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Issues: Whether the leaflet was a pamphlet and therefore a book within the meaning of the Press and Registration of Books Act, 1867, so as to sustain the conviction for breach of the printing particulars requirement.
Analysis: Section 3 required every book or paper printed in India to bear the printer's name and place of printing. The Act defined "book" broadly to include a pamphlet, and the leaflet was a four-page unstitched composition containing systematic allegations against named individuals. A defamatory character did not exclude it from being treated as a treatise or pamphlet. The concurrent finding that it had been printed in the applicant's press could not be reopened in revision.
Conclusion: The leaflet was a pamphlet and therefore a book within the Act. The conviction and sentence were upheld.