14, 2 February 2021, www.article-14.com/post/our-new-database-reveals-rise-in-sedition-cases-in-the-modi-era; Supriya Sharma, “10,000 People Charged With Sedition in One Jharkhand District. What Does Democracy Mean Here?” Scroll.in, 19 November 2019, https://scroll.in/article/944116/10000-people-charged-with-sedition-in-one-jharkhand-district-what-does-democracy-mean-here.
8. “UAPA: 72% Rise in Arrests Between 2015 and 2019,” The Wire, 10 March 2021, https://thewire.in/government/uapa-72-rise-in-arrests-between-2015-and-2019.
9. Meenakshi Ganguly, “Dissent Is ‘Anti-National’ in Modi’s India,” Human Rights Watch, 13 December 2019, www.hrw.org/news/2019/12/13/dissent-anti-national-modis-india; A. Sharma and J. Pal, “Indian Twitter and Its Anti-Nationals,” University of Michigan unpubl. ms., 2020, http://joyojeet.people.si.umich.edu/antinationals.
10. Sandipan Baksi and Aravindhan Nagarajan, “Mob Lynchings in India: A Look at Data and the Story Behind the Numbers,” Newslaundry, 4 July 2017, www.newslaundry.com/2017/07/04/mob-lynchings-in-india-a-look-at-data-and-the-story-behind-the-numbers; “Uttar Pradesh: India’s Muslims Victims of Hate Crimes Live in Fear,” BBC News,21 February 2022, www.bbc.com/news/world-asia-india-60225543.
11. Vrinda Grover, “Assessing India’s Legal Framework on the Right to Peaceful Assembly,” International Center for Not-for-Profit Law, December 2021, www.icnl.org/post/report/assessing-indias-legal-framework-on-the-right-to-peaceful-assembly.
12. Murali Krishnan, “India: ‘Internet Shutdown Capital of the World,’” Deutsche Welle, 15 March 2023, www.dw.com/en/india-internet-shutdown-capital-of-the-world/a-64997062.
13. Aakar Patel, Price of the Modi Years (Delhi: Vintage, 2022), ch. 5; Ganguly, “Dissent Is ‘Anti-National’ in Modi’s India.”
14. Christophe Jaffrelot and Vihang Jumle, “One-Man Show,” Caravan, 15 December 2020, https://caravanmagazine.in/media/republic-debates-study-shows-channel-promotoes-modi-ndtv.
15. Media Ownership Monitor, India, 2023, http://india.mom-gmr.org/en/.
16. “BloombergQuint Gives Up After Three Years, Suspends TV Division,” 20 April, 2020, Newslaundry, www.newslaundry.com/2020/04/22/bloombergquint-gives-up-after-three-years-suspends-tv-division; Reports Without Borders, India Country Report 2023, https://rsf.org/en/country/india. Anjana Krishnan, Reuters Institute, Oxford University, India Report 2022, https://reutersinstitute.politics.ox.ac.uk/digital-news-report/2022/india.
17. Astha Rajvanshi, “India’s Richest Man Is Buying a Major TV Channel. It’s a Blow to Independent Media in the Country,” Time, 1 December 2022, https://time.com/6238075/india-ndtv-gautam-adani-narendramodi/.
18. Hannah Ellis-Petersen, “Indian Journalists Say BBC Raid Part of Drive to Intimidate Media,” Guardian, 18 February 2023, www.theguardian.com/world/2023/feb/18/indian-journalists-bbc-raid-media.
19. Umang Poddar, “Can the Police in India Force Someone to Hand Over Their Phone and Check Their Messages?” Scroll.in, 4 November 2021, https://scroll.in/article/1009529/can-the-police-in-india-force-someone-to-hand-over-their-phone-and-check-their-messages.
20. Sani Ali and Amber Sharma, “In Modi Era, the Role of Parliamentary Committees Is Getting Diminished,” Scroll.in, 16 September 2020; Zoya Hasan, “Indian Parliament Is Diminished by Official Disruption,” The Wire, 9 April 2023; “80 RTI Activists Killed Since 2014, Yet Modi Govt ‘Refuses’ to Implement Whistleblowers Act,” The Counterview, 12 December 2019.
21. S.P. Sathe, Judicial Activism in India: Transgressing Borders and Enforcing Limits (New Delhi: Oxford University Press, 2002), 249.
22. Manu Sebastian. “ How Has the Supreme Court Fared During the Modi Years?” The Wire, 12 April 2019, https://thewire.in/law/supreme-court-modi-years.
23. J. Chelameswar, “Bonhomie Between Judiciary, Government Sounds Death Knell to Democracy,” Scroll.in, 29 March 2018, https://scroll.in/article/873787/full-text-bonhomie-between-judiciary-and-government-sounds-the-death-knell-to-democracy.
24. Arvind Narrain, India’s Undeclared Emergency: Constitutionalism and the Politics of Resistance (Delhi: Westland Publications, 2021).
25. Ashutosh Varshney, “Democratic Unclogging,” Indian Express, 18 May 2023.
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